CESSCO,INC. - Executive Summary |
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Cessco is a small aerosol filling company located on rural Johns Island, S.C. Currently Cessco employees nine (9) people including management and owners. When Cessco relocated its plant facilities in 1991, it sought an isolated location. In determining the propellant tank location sites, the tanks were placed at the furthest possible distance from homes or offices. Being a small, close knit company, management makes every effort to provide a safe working environment. Monthly safety meetings are held and management and plant personnel interact equally. Every employee has received and been certified in Hazardous Materials HM0181F/126F Training. Last training and certification was completed on July 13, 1999, on site by HAZCOM of Salem, Virginia. Cessco also receives regular courtesy visits from the St. Johns Fire Department as the fire department periodically uses Cessco's plant and grounds for the training of their new firemen. Cessco manufactures insecticide aerosols, insecticide liquids, and liquid cleaning products. Cessco formulates and fills its own EPA registered products and also contract fills for other companies. All products are formulated from EPA approved Confidential Statements of Formula. The concentrated active ingredients used in various formulas are pyrethrum, piperonyl butoxide, d-trans allethrin, permethrin, tetamethrin, chloropyrifos, and DDVP (vapona). These active ingredients are blended with solvents, those being Isopar M, LPA 210, BVA KX45, Exxate 1300, Odorless Mineral Spirits, Hi-Sol 10, and Sponto AK 3138. Propellants used to fill the aerosols are HFC-134A (non-flammable) and Hydrocarbon A-70 (flammable). All of the chemicals except for 134A and A-70 are brought into the plant in 5, 30, or 55 gallon containers. 134-A and A-70 are received in bulk and put into storage tanks located on the northeast side of the plant property. The worst case scenario would be if the propane tank was filled to 19,000 pounds an d the relief valve atop the propane tank to failed. If this should occur there would be no way to keep the tank from emptying its contents. Using Table 3 of the Risk Management Program Guide Book, NOMINAL TANK CAPACITY VERSUS DISTANCE TO ENDPOINT, the furthest point affected by the vapor cloud would be .2 of a mile. As part of our Emergency Response Plan, the St. Johns Fire Department would be contacted immediately and their response time would be approximately five (5) minutes. Upon arrival they would cover the vapor cloud with a water mist that would help keep the cloud visible and allow them to track the cloud. The above scenario is unlikely to happen because the pressure relief valve is rated at 250 PSI (tested even higher) and the actual tank pressure rarely reaches 80 PSI. As for failure of the relief valve, the NFPA 58, Appendix E 23.1 (d) states pressure relief valves have excellent safety records so mechanical failure would be unlikely. The pressure relief va lve was installed and tested in 1995 before the tank was put into service. The alternative scenario that could occur would be for the propane tank man-way gasket to fail. If this should happen and the propane tank contained 19,000 pounds there would be no way to contain the propane and keep it from escaping. A vapor cloud would be produced and would travel .2 of a mile to its endpoint. As part of our Emergency Response Plan, the St. Johns Fire Department would be contacted immediately and their response time would be approximately five (5) minutes. Upon arrival they would cover the vapor cloud with a water mist that would help keep the cloud visible and allow them to track the cloud. This scenario is unlikely to happen because in 1995 before the tank was put into service, a new stainless steel man-way gasket was installed and thoroughly pressure tested. Cessco currently complies with the rules and regulations set forth by the EPA, DOT, OSHA, DEHEC, and local agencies. The Accidental Release prevention Program focuses on repeatedly training employees, (e.q. daily hands on training.) Before any start up of equipment, it is required that all pumps, compressors, pressure gauges and pressure relief valves be inspected. Back-up and prevention systems are as follows: 1) Emergency shut-off systems for electrical, piping, and pumps. 2) Backflow prevention valves. 3) Excess flow valves. 4) Pressure relief valves. 5) Breakaway piping. 6) 20 PSI blow out panels. 7) Sprinkler systems. Cessco has had no accidental releases in the past five years. Cessco's Emergency Response Plan is coordinated directly with the St. Johns Fire Department and HAZMAT Response Team. The nearest fire department is 2.5 miles away and response time is five (5) minutes or less. Cessco will continue hands on training of its personnel and monthly safety meetings. There are no changes planned for the emergency shut down and prevention systems that are in now in place. Our b iggest challenge is keeping up to date on the many rule changes that take place with the various government agencies. Plans are in process to contract with a consultant in Occupational and Environmental Health and Safety to assure that the company stays up-to-date and in compliance with the rules and regulations of EPA, DOT, OSHA, DEHEC, and local agencies. |