C3 Polymers - Executive Summary

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Epsilon Products Company 
RMP Plan 
Executive Summary 
Accidental Release Prevention and Emergency Response Policies 
Epsilons' management has made the commitment to Safety a top priority. They are directly involved in the several Teams which oversee the Safety Programs. These Teams are composed of a broad cross section of the employees. 
Epsilon maintains a fully staffed Safety department. The Emergency Response Team has fully trained volunteer members on duty around the clock. 
Facility Description and Regulated Substances Handled 
Epsilon manufactures Polypropylene, one of the most useful of Plastics. It is inert, non-toxic, non-hazardous and burns poorly. 
Epsilon employs 140 people at the Marcus Hook site and is currently expanding. These people work in the Tri-State area with many residing in the Townships surrounding the facility. 
Propylene is the major hazardous material on site. It is the chemical, which places Epsilon in the RMP Program. Similar to Propane in characteristic 
s, it is flammable and potentially explosive if mixed with air. It is handled under pressure in both its gaseous and liquid forms.  
Other chemicals on site include: 
* Ethylene, which is a normally gaseous hydrocarbon. It is flammable and potentially explosive when mixed with air. 
* Propane, which is similar to Propylene in characteristics. 
* Hydrogen, which is handled in both its' gaseous form and as a cryogenic liquid. It is flammable and potentially explosive when mixed with air. 
* Nitrogen, which is handled as a gas and as a cryogenic liquid. It is potentially a sufficant and can cause severe frost burns in its' liquid form. 
* Catalyst components, which have low toxicity levels. 
* A Pyrophoric liquid which burns with contact with air and reacts with water. 
* Organic Peroxides which could react violently if exposed to heat. 
Worst Case Release Scenarios and Alternate Case Release Scenarios 
The Worst Case Release Scenario: 
The release of 130,000 pounds of Propylene followed by a  
Vapor Cloud Explosion. This release assumes the complete failure of the vessel containing the largest amount of flammables on site. The release would have an affect for approximately 0.40 miles. The estimate residential population in this area is 40. Surrounding industrial facilities would also be affected. 
The Alternate Case Release Scenario: 
The release of 20,000 from a failed pump seal followed by a Vapor Cloud Explosion.  
General Accident Release Prevention and Chemical Specific Prevention Steps 
* Gas Detectors. 
* Flame Detectors. 
* Computerized Process Control / Alarm/ Interlock Shutdown System. 
* Fully Staffed Safety Department. 
* Fully Trained Operations and Maintenance Departments. 
* OSHA Risk Management Plan includes: 
-Employee Participation               -Mechanical Integrity 
-Process Safety Information        -No Trade Secrets 
-Hazards Analysis                      -Compliance Audits 
-Operating Procedures               -Emergency Response and Planning 
-Personnel traini 
ng                       -Incident Investigations 
-Contractor Training                    -Hot Work Permits 
-Pre-Startup Safety Review        -Management Of Change Procedures 
* OSHA and EPA Inspections. 
* Insurance Provider Inspections and Standards. 
Five Year Accident History 
Epsilon Products Company had one reportable incident. The top was torn off of a storage silo by the ignition of flammable gases. No Injuries occurred and no Off-Site Consequences were involved. Silo damages were in the $300,000.00 range. 
A second incident occurred, which was not reportable under RMP guidelines. Flammable gases were releases from a pressure safety device. The gases were ignited. There were no injuries, no Off-Site Consequences and no significant damage (approximately $1,000.00). 
Emergency Response Programs In Place: 
* Automatic Emergency Feed Shutdowns. 
* Automatic and Manual Sprinkler Systems. 
* Centralized Alarm System. 
* Fully Trained Emergency Response Team. 
* Communications Systems: R 
adios, Emergency Phones, PA system, Emergency Call Procedures. 
* Emergency Evacuation Procedures and Drills. 
* Fire Water System: Hydrants, Monitors, Hose Stations, and Backup Firewater system. 
* Diking and Burn Pits for Pyrophoric Liquids. 
Community Response Plans In Place: 
* Emergency Reporting through the County LEPC (911). 
* Agency Reporting: 
PA-DEP, National Response Center, State Emergency Operations Center,  
Community Involvement in Place: 
- Environmental Advisory Committee Reporting 
- "SARA" Hazardous Material Reporting, County and Local, State 
- ERT Members on Local Fire Departments.  
- Mutual Aid Agreements. 
- Drills with local Emergency Response Teams and area Company Response Teams. 
Planned Changes to Improve Safety 
Epsilon maintains a Safety Suggestion program to continually improve Safety. 
Epsilon is preparing to enter OSHAs' Voluntary Protection Program which requires a voluntary commitment to the highest Safety standards.
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