Sentinel Polyolefins LLC - Executive Summary

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Sentinel Polyolefins, LLC ("Sentinel") is a manufacturer of cross-linked polymer products for use in manufacturing and packaging.  Sentinel operates a blown foam manufacturing facility located on Langdon Avenue in Richfield Springs, NY. Butane is used at the facility as a blowing or foaming agent for foam produced through extrusion. The facility has two 6,500 gallon butane tanks and the associated low and high-pressure transfer and feed systems. Butane is subject to EPA regulation under 40 CFR 68, Accidental Release Risk Management of Highly Hazardous Chemicals. 
 
Pursuant to the RMP regulations (40 CFR 68) and the Process Safety Management (PSM) regulations, Sentinel has developed a PSM written program to protect our employees and the surrounding community from exposure to the hazardous chemicals onsite.  The facility completed a process hazards analysis (PHA) for butane using a Hazard and Operability (HazOp) Analysis. The PHA was completed using technical and operations staff from the 
Sentinel facility as well as experienced facilitators from an outside engineering firm. 
 
Sentinel's implementation of the PSM program includes employee education in the hazards of butane and measures that can be used to reduce employee and community exposure to accidental releases of butane. The plans include preventive maintenance programs (mechanical integrity) for the butane system, and a program for both pre-startup safety reviews and management of changes (MOC) to this system. The program also includes specific requirements for safe work practices (such as safe approaches to welding and similar hot work) and safety requirements for contractors who may be hired to work on the system. 
 
Lastly, the PSM written program incorporates the Sentinel emergency response plan and places special emphasis on handling accidental releases of hazardous chemicals and coordination of emergency response with local fire departments and other emergency response organizations. 
 
The Sentinel facility ha 
s never experienced a release of butane involving consequences that affected residents or the environment. However, as part of the RMP requirements, Sentinel undertook a review of the potential offsite consequences of the accidental releases of the largest vessels in the system.  Although such a release is highly unlikely, the regulation requires this review.  
 
The worst case scenario was assumed to be the release of the entire contents of the entire 27,864- pound capacity of a single butane tank. The analysis of this release indicates that a potential exposure of an area approximately 0.5 miles in diameter (distance to endpoint of 0.25 miles) would result. The total population within the potential exposure area is 50.  Within this area there are residences and commercial/industrial areas. 
 
In determining the alternate case scenario for butane, Sentinel analyzed incidents occurring at other blown foam manufacturing facilities and the results of the internal process hazards analysis (PH 
A).  Flammable gas systems such as the one used at Sentinel are inherently safe and are highly unlikely to suffer failures substantial enough to affect off-site receptors.  The scenario chosen for the butane system is a pool fire of butane resulting from shearing the feed pipe to the low pressure delivery system.   Such a release would affect an area of 0.22 miles (0.11 miles to the toxic endpoint) and create the potential to affect approximately 10 persons. Only residences are located within this area. 
 
Sentinel is committed to minimizing accidental releases of butane from the process at the Richfield Springs facility.  Facility management is involved in the design, operation, and maintenance of the system.  Sentinel employees at all levels have been involved in the development of the PSM and RMP programs.  Management has committed to working with local agencies regarding the hazards of butane and to ensure a safe workplace and surrounding community.
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