Linpac Plastics, Inc. - Executive Summary |
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The purpose of this Risk Management Plan (RMP) is to prevent accidental releases and to minimize the consequences of any such release of a 112(r) substance or any other extremely hazardous substance (EHS). Owners/operators have a general duty to identify hazards, to design and maintain a safe facility, and to minimize the consequences of releases which do occur. If at any time a covered process no longer meets the eligibility criteria of its program level, the owner/operator shall comply with the applicable new program requirements and update the RMP accordingly. This Executive Summary comprises the Rule 40 CFR 68.155 of the Clean Air Act as it applies to Linpac Plastics. The Tasks, 1-4 indicate Environmental Engineering Consultants, Inc. evaluation of Linpac Plastics' compliance with the stated Rule. 40 CFR Part 68.155(a): Accidental release prevention and emergency response policies; Linpac's Process Safety Management (PSM) Policy requires daily inspections by maintenance me chanics and the Plant Engineer. Butane gas detectors are located in the Butane Storage Tank Area and in the Butane Pump Room. These detectors are connected to a butane detection warning panel with lights and a warning horn, it is also integrated into the fire alarm system. Butane pumps and motors are regularly rotated with their backups to verify proper working order and to allow for scheduled maintenance. The Accidental Release Prevention Plan (ARP) is to call 911 for emergency response, sound the evacuation alarm and evacuate the building. If possible, the butane emergency shut-off will be activated and the power turned off to the butane motors. Operators will turn their equipment off as they evacuate. Maintenance supervisors and lead operators will provide first aid until paramedics arrive. TASK 1 was to perform a Process Safety Management and Accidental Release Plan (PSM/ARM) Compliance Audit. This compliance audit indicated good overall compliance and excellent results, w ith no accidents related to the Butane System. 40 CFR Part 68.155(b): Stationary source and regulated substances handled; Linpac Plastics, Inc. is a manufacturer of polystyrene plastic. Linpac sells the polystyrene to clients and also uses it to manufacture various plastic containers, such as egg cartons and "carry out" food containers. Butane is used as a blowing agent in the manufacturing process. Butane is stored on site in an 18,000-gallon tank under pressure. Butane is the only "regulated substance" handled by Linpac Plastics. 40 CFR Part 68.155(c): Worst case release scenario(s) and the alternative release scenario(s); TASK 2 was to perform a review of the hazard assessment elements. An off-site consequence analysis was required to evaluate specific potential release scenarios, with a worst-case scenario and an alternative case for computer modeling. The worst case release scenario indicated a vapor cloud explosion would have an effect to a distance of 0.3 miles (1584 fee t). Our research indicates that three (3) vacant buildings, five (5) active businesses, two (2) Sebring Airport Authority maintenance buildings and the Security Trailer and the water plant could potentially be affected in this scenario (Figure 1, Map of 0.3-Miles radius.). EXECUTIVE SUMMARY continued: * The Alternative Release Scenario indicated that a vapor cloud fire would have an effect to 0.1 miles (500 feet). The vapor cloud fire scenario could affect one (1) active business, three (3) vacant buildings and the Sebring Airport Authority water plant (Figure 2, Map of 500 feet radius). The residential population and the environmental receptors are not affected by either scenario. Linpac's Administrative Controls and Mitigation Measures include the following: * The butane gas detection sensors, with monitoring system and associated alarm. * A locked gate and the chain link fence enclosing the tank and the unloading station. * Back up pumps and motors. * Explosion-proof equipme nt. * Gravel has been placed around the tank and the unloading station to dissipate a spill. * Only trained mechanics are allowed to perform maintenance on the butane system. * Safety procedures are reviewed during Safety Meetings. 40 CFR Part 68.155(d): General accidental release prevention program and chemical-specific prevention steps; The general Accidental Release Prevention Program and Chemical-Specific Prevention Steps are as follows: * Only trained maintenance mechanics are allowed to perform maintenance on the butane system. * A supervisor and the Plant Engineer review all work before it is performed to ensure compliance with safety rules and to prevent an accidental release. * In general, all maintenance work related to the butane system is performed using a two-person team to ensure safety compliance and to prevent an accidental release. * A butane trained employee is always present during the unloading process to ensure safety compliance and to prevent an accidental releas e. * The program complies with safety precautions, monitoring, record keeping, reporting, operator training, vapor recovery, secondary containment, work practices, standard operating procedures modifications as needed, the generation of a "Hot Work Permit", and the OSHA PSM Rule. TASK 3 was to develop a Detailed Accidental Release Prevention Program. Our review indicated that existing procedures met the requirements, but one area needed to be addressed to be in full compliance with the regulations. Safety compliance audits take place monthly. An incident investigation procedure is currently in place. An Employee Participation Plan in the form of a Central Safety Committee is currently in effect. A design review of compliance with the National Fire Protection Association Codes relevant to the butane system is on going and will be updated whenever changes are made to the butane system. An API 510 inspection by Applied Technical Services, Inc., (770-423-1400) certified the tank i s suitable for operation at pressures up to 240 psi at 125?F. A follow up tank inspection was recommended to be conducted by 2004. 40 CFR Part 68.155(e) Five-year accident history; Linpac safety records indicate that there have been no accidents related to the butane system during the last five (5) years. EXECUTIVE SUMMARY continued: 40 CFR Part 68.155(f) Emergency response program; TASK 4 was to develop an Emergency Response Program. We have chosen to use the 911 emergency phone system as our Emergency Response Program (ERP). The De Soto City Volunteer Fire Department is less than four (4) miles away and has been notified of the existence of the butane tank, in compliance with the State Emergency Response Program. The fire department has agreements with fire departments in two surrounding cities (Lorita and the City of Sebring) to provide assistance when needed. Linpac's ERP identifies only the actions to take until the Fire/Rescue Personnel arrive. 40 CFR Part 68.155(g) P lanned changes to improve safety; To improve safety at the facility, the following procedures will be implemented: * An Employee Participation Plan will be incorporated into the existing Safety Central Committee. * Prior to changes in the butane system Linpac will perform a Design Review of Compliance with the National Fire Protection Association Codes relevant to the butane system. |