Applied Extrusion Technologies, Inc. - Executive Summary |
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1.0 SOURCE & SUBSTANCE The Applied Extrusion Technologies, Inc. (AET) facility in Covington, Virginia produces polypropylene film and coats plastic films with a latex-type coating. The latex for the film coating process is also manufactured on site. Vinylidene chloride (VDC) is an essential component of the vinylidene chloride latex production process. Greater than 10,000 pounds of VDC is stored on-site and, therefore, AET is subject to regulations under 29 CFR 1910.119 and 40 CFR 68. Vinylidene chloride is regulated as a flammable liquid. VDC is a colorless liquid with a mild, sweet odor resembling that of chloroform. If not handled properly, VDC poses a significant fire and explosion risk, as well as acute and chronic health concerns. Acute overexposure to VDC vapor by inhalation can cause irritation of the respiratory tract, dizziness, nausea, headache, loss of coordination and equilibrium and -- if continued -- unconsciousness and death in confined or poorly ventilated ar eas. 2.0 RELEASE SCENARIOS In accordance with federal regulation, plant management has modeled four accidental release scenarios: one "worst-case" and three "alternative-case." The Worst-Case Analysis uses conservative assumptions to determine the greatest distance at which exposure to the heat resulting from ignition of the flammable liquid will cause second degree burns. The Alternative-Case Analysis demonstrates an off-site impact for a smaller release. Scenarios are described briefly below. A) Worst-Case Scenario for VDC -- BLEVE The worst-case scenario describes a situation in which the entire contents of the VDC vessel explode. Under stable atmospheric conditions with a one and one-half meter per second wind, heat from the explosion could cause second degree burns at a radius of 0.3 miles from the VDC vessel. An explosion of this magnitude would affect a residential population of 73 persons. B) First Alternative-Case Scenario for VDC -- BLEVE The first alternative case scenario describes a situation in which half of the contents of the VDC vessel (113,625 pounds) explode. Under slightly unstable atmospheric conditions with a 3 meter per second wind, heat from the explosion would cause second degree burns at a radius of 0.2 miles from the VDC vessel. An explosion of this magnitude would affect a residential population of 24 persons. C) Second Alternative-Case Scenario for VDC -- Pool Fire The second alternative case scenario describes a situation in which a release of 227,250 pounds occurs during the charging of the VDC vessel. If this release were to be ignited and create a pool fire, the distance to the heat radiation end point (5kw / square meter) would be 0.1 mile. This distance is within the boundaries of AET's property therefore there would not cause an off-site consequence. D) Third Alternative-Case Scenario for VDC -- Vapor Cloud Fire The third alternative case scenario describes a situation in which a release occurs as a result of a 20.5 square inch hole at the base of the VDC vessel, when the vessel is at its maximum capacity. The dike that is beneath the tank is considered passive mitigation. If the vapor emanating from the liquid released were to be ignited, the distance to lower flammability limit (7.3% or 290 mg/L) would be less than 0.1 miles. This distance is within the boundaries of AET's property therefore there would not cause an off-site consequence. Due to the safety procedures that are in place and the control systems that AET employs, AET believes that the probability for occurrence of these scenarios is remote. 3.0 ACCIDENT HISTORY & ACCIDENTAL RELEASE PREVENTION PROGRAM AET can certify that there have been no releases of VDC in the past five years that meet the off-site impact regulatory criteria for inclusion in the Risk Management Plan. The plant is proud of its accident-free history and has put into effect an extensive accidental release prevention program to maintain its excellen t safety record. 4.0 EMERGENCY RESPONSE PROGRAM AET has a formal emergency response plan in place at it's Covington, Virginia facility. This plan documents the procedures that will be followed by employees to adequately and safely respond to an accidental release of VDC and or a fire resulting from such a release. The emergency plan contains an updated list of company, emergency response, and media phone numbers. Proper first-aid and emergency medical treatment are documented in the plan. Procedures are in place for informing the public and emergency response agencies about any accidental releases. AET has developed eleven (11) specific chemical information sheets for chemicals present at the facility, including VDC. The chemical information sheet is a single summary page that includes: location, hazards, protective equipment, first-aid procedures, spill or leak procedures, fire procedures, and notification procedures. Should an emergency arise, each responding agency is given a copy of the appropriate chemical information sheet. |