Chem-Tech LTD. - Production Plant - Executive Summary |
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40-CFR-68.155 Executive Summary 40-CFR-68.155(a) Chem-Tech LTD. of the Pleasantville production facility accidental release prevention policy involves a hands on approach. No process is left unattended while in operation. Constant monitoring by production staff is normal operating procedure. Rules of the U.S. Environmental Protection Agency Prevention Program are implemented and practiced at Chem-Tech LTD. An emergency response program has been prepared for the Pleasantville location and coordination with local law enforcement, fire dept. and LEPC are ongoing. The program is in compliance with the EPA Emergency Response Program requirements. 40-CFR-68.155(b) Chem-Tech LTD's only production facility is located in Pleasantville, IA. The facility main production involves specialty packaging of aerosol and liquid products. The facility is located on he North side of Pleasantville on highway 5. The aerosol packaging line includes bulk propellant storage, transfer equipment, an explosion proof gas charging room for pressurizing aerosol cans and quality control equipment for line and equipment monitoring. The amount of 152a handled on site is no more than 80% of the bulk storage tanks or 4800 gallons. The equipment when in operation is under constant staff supervision. 40-CFR-68.155(c) The Worst Case scenario at Chem-Tech LTD. would be a catastrophic failure of the bulk storage 152a tank. The failure would release 36000 pounds of 152a within 10 minutes. Using the RMP-Comp program from the EPA a worst case scenario distance to end point for such a release is 0.2 miles. Measures to limit the distance are not advised. The containment of a flammable, compressed gas due to a catastrophic failure presents a whole new set of hazards. These hazards would place response team members at great risk. The compressed gas expands and dissipates at such a high rate of speed, an incident would be over before any attempt at containment could begin. The gas should be allowed to dissipate. Since containment is not a practical procedure, limiting the severity of the incident would include eliminating any ignition source with-in the affected area. This would include auto traffic, motors, electrical devises, lawn mowers, or any sources of heat. The flammability limits of 152a are 3.9% to 16.9% therefore with a distance to end point of 0.2 miles all ignition sources within that distance should be eliminated. (Note: Do Not Introduce an Ignition Source to Eliminate One. Don't drive in.) All alternative release scenarios involve reduction of the 152a release rate. Examples would include releases from cracked pipes, valves, pumps, unions, i.e. Every attempt to isolate a release source should be made using existing valves and shut offs. In all cases the same attention to eliminating ignition sources should be taken. 40-CFR-68.155(d) The Chem-Tech LTD. accidental release prevention program includes; 1) Hands On operation - Equipment operates under employee supervi sion 2) Only trained employees operate production lines 3) Visual and Audio inspections twice a day while in production 4) Written operating procedures, written with the participation of the operators 5) Process falls under the Process Safety Management of HHC 29 CFR 1910.119 and is operated accordingly The chemical-specific prevention steps include employee training and awareness programs. 40-CFR-68.155(e) No accidental releases of 152a have occurred at this facility in the past five years. 40-CFR-68.155(f) The facility has a written emergency response program. The program is on file with the Marion County LEPC in Knoxville, IA. The program includes all components outlined in 29 CFR 1910.119. Reviews will be held every three years including emergency operation and response procedures. 40-CFR-68.155(g) One change was identified in the June 1999 Process Hazard Analysis for the aerosol line. It was determined that the bulk storage tank for 152a will be moved 10 feet further from th e building. The completion date for the project is 1/1/2000. |