PMD Group, Inc. - Executive Summary |
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PMD Group, Inc. Plant Site RMP Risk Management Plan "Executive Summary" Per 40 CFR Part 68, Subpart "G" 68.155 Policy PMD Group, Inc. is committed to reducing the risk of harm posed by the use of hazardous substances to its employees, consultants, contractors, the general public and the environment. In support of this commitment, it is the policy of PMD Group, Inc.'s management to support, promote, and implement accidental release prevention and emergency response through this risk management plan (RMP). Facility Description (Stationary Source) Name: PMD Group, Inc. Address: 1296 3rd Street Northwest, Kalama, WA 98625 EPA I.D. #: WAD092899574 PMD Group, Inc. is located on the north boundary of the city of Kalama, between the Burlington Northern Railroad and the Columbia River, near river mile post 74. The facility operates 24 hours a day, three hundred and sixty five days a year. The site consists of 155 acres, of which 39 acres are filled with river dredging and are currently developed. There is a 720-foot dock of wood construction on the Columbia River. All activities on this dock are controlled and regulated by the United States Coast Guard, who has issued the facility a certificate of adequacy for reception facilities. Regulated Substances There are 141 regulated substances by the RPM. Of these, only acetaldehyde is present on the plant site above its threshold quantity (10,000 pounds). Acetaldehyde is used in the manufacture of Cinnamon oil (cinnamic aldehyde) which is the major component of cinnamon flavoring. Because cinnamic aldehyde is not manufactured continuously on the site, acetaldehyde is only on the plant site during cinnamic aldehyde production. The maximum amount of acetaldehyde on the plant site is limited to 46,872 pounds (7,200 gallons), which is 90% of the volume of its storage tank. Regulated Process Description Acetaldehyde is pur chased in single tank truckload shipments and is off loaded using nitrogen into a nitrogen padded, insulated storage tank. The acetaldehyde is blended with another raw material in a mix tank one batch at a time, and then the mixture is fed to a reactor where it is converted into cinnamic aldehyde. Each batch is made using an excess of the other raw material to ensure that during the reaction step all of the acetaldehyde is converted into cinnamic aldehyde. The storage tank, mix tank, and reactor all vent through a common header to a water scrubber for control of acetaldehyde vapors. Worst Case Release Scenario As dictated by 40 CFR 68.25(e) for flammables, the Worst Case Release Scenario (WCS) would be if the total amount of acetaldehyde in the storage tank is released, vaporized, ignited and involved in a vapor cloud explosion. Using the formula dictated by the EPA's RMP rule this would require the acetaldehyde storage tank to BLEVE (boiling liquid expanding vapor expl osion), resulting in an offsite impact. Administrative Controls to Limit the Impact Distance See the corresponding section under the Alternate Release Scenario (ARS) for the administrative controls used here to limit the impact distance of this WCS. Mitigation Measures to Limit the Impact Distance See the corresponding section under the Alternate Release Scenario (ARS) for the mitigation measures used to limit the impact distance of this WCS. Alternative Release Scenario The Kalama plant Acetaldehyde Process Hazard Analysis (PHA) was used as the principal source for Alternate Release Scenarios (ARS). The PHA utilized Fault Tree analysis based on a catastrophic release of acetaldehyde. Candidate ARSs from the PHA were screened to establish the most likely scenario according to impact, quantity, offsite impact, fuel source, ignition source, severity, and likelihood. Of the ARSs generated by the PHA only a variation of the worst case scenario was found to have an impa ct zone beyond the fence line. Alternative Release Scenario (continued) Once this ARS had been selected, the EPA's Offsite Consequence Guidance Manual was used to estimate the impact zone for a pool fire with vapor cloud explosion. To establish the most likely percent of the worst case scenario to be used as the ARS a review of the most likely tank level at which a BLEVE (boiling liquid expanding vapor explosion) would occur was done. This review yielded a 50% tank level. Therefore, the Alternate Release Scenario was found to be a BLEVE (boiling liquid expanding vapor explosion) of the acetaldehyde storage tank, containing 23,436 pounds (3,600 gallons) of acetaldehyde, caused by a fire impinging on the non-insulated, outside wall of the tank. Using the formula dictated by the EPA's RMP rule the resulting BLEVE would have an offsite impact. Administrative Controls to Limit the Impact Distance Prior to making any transfers into or out of the tank the operator is to i nspect the tank, transfer lines, and the receiving vessel for integrity to insure that there are no worn or damaged parts. In addition, the operator is to check that the receiving vessel has the empty space in it to receive the full amount of the intended transfer quantity without going over 90% in the receiving tank. During tank truck