GREEN TREE CHEMICAL TECHNOLOGIES, INC. - Executive Summary |
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Executive Summary - Green Tree Parlin RMP submittal Policy: At Green Tree, we manufacture chemical specialty products. We do so with full commitment to the chemical industry's Responsible Care? initiative. In keeping with this commitment, we are dedicated to providing a safe and healthful environment for our employees, customers, and communities. The following are basic principles we follow in managing our business: We will comply with the letter and spirit of all applicable safety, health, and environmental laws and regulations. We will develop strategic and tactical plans, provide necessary resources, and measure our progress on safety, health, and environmental matters on an ongoing basis. We will evaluate the safety, health, and environmental impacts of new and existing products and operations and will work to reduce the adverse impacts. We will maintain an open dialogue on safety, health, and environmental issues relating to our products and operations with our employees, customers, and communities. We will work to continually reduce workplace injuries; incidents with the potential for causing property damage, material loss, or interruption of our business; waste; and releases to the environment. We will emphasize the importance of safe and environmentally responsible handling of our products to our transporters, distributors, and customers. Facility Description: The primary activity at the Green Tree Parlin Plant is the manufacture of Nitrocellulose. Nitrocellulose is used as a film former in lacquers and inks used in the home and industry. It is also the major ingredient for smokeless propellant for both sporting and military applications. The primary ingredients in Nitrocellulose are cellulose and nitric acid. Strong nitric acid (98 %) is produced at the plant by concentrating purchased 65 % acid. The strong acid is stored in two tanks, each limited to 67,500 gallons by administrative controls and one tank administratively controlled to 45, 000 gallons. The acid storage and handling area is provided with containment dikes and sewer diversions in which spills can be managed. An 80,000-gallon emergency storage tank, pumps, and associated piping are also installed so that a spill can be quickly cleaned up in order to minimize any adverse impacts. Worst Case Scenario: The worst case scenario for the plant is the failure of an entire storage tank, containing 67,500 gallons of strong nitric acid. This scenario will have an offsite impact, based on the use of the SLAB model . The release rate to the atmosphere is based on a calculated evaporation from the liquid pool that will form in the dike surrounding the storage tank. This scenario requires the extremely unlikely event of a catastrophic failure of the storage tank. Administrative controls in standard operating procedure and high level alarms limit the quantity released in this scenario. Alternative Case Scenario: The alternative case scenario for strong nitric acid is a pipe leak in the transfer system that results in the evaporation of 330 pounds into the atmosphere. This scenario will have an offsite impact, based on the use of the EPA OCAG guidance. The impact from this scenario is limited by dilution of the spill with water and neutralization with soda ash. Accident Prevention Program: The use of strong nitric acid in the plant's processes has been subject the New Jersey Toxic Catastrophe Prevention Act (TCPA) regulations since their adoption in 1988, as well as the subsequently adopted OSHA Process Safety Management standard (29CFR 1910.119). The plant has an established risk management system in place to meet these requirements and to minimize the potential for accidental release of these substances. Our management system includes: 1. Process hazard analysis to identify and address potential hazards. 2. Management of change procedures to assure that standards are maintained and potential new hazards assessed. 3. Mechanical integrity procedu res for minimizing mechanical failures, Detailed operating procedures for process control 4. Training for the personnel involved in operating and maintaining the processes. 5. Facility design incorporates multiple layers of incident prevention. Five Year Accident History: In the past five years, the Parlin plant has not had any accidental releases of strong nitric acid that resulted in on-site injuries or damage or any off site impacts. Emergency Response Program: The Green Tree Parlin plant has a written emergency response plan and coordinates emergency response matters with the Sayreville Office of Emergency Management (L.E.P.C.). The plant provides emergency response training for all plant employees and has trained emergency response teams on site. Emergency response exercises are conducted several times each year. |