PACTIV Corporation - Beech Island, SC Facility - Executive Summary |
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1. Accidental Release Prevention and Emergency Response Policies. We at Pactiv Corporation are strongly committed to employee, public and environmental safety. This commitment is inherent in a comprehensive accidental release prevention program that covers areas such as design, installation, operation, and maintenance of the processes at our facility. It is our poicy to implement appropriate controls to prevent possible releases of regulated substances and to train employees regarding the safe operation of processes involving regulated substances. Although such an event is unlikely, employees are trained to react to unplanned releases of regulated substances. In addition the plant has coordinated with the local and other emergency response organizations which provide highly trained emergency response personnel to help control and lessen the effects of any unplanned release. 2. The Stationary Source and the Regulated Substances The primary manufacturing activity at this plant invol ves the production of plastic consumer products such as polystyrene foam plates, bowls, and food containers. We have one substance present at our facility which is regulated by the United States Environmental Protection Agency (USEPA) under the Risk Management Program. This substance is CBI-Flammable substance; and is referenced in this document by the term "regulated substance". The products are also often called "blowing agents" or "expansion agents". The maximum inventory of CBI-Flammable substance possible at our facility is approximately 100,000 pounds. Written operating procedures and high-level alarms prevent more than this amount from being present in this tank. 3. Worst Case Scenario(s) and Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. Under RMP, USEPA requires facilities to determine the effects of catastrophic releases of regulated substances. In the facilities which use f lammable regulated pressure as a result of an instaneous release of the largest tank volume utilizing no active measures to control the release of the regulated substance under the worst-case weather conditions. USEPA defines alternative release scenarios as 1psi over-pressure as a result of a timed release of a portion of the largest tank volume utilizing active measures to control the release of the regulated substance under the neutral weather conditions. To evaluate the worst case scenario for the particular regulated substances and conditions at this facility, we used equations from Appendix D of the USEPA RMP Offsite Consequence Analysis Guidance and RMP Compute, a simplified EPA model based on the EPA's Offsite Consequence Analysis Guidance. For analysis of alternative release scenarios, we also employed the equations provided by the USEPA in the RMP Offsite Consequence Analysis Guidance and RMP Compute. The following paragraphs provide details of the chosen scenarios. The activities at the plant can be categorized by Program 3 of the RMP guidance. The projected worst case release scenario would involve a catastrophic release from the CBI-Flammable substance storage. The scenario involves the release of 100,000 pounds of CBI-Flammable substance. Passive mitigation systems such as dikes were not considered when evaluating this scenario. The worst case release scenario assumes that the entire quanity of the CBI-Flammable substance storage tank is released as a vapor, an ignition source is present and 10 percent of the released quanity participates in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.40 miles corresponds to an endpoint of 1 psi overpressure. The alternative release scenario involves a release from the CBI-Flammable substance storage tank assumed to result in a vapor cloud explosion. The scenario involves the release of 330 pounds of CBI-Flammable substance. The release is controlled by active mi tigation measures that include a deluge system, an automatic shut off valve. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressuer is 0.03 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under the EPA's 40 CFR Part 68. This facility was designed and constructed in accordance with the NFPA-58 Standard, 1967 Edition. A number of processes at our facility are subject to the OSHA PSM standard under the 29 CFR 1910.119. We also have an air operating permit under the Title V of the Clean Air Act. The following sections briefly describe the elements of the release prevention program that are in place at our stationary source. Process Safety Information Pactiv Corporation maintains a detailed record of safety information that describes the chemical hazards, operating g uidelines and equipment designs associated with the processes. Process Hazard Analysis Our facility conducts extensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The approach used to carry out these analyses is a HAZOP process. The studies are undertaken by a team of qualified personnel with expertise in engineering, process operations and safety and are revalidated at a regular interval of approximately every 5 years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purpose of safely conducting activities within our covered processes, Pactiv Corporation maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily available to operators involved in the processes. Training Pactiv Corporation utilizes a detailed training and certification program to ensure that employees who are operating processes using regulated substances are skilled in the handling, operation, and maintenance procedures associated with these processes. Refresher training is provided at least every 2 years and more frequently as needed. Mechanical Integrity Pactiv Corporation carries out routine, periodic maintenance inspections and preventive maintenance on process equipment to ensure proper operations. Process equipment examined during inspections include but are not limited to pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with training in maintenance practices. These personnel are provided specialized training as needed. Any equipment deficiencies identified by maintenance inspections are corr ected in a safe and timely manner. Management of Change Written procedures at Pactiv Corporation are in place to manage changes in process chemcials, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of changes and provided training, as needed, to deal with these changes. Pre-startup Safety Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Pactiv Corporation. These reviews are conducted to confirm that equipment and procedures are complete and suitable for safe startup prior to placing equipment into operation. Compliance Audits Pactiv Corporation conducts audits on a regular basis to determine whether the requirements set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective action s required as a result of the audits are undertaken in a safe and promt manner. Incident Investigation Pactiv Corporation promptly investigates any incident that results in, or could reasonably result in a catastrophic release of a regulated substance. Thes investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent a potential release from reoccurring. Reports are kept for a minimum of 5 years. Employee Participation Pactiv Corporation truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. Many employees participate in safety initiatives within the plant. In addition, our employees have access to all information created as part of our facility's implementation of RMP rule, including information resulting from process hazard analyses, in particular. Production employees sit in all HAZOP studies. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Proir to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Pactiv Corporation has a strict policy of informing contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of the procedures for emergency response should an accidental release of a regulated substance occur. Hot Work The facility maintains a hot work program and issues a hot work permit for hot work conducted on or near the covered process. Hot work is performed by qualified personnel who complete each permit and fulfill its requirements prior to the start of a hot work operation. These permits are kept on file until the conclusion of the hot work operation. 5. Five-year Accident History Pactiv Corporation has an excellent record of preven ting accidental releases over the last 5 years. There has been no accidental release during this period. 6. Emergency Response Plan Pactiv Corporation has developed a written emergency response plan to deal with incipient stage fires and minor releases of hazardous materials such as leaking packing on valves. The plan includes all aspects of emergency response including prompt notification of local emergency response agencies and the public; emergency evacuations, if necessary ; adequate first aid and medical treatment should any be necessary. The plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. In addition, emergency response equipment (fire extinguishers, etc.) is regularly inspected and serviced. 7. Planned Changes to Improve Safety Our facility has exemplary occupational safety and health programs which encompass employee involvement, recognition for safe work, and continuous haza rd identification activities. To enhance our continuous improvement in occupational safety and health, we have a Central Safety Committee made up of hourly employees and management staff working together. |