offloading and transfer operations an operator has to be present walking around inspecting for leaks. There is a mechanical integrity program at the facility that checks and tests the instrumentation and loss prevention systems (i.e. PSV, fire valve, fire suppression systems, fire water supply system, vessel and pipe thickness testing, etc.) A Process Hazard Analysis (PHA) program exists at the facility, which assesses the process every time there is a change and every five years if there are no changes. There is a Management of Change (MOC) system at the facility, which insures that when a revision of any kind is done with respect to this process (no matter how minor a change) everything is reviewed and changed as necessary. This includes, but not limited to, all engineering, all process safety information, all procedures, all training, all reporting, all notification, all documentation, and all auditing. The facility has a Spill Containment and Counter Measure Plan (SPCC Plan) designed to prevent any accidental releases, and with contingencies to contain and minimize an impact should a release occur. The facility has a HAZWOPER training program in place that keeps all company employees (186) and all of its major maintenance contractor's employees (33) current at their required HAZWOPER level. Currently this training program maintains 164 individuals at the technician level HAZWOPER, 14 at the incident commander level HAZWOPER, and 41 at the awareness level HAZWOPER. In addition to this hazardous materials training, the facility has a Process Safety Management training program, required by OSHA's Process Safety Management regulations that keeps each operational employee current in their individual job classification requirements. Alternative Release Scenario (continued) Mitigation Measures to Limit the Impact Distance The tank is designed such that both the filling and discharge activities are through the same line. A fusible link fire valve is installed in this line just prior to its attachment to the tank. Then, should a fire start during either of these activities, the fusible link will fail allowing the valve to shut, closing off the fuel source, which in turn stops the fire by stopping the flow of fuel. A fire system monitor, capable of delivering 700 gallons per minute, is located approximately 150 feet from the tank for cooling the tank to prevent vessel failure. The tank is completely wrapped in insulation to protect the tank from flame impingement. The tank supports are designed per the applicable NFPA codes for horizontal storage tanks used for the storage of flammable materials to prevent them from failing in the event a fire should occur. The tank sits inside of a dike, which is designed to contain the contents of the tank plus room for holding normal rainfall. All plant operational personnel are trained in defensive, tank cooling, fire hose tactics. General & Chemical Specific Accidental Release Prevention Steps As mentioned earlier in the administrative controls to limit the impact distance, prior to making any transfers into or out of the tank, the operator is to inspect the tank, transfer lines, and the receiving vessel for integrity to insure that there are no worn or damaged parts. In addition, the operator is to check that the receiving vessel has the empty space in it to receive the full amount of the intended transfer quantity without going over 90% in the receiving tank. Also, during tank truck offloading and transfer operations an operator has to be present, continuously walking around inspecti ng for leaks. Five Year Accident History There have been no events involving Acetaldehyde at the PMD Group, Inc. Kalama Plant site during the RMP Five Year Accidental Release History period. Emergency Response Program The facility has an emergency response plan at the plant designed to handle any of the ARS that were uncovered during the original and following PHA studies. This emergency response plan has been reviewed and modified to coordinate with the community emergency response plan. The emergency response plan has been reviewed with each of the individual community agencies (i.e. Cowlitz County Fire District #5, Cowlitz County Department of Emergency Management, Washington State Patrol, City of Kalama Public Works Department, Kalama City Police, Kalama Public School District, Cowlitz County Sheriff's Department, the City of Kalama, Cowlitz County Local Emergency Management Committee, to name a few). Planned Changes to Improve Safety This is a fully regul ated chemical facility. We will continue to comply with all of the following regulatory requirements designed to prevent releases and to promote safety: (01.) 29 CFR 1910.38 (02.) 29 CFR 1910.120 (03.) 30 CFR 254 (OPA-90) (04.) 33 CFR 154 (OPA-90) (05.) 33 CFR 156 (06.) 40 CFR 61, subpart V (07.) 40 CFR 112 (08.) 40 CFR 122 (09.) 40 CFR 112 (OPA-90) (10.) 40 CFR 123 (11.) 40 CFR 124 (12.) 40 CFR 264 (13.) 40 CFR 265 (14.) 40 CFR 279.52 (15.) 40 CFR 402 (p) (16.) 49 CFR 100-181 (17.) 49 CFR 194 (OPA-90) (18.) RCW 90.48 (19.) RCW 70.94 (20.) WAC 173-200 (21.) WAC 173-201 (22.) WAC 173-204 (23.) WAC 173-400 (24.) WAC 173-460 (25.) WAC 173-307-010 (26.) WAC 173-303-170 (27.) CMA's Responsible CAER Code. |