3V Inc. - Executive Summary
Executive Summary for the RMP |
Accidental Release Prevention and Emergency Response Policy:
3V Inc. is committed to providing every employee with a working environment that is free of conditions likely to cause injuries or illnesses or releases of hazardous materials. We will maintain a safety and health program that conforms to the best practices of organizations similar to ours. The objective of our safety and health program is to surpass the best experience of operations similar to ours. Our goal is for every employee to embrace the "zero-injury" philosophy; that is, every accident that causes an injury or illness is preventable, and no accidents are acceptable to us.
Our preventative measures start prior to the introduction of any new chemical entering the facility. Changes are reviewed at several levels including safety and environmental impacts. Emphasis is placed on characterizing all incoming materials to determine the protective measures necessary to safely store and ha
ndle the material. No chemical substance enters or leaves our facility without written information that provides the hazardous properties and safe handling precautions for the substance. Our storage and processing equipment is designed to safely contain and handle the materials used. Design data and process evaluations are reviewed at multiple levels to ensure their completeness. Our ongoing programs to inspect, maintain, and improve our processes are a testament to 3V's commitment to keep our employees, the surrounding community, and the environment safe.
Facility and regulated substances handled:
The 3V, Inc. facility is located adjacent to the Sampit River, approximately 4.0 miles west of Highway 17 South on Pennyroyal Road in Georgetown County, South Carolina. The core business is dedicated to the batch production of organic specialty chemicals. Customers range from the cosmetics industry to paper and pulp manufacturers.
Our manufacturing scheme is relatively similar for all
products. Measured quantities of raw materials are pumped from storage tanks to a reaction vessel via a closed piping system. Various additives and solid materials are sometimes loaded into the reactors via portals or dump chutes. The mixture is then reacted by manipulation of temperatures and pressures in the reaction vessel. The resulting mixture is then transferred to downstream equipment where mechanical operations such as filtering, drying, and packaging are performed. Any unreacted material is then recovered for reuse or treated and removed. In general, the storage, transfer, and reaction steps are the most critical in terms of safety. The majority of our final products are non-hazardous.
Two of 3V's stored raw materials that receive particular emphasis on safe handling are acetaldehyde and vinyl acetate. Both materials are stored and processed in closed systems with protective alarms and features. Through careful planning and controls, acetaldehyde has been handled saf
ely for over 3 years. The vinyl acetate system has been safely handled for over 19 years.
Worst case and alternate release scenarios:
The worst case release scenario's for vinyl acetate were considered from the storage tank which contains the largest on site inventory of the substance and from the process vessel which contains a much smaller inventory but at elevated temperature. The storage tank is located outside in a concrete containment structure and the process vessel is located inside a process building. EPA's model, RMPComp, was used to evaluate the distances to the toxic end points. A release of the charge to the process vessel resulted in the larger distance to endpoint of the two worst cases evaluated and therefore that scenario was reported. In either case, even though the endpoints are located beyond the facility boundary, there are no offsite receptors (houses, churches, schools, etc.) located within that distance. In fact the closest house is more than twice the dis
tance from the facility as the worst case end point.
An alternate release scenario was considered as a release from the storage tank through a 4-inch opening while the tank is half full. Again, RMPComp was used to evaluate the distance to the end point which resulted in an area without any offsite receptors.
The worst case release scenario for acetaldehyde was the loss of the maximum inventory in an external storage tank accompanied by a vapor cloud explosion. Again, the end points of such an event extend beyond the facility boundary but do not reach any receptors. The closest house is more than five times the distance from the facility as the worst case end point. The alternate release scenario for this material is a release from the same vessel, but assumes that the tank is half full and the failure of the tank is through a 3-inch opening. In this case the distance to an end point is within the facility boundary.
