LinPac Plastics, Inc. - Executive Summary |
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RMP*Submit V1.1.5 Executive Summary Submittal LinPac Plastics, Inc. Wilson, North Carolina This Executive Summary is comprised of the seven parts (a thru g) of Rule 40 CFR 68.155 of the Clean Air Act as it applies to LinPac Plastics, Inc. (LinPac) in Wilson, North Carolina. The purpose of the Risk Management Program (RMP) regulation is to prevent accidental releases of an identified flammable or toxic substance from a covered process, and to minimize the consequences of such a release of an affected substance. Owners/operators have a general duty under the regulation to identify hazards, design and maintain a safe facility, and minimize the consequences of releases of affected substances 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. The following paragraphs summarize an evaluation of LinPacs' general compliance wi th the stated Rule. 40 CFR Part 68.155(a): Accidental Release Prevention and Emergency Response Policies: The LinPac Process Safety Management (PSM) Policy requires daily inspections by maintenance mechanics and the Plant Engineer. Butane gas detectors are located in the Butane Storage Tank Area and at each high-pressure pump area near the back end of each extruder. These detectors are connected to a butane detection warning panel with lights and a warning horn. Butane pumps and motors are regularly rotated with their backups to verify proper working order and to allow for scheduled maintenance. The general Emergency Response Plan (ERP) sequence 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. In addition as can be accomplished, equipment operators will turn their equipment off as they evacuate. Maintenance supervisors and lead oper ators will provide first aid until paramedics arrive. A review of the Process Safety Management and Accidental Release Plan (PSM/ARP) elements as they relate to the RMP was conducted. This review indicated good overall compliance and excellent results, with no accidents related to the Butane System. 40 CFR Part 68.155(b): Stationary Source and Regulated Substances Handled: The LinPac Wilson, North Carolina (LinPac) is a manufacturer of extruded, expanded polystyrene foam, plastic food handling products and building products. The food handling products include various plastic containers and trays such as meat trays and "carry out" food containers. The building products are building insulation and insulation cavity integrity forms. For the purposes of this regulation the covered process is defined as the butane storage and delivery system to the extruders, including the extruder die. Butane is used as a physical blowing agent in the manufacturing process and is stored on-site in an 18,000-gallon tank under pressure. Butane is the only "regulated substance" handled by LinPac. 40 CFR Part 68.155(c): Worst Case Release Scenario(s) and the Alternative Release Scenario(s): RMP requires that off-site consequences be considered in a hazard assessment process. An off-site consequence analysis was required to evaluate specific potential release scenarios, with a worst-case scenario and an alternative case scenario for the lookup tables found in the EPA guidance. No environmental receptors were identified for either scenario. The worst case release scenario indicated a vapor cloud explosion would have an effect to a distance of 0.34 miles (1,795 feet). A receptor survey indicates that besides the LinPac facility, seven (7) active businesses, and ten (10) private residences could potentially be affected in this scenario. The Alternative Release Scenario indicated that a vapor cloud fire would have an effect to 0.073 miles (385 feet). The vapor cloud fire scenario c ould affect one (1) active business and one (1) private residence not including the Wilson facility itself. 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: ? Administrative Controls and Mitigation Measures include the following: ? Butane gas detection sensors, with monitoring system and associated alarm. ? Restricted/authorized access to the storage tank and butane delivery pumps as well as limited access to the butane unloading station. ? Back up pumps and motors. ? Explosion-proof equipment. ? Gravel absorbent placed around the storage tank and the unloading station to dissipate a spill. ? Training for maintenance and other personnel that have safety functions related to butane use. ? Periodic safety review activities during Safety Meetings. ? Chemical-Specific LinPac policy associated with accidental butane re lease prevention. ? 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 release. ? The program utilizes 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" in general accord with the OSHA PSM Rule. A review of the required RMP elements indicated that existing procedures met the requirements, but one area needed to be updated wit h the regulations. Process Hazard Analysis (PHA) documentation was needed and a PHA was held using a structured "What If" technique. Identified areas of concern are currently being addressed under a proposed schedule that was generated by the PHA process. Safety reviews take place periodically. 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 for the butane storage tank is planned for the near future as part of the mechanical integrity policy. Follow up tank inspections will be performed in accordance with the mechanical integrity procedures. 40 CFR Part 68.155(e): Five-year Accident History: LinPac safety records at the Wilson facility indicate that there have been no accidents resulting in personal injury and related to the butane system during the last five (5) years. 40 CFR Part 68.155(f): Emergency Response Program: The LinPac facility has chosen to use the 911 emergency phone system as the Emergency Response Program (ERP). A fully staffed Wilson City Fire Department substation is less than ? mile away and has been notified of the existence of the butane tank, in compliance with the State Emergency Response Program. Placarding for the tank and the plant are in place. The Wilson City Fire Department has other substations that can be called upon to in the event that further assistance is needed. LinPac's ERP identifies only the actions to take until the Fire/Rescue Personnel arrive. 40 CFR Part 68.155(g): Planned Changes to Improve Safety: To improve safety at the facility, the following procedures will be implemented: ? The contractor safety policy document will be amended to include a section to address handling heavy loads around the butane storage tank area. ? A section will be added to the extruder process operating manual and the operator-training manual addressing the "string-up" step of the start-up procedures and false alarms of the butane release warning system. ? 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. |