Exxon Grease Plant - Executive Summary |
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Executive Summary This Risk Management Plan (RMP) has been created to fulfill the requirements of the Clean Air Act (CAA) 112(r). Under 112(r), there are categories of facilities: Program 1, Program 2, and Program 3. These categories of facilities are based on the potential for offsite public exposure from a worst-case accidental release, accident history, and the facility compliance status under the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standards. The major components of this RMP include a Hazard Assessment, a Management Program, a Prevention Plan, and an Emergency Response Program. The Hazard Assessment includes a Worst Case Analysis, several Alternative Release Scenarios, and a 5-year Accident History. The Prevention Program consists of safety information, hazard reviews, operating procedures, training, maintenance procedures, incident investigations, and compliance audits. The Emergency Response Program has been integrated into an Integrated Compliance Plan (ICP) for the entire facility. The Exxon Olathe Grease Plant is located at 1400 South Harrison in Johnson County. A site location map can be found in Section 1. The facility's current operation involves the manufacturing of lubricants and lubrications products. This includes the manufacturing and packaging of grease and specialty oils. The manufacturing process utilizes refined oils, combined additives to produce lubricants, and lubrication products including grease. Raw materials for the process are received via dray truck, tank truck, and tank car. Packaging materials are received by dray truck. Liquid raw materials are stored in tanks on the plant property both inside and outside. Packaged raw materials are stored on pallets in pallet racks until they are required in the manufacturing process. The lubricants and lubrication products are manufactured in a batch process in mixing and cooking kettles of various sizes. The cooking kettles are heated by eith er steam, or hot oil systems. Finished products are stored in the tanks within the warehouse, or in the manufacturing kettles until they are packaged. The finished products are manufactured in a variety of package styles and they are stored in the warehouse pallet racks until shipped to the various customers. Finished products are also loaded into bulk trucks and delivered to customers. The Exxon Olathe Grease plant currently operates in compliance with Air Permit #0910014. A representative of the Johnson County Environmental Department (JCED), acting as a designated agent for the Kansas Department of Health and Environment (KDHE), conducts annual inspections to verify compliance. Copies of the inspections, as well as the actual air permit, can be found in Section 1. The Olathe Grease Plant is also subject to EPCRA Tier II filing for toxic chemicals. Copies of the actual reporting forms for the chemicals (including TDI and CHA) can be found in Section 1 also. The two chemicals stored at the Exxon Grease Plant in quantities over the threshold values are Toluene-diisocyanate (TDI) and cyclohexylamine (CHA). TDI and CHA are brought in as raw materials and are essential in the production of various greases. These materials are received in bulk, nitrogen pressurized cylinders, and drums. Each is added at various times during the grease-making process at various temperatures and pressures. Copies of the Material Safety Data Sheets (MSDS) are in Section 5. Hazard Analysis Worst Case Scenario The worst case scenario for the Olathe Grease Plant has been determined to be an unloading accident. Cyclohexylamine is delivered to the plant via semi-truck. The CHA is stored in 50 gallon drums and the maximum Olathe can receive is 80 drums. For modeling purposes, it is assumed that the truck is overturned and all 80 drums are punctured. For worst case, it is assumed that the CHA is instantaneously released into the atmosphere. OCAG was used to determine the toxic endpoint. Assu mptions in the model are: 1) Wind Speed = 1.5 m/s 2) Stability Class = F 3) Air Temperature = 77 degrees Fahrenheit The toxic endpoint was estimated to occur at a distance of 0.87 miles from the center of the facility. Estimated population in that radius is 5200 people. The population was estimated using Environmental Data Resources, Inc. (EDR)'s Offsite Receptor Report. This report also helped locate environmental and public receptors in the area. A copy of this report can be found in Section 2. Alternative Release Scenarios Cyclohexylamine It was assumed that while the forklift operator was unloading a pallet consisting of 4-50 gallon drums, he accidentally dropped it. The CHA is released at 200 gallons/minute (i.e. liquid in all 4 drums is released within 1 minute). No mitigation measures were used. Other assumptions in the release scenario are: 1) Wind Speed = 3.0 m/s 2) Stability Class = D 3) Air Temperature = 77 degrees Fahrenheit The toxic endpo int was estimated to occur at a distance of 0.1 miles from the center of the facility. Estimated population in that radius is 520. Toluene - diisocyanate It was assumed that a valve or transfer hose malfunctions during unloading and 40,500 lbs. of TDI is released onto the cement unloading area. The release rate of the chemical is 100 gallons per minute. No mitigation measures were used. Other assumptions in the release scenario are: 1) Wind Speed = 3.0 m/s 2) Stability Class = D 3) Air Temperature = 77 degrees Fahrenheit The toxic endpoint was estimated to occur at a distance of 0.1 miles from the center of the facility. Estimated population in that radius is 520. The facility is eligible for Program 2 under the 112(r) regulation, because the worst case modeling indicates that there may be a potential for public exposure. Under Program 2, the RMP must contain the following: 7 Executive Summary 7 Registration 7 Worst-Case Analysis for both Toxic Releases and Flammable Releases 7 Alternative Release Scenarios for both Toxic Releases and Flammable Releases 7 5-Year Accident History 7 Prevention Program 7 Emergency Response Plan that has been coordinated with the Local Emergency Planning Commission (LEPC) 7 Certification The Exxon Olathe Grease Plant has had very few accidental releases of TDI and CHA in the past five years. No offsite consequences (personal or property injuries) have been reported due to these accidental releases. Copies of the spill reports/near miss analysis reports and OSHA 400 logs can be found in Section 4. The Exxon Olathe Grease Plant has an emergency response plan that has been incorporated into an integrated contingency plan (ICP). Training and drills are performed regularly with new and existing employees. |