CertainTeed, Athens Plant - Executive Summary |
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General Executive Summary 1. Accidental Release Prevention and Emergency Response Policies We at CertainTeed, Athens Plant are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass manufacture of wool fiberglass insulation. We have 2 regulated substances present at our facility. These substances include propane and ammonia (aqueous). Propane is used for an alternate fuel and ammonia (aqueous) is used as a process ingredient. The maximum inventory of propane at our facility is 487335.00 lb. while ammonia (aqueous) is pres ent at our facility in a maximum quantity of 23765.40 lb.. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Aqua ammonia storage. In this scenario 23765 lb. of Ammonia (conc 30%) is released. The toxic liquid released is assumed to form a pool inside a diked area from which evaporation takes place for 10 minutes Passive mitigation systems such as dike(s) are also taken into account to calculate the scenario. These mitigation systems have the effect of limiting the evaporation. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.43 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario for Ammonia (conc 20% or greater) involves a release from Aqua ammonia storage. The scenario involves the release of 11883 lb. of aqueous ammonia. The same passive mitigation controls are taken into account to calculate the scenario, having the effect of limiting the evaporation rate. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (conc 20% or greater) is 0.19 miles. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from propane storage. In this scenario 487335 lb. of Propane is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calcul ated distance of 0.64 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from propane storage. The release is assumed to result in a Vapor Cloud Fire. The scenario involves the release of 243882 lb. of Propane in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of Lower flammability limit is 0.14 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 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information CertainTeed, Athens Plant maintains a detailed record of safety information that describes the chemical hazards, operat ing parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is common sense, checklist, review of drawings, and physical evaluation. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated as needed. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 05/11/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, CertainTeed, Athens Plant 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 accessible to operators involved in the processes. Training CertainTeed, Athens Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every year and more frequently as needed. Mechanical Integrity CertainTeed, Athens Plant carries out maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; 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 previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a s afe and timely manner. Management of Change Written procedures are in place at CertainTeed, Athens Plant to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/11/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a matter of policy. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. There have been no recent start up activities necessitating such a review at the CertainTeed Athens plant. Compliance Audits CertainTeed, Athens Plant conducts audits on a regul ar basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on March 30, 1999. These audits are carried out at least every year and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation CertainTeed, Athens Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation CertainTeed, Athens Plant 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. In additi on, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. CertainTeed, Athens Plant has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History CertainTeed, Athens Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan CertainTe ed, Athens Plant carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Georgia ERC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. are some of the major steps we want to take to improve safe ty at our facility. These changes are expected to be implemented by 5/15/99. |