Exxon Grease Plant - Executive Summary |
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Executive Summary This Risk Management Plan (RMP) has been created to fulfill the requirements of the Clean Air Act (CAA) 112(r). Under 112(r), there are categories of facilities: Program 1, Program 2, and Program 3. These categories of facilities are based on the potential for offsite public exposure from a worst-case accidental release, accident history, and the facility compliance status under the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standards. The major components of this RMP include a Hazard Assessment, a Management Program, a Prevention Plan, and an Emergency Response Program. The Hazard Assessment includes a Worst Case Analysis, several Alternative Release Scenarios, and a 5-year Accident History. The Prevention Program consists of safety information, hazard reviews, operating procedures, training, maintenance procedures, incident investigations, and compliance audits. The Emergency Response Program has been integrated into an Integrated Compliance Plan (ICP) for the entire facility. The Exxon Olathe Grease Plant is located at 1400 South Harrison in Johnson County. A site location map can be found in Section 1. The facility's current operation involves the manufacturing of lubricants and lubrications products. This includes the manufacturing and packaging of grease and specialty oils. The manufacturing process utilizes refined oils, combined additives to produce lubricants, and lubrication products including grease. Raw materials for the process are received via dray truck, tank truck, and tank car. Packaging materials are received by dray truck. Liquid raw materials are stored in tanks on the plant property both inside and outside. Packaged raw materials are stored on pallets in pallet racks until they are required in the manufacturing process. The lubricants and lubrication products are manufactured in a batch process in mixing and cooking kettles of various sizes. The cooking kettles are heated by eith er steam, or hot oil systems. Finished products are stored in the tanks within the warehouse, or in the manufacturing kettles until they are packaged. The finished products are manufactured in a variety of package styles and they are stored in the warehouse pallet racks until shipped to the various customers. Finished products are also loaded into bulk trucks and delivered to customers. The Exxon Olathe Grease plant currently operates in compliance with Air Permit #0910014. A representative of the Johnson County Environmental Department (JCED), acting as a designated agent for the Kansas Department of Health and Environment (KDHE), conducts annual inspections to verify compliance. Copies of the inspections, as well as the actual air permit, can be found in Section 1. The Olathe Grease Plant is also subject to EPCRA Tier II filing for toxic chemicals. Copies of the actual reporting forms for the chemicals (including TDI and CHA) can be found in Section 1 also. The two chemicals stored at the Exxon Grease Plant in quantities over the threshold values are Toluene-diisocyanate (TDI) and cyclohexylamine (CHA). TDI and CHA are brought in as raw materials and are essential in the production of various greases. These materials are received in bulk, nitrogen pressurized cylinders, and drums. Each is added at various times during the grease-making process at various temperatures and pressures. Copies of the Material Safety Data Sheets (MSDS) are in Section 5. Hazard Analysis Worst Case Scenario The worst case scenario for the Olathe Grease Plant has been determined to be an unloading accident which may have an offsite impact. Alternative Release Scenarios Cyclohexylamine An incident during unloading of CHA which may have an offsite impact Toluene - diisocyanate An equipment malfunction during unloading of TDI which may have an off site impact. The facility is eligible for Program 2 under the 112(r) regulation, because the worst case modeling indicates that there ma y be a potential for public exposure. Under Program 2, the RMP must contain the following: ? Executive Summary ? Registration ? Worst-Case Analysis for both Toxic Releases and Flammable Releases ? Alternative Release Scenarios for both Toxic Releases and Flammable Releases ? 5-Year Accident History ? Prevention Program ? Emergency Response Plan that has been coordinated with the Local Emergency Planning Commission (LEPC) ? Certification The Exxon Olathe Grease Plant has had very few accidental releases of TDI and CHA in the past five years. No offsite consequences (personal or property injuries) have been reported due to these accidental releases. The Exxon Olathe Grease Plant has an emergency response plan that has been incorporated into an integrated contingency plan (ICP). Training and drills are performed regularly with new and existing employees. |