Accidental Release Prevention Program and Chemical-specific Preve
All waste management, raw materials and finished products operations are performed with the necessary precautions to prevent accidental ignition or reaction of flammable or reactive materials. Smoking is prohibited throughout the facility except in limited designated areas. Hot work must be conducted by permit only and not in the presence of combustible materials. Process equipment and storage tanks containing flammable liquids are grounded and inerted with nitrogen and equipped with flame arrestors. Oxidizers and organic peroxides are segregated from combustible and flammable liquids. Signs are posted at the entrance to the facility prohibiting smoking, matches or open flames. Facility personnel inspect process vessels, pumps and piping systems routinely for leaks. Temperatures, pressures and levels are monitored at appropriate intervals on tanks and process equipment. Containment structures exist around tanks and process units containing hazardous materials to cont
ain spills should they occur. These structures are inspected routinely and deficiencies are addressed as they are discovered. Storage tanks containing flammable or toxic liquids are provided with nitrogen blankets to remove oxygen, vent controls to avoid over or under pressurization, and safety devices to protect the tank from failure. Structural integrity of vessels, piping systems and tanks is determined by the presence or absence of visible leaks during visual inspections each shift as well as from scheduled non destructive thickness testing at recommended intervals.
Both acetaldehyde and vinyl acetate systems and all associated manufacturing processes are covered under the OSHA Process Safety Management rule. As 'covered' chemicals, their use is evaluated for safety from loading and storage to final processing. Hazard studies have been performed for all equipment, procedures, and monitoring systems related to the handling of these chemicals. 3V's Process Safety Management pro
gram is fully implemented to prevent releases of these substances by incorporating the following features: 1) hazard identification, 2) protective measures, 3) procedures written to emphasize correct handling and operation, 4) control systems, 5) periodic equipment inspection and maintenance, and 6) training of all personnel associated with hazardous processes.
The storage systems for acetaldehyde and vinyl acetate are designed to meet NFPA requirements for flammable liquids. These guidelines assure that the tanks will not over-pressurize under emergency conditions. Some of the specific methods that we use for accident prevention include the following:
* Inerting - oxygen is purged from tanks, pipes, and process equipment with nitrogen to eliminate the potential for a flammable atmosphere. Under inert conditions, flammable vapors cannot ignite.
* Grounding - storage and process systems are grounded and tested to prevent static discharges, which are a potential ignition source.
Venting - storage tanks and process vessels have emergency venting systems to prevent vessel ruptures, explosions, and structural damage in an over-pressure situation.
* Alarms - storage tanks and process vessels have various alarms to warn personnel when an operating parameter (i.e. level, temperature, pressure) has deviated out of its safe range.
* Temperature Control - Acetaldehyde is stored at reduced temperature to reduce its vapor pressure, thereby reducing the likelihood of a significant vapor release from the storage and transfer systems.
The five-year accident history:
In the past five years, there have been no reportable accidents associated with our regulated chemicals or their associated processes. This is a testament to our ability to safely handle these materials without risk to offsite populations.
The Emergency Response Program
3V Inc. (3V) has a complete Emergency Response Plan (Plan). The purpose of the Plan is to minimize hazards to human health or the environmen
t from fires, explosions, or any unplanned release of hazardous materials to the air, soil, or surface water. The plan is organized into two sections consisting of general information about the 3V facility, preparedness and prevention, training requirements, how the emergency organization is established, coordinating with outside agencies and implementation of the plan in an emergency situation. The second section is the working document containing specific information needed in an emergency such as telephone numbers of emergency response personnel and off-site responders, notification and emergency procedures, and lists and locations of safety and emergency equipment.
3V's Emergency Response Plan is provided to and reviewed with local emergency response agencies and it is included in the Georgetown County Emergency Response Plan. In addition, 3V has provided to the LEPC and the local fire department information on the facility's hazardous chemical inventory. In March 1998, 3V of
ficials met with the members of local emergency response agencies to coordinate emergency response efforts.
All employees are trained to recognize the general facility evacuation alarm tones, to understand evacuation procedures and emergency response procedures specific to their work area. In addition, employees who may become involved with a hazardous material release are trained on how to recognize hazardous materials and/or hazardous situations for purposes of taking defensive measures (alarm, containment, control, and evacuation).
Drill exercises are planned and scheduled for training of emergency response personnel as necessary to keep these personnel current in their training and proficient in procedures and equipment use.
Georgetown County is a member of an independent, local, community alert network and 3V Inc. is a participant in that effort. In the unlikely event a hazardous material release were to occur, potentially affected citizens would be notified by means of
telephone communications and instructed on what steps to take to protect themselves.