Hunt Corporation - Bienfang Products Division - Executive Summary |
|
Executive Summary A. Description of Stationary Source and Regulated Substances Handled Hunt Corporation (Hunt) is a manufacturing facility located in Statesville, North Carolina. As a result of the manufacturing process, isopentane is stored at the facility in quantities that exceed the 10,000 pound threshold quantity specified by the EPA Risk Management Program (RMP) regulation. The facility has one covered process that requires the facility meet Program 1 requirements under the EPA RMP regulation. Hunt maintains a 10,000 gallon underground storage tank of isopentane which is used in the production of polystyrene foam products. The isopentane is fed from the underground storage tank into the pump house, where it is pressurized to approximately 115 psi and fed in to one of the three extruders. Since the Title V permit has not been issued for this facility at this time, the permit ID number has not been entered into the RMPSubmit. B. Accidental Release Prevention & Emergency Response Policies of Hunt Hunt is committed to protecting facility personnel, the public and the environment from any workplace and accidental release hazards. Appropriate responses to releases of regulated chemicals are documented in the Plant Safety Manual and Stormwater Spill Plan. Safety, environmental protection and risk management programs are fully implemented and coordinated with community emergency responders for emergency planning and response efforts. C. Worst-Case Release Scenario The following is a brief description of the worst-case release scenario that is being submitted by Hunt in the Risk Management Plan (RMPlan). Hunt elected to use the EPA Offsite Consequence Analysis Guidance Document and the look-up tables contained in this document to calculate estimated release rates and to determine the distance to the appropriate flammable endpoint Although, Hunt maintains a 10,000 gallon storage tank of isopentane, the EPA RMP General Guidance for Risk Management P rograms (July 1998, Page 4-11) states that vessels sufficiently buried underground are passively mitigated or prevented from failing catastrophically. Therefore the failure of piping connected to underground storage for the worst-case and alternative scenarios should be evaluated. The worst-case flammable release scenario for Hunt was determined to be a vapor cloud explosion involving 24 pounds of isopentane from the aboveground process piping used to transfer liquid isopentane from the underground storage tank to the pump house. The release would involve the instantaneous loss of isopentane from approximately 112 feet of 1 inch diameter pipe. Using the EPA look-up tables, the release was estimated have a 1 psia overpressure at approximately 121 feet from the release location. The distance from the point at which the process piping comes above ground to the property boundary of an adjacent facility is 138 feet. D. Five-year Accident History Under the EPA RMP regulations, an ac cidental release is defined as a release of a regulated substance that "resulted in deaths, injuries or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage." Within the past five years, Hunt has has had two accidents involving employees only as follows: 1997 a flash fire resulted in the burn to the face and eye of one employee. The fire was a flash fire of the product which still contains trace levels of isopentane and is therefore, reported in this document. There is not much information available about the details of the fire. The amount of isopentane released would be minimal and the duration would be almost instantaneous. Subsequently employees were trained to wear proper personel protective equipment when working near the extruder die. This accident did not involve off-site impacts nor was it necessary to notify emergenc y responders. E. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The Hunt facility complies with the RMP regulation requirements for its Program 1 covered process. The facility also complies with all applicable state and local codes and regulations. F. Emergency Response Program Employees at the Hunt facility will only respond to incidental releases of isopentane where the release can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel. For non-incidental releases Hunt will rely on outside responders, therefore, they do not have to comply with either OSHA 1910.38(a), or 1910.120 and do not have to develop and Emergency Response Program under 40 CFR 68.95. G. Planned Changes to Improve Safety By meeting the Program 1 eligibility requirements, Hunt believes that the existing safety program is adequate. However, if any changes occur in the futu re which affect the isopentane process, these changes will be thoroughly reviewed to ensure that the safety of Hunt employees and neighbors is not compromised. |