Specialty Industrial Products, Inc. - Executive Summary |
SPECIALTY INDUSTRIAL PRODUCTS, INC. SPARTANBURG, SOUTH CAROLINA RISK MANAGEMENT PLAN EXECUTIVE SUMMARY (40 CFR 68.155) Background Data In accordance with Title 40 of the Code of Federal Regulations Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Specialty Industrial Products, Inc. (SIP) submits this Risk Management Plan (RMP) for operations at their Spartanburg, South Carolina facility. SIP is a chemical manufacturing facility. SIP's operations include the manufacture of esters and other specialty chemicals. SIP has been in operation at this facility for over 20 years and provides over 50 jobs to the local community. Accidental Release Prevention and Emergency Response Policy SIP is committed to protecting the health of its employees, the surrounding community, and the environment; therefore it is SIP policy to maintain compliance with 40 CFR 68 as well as Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulat ions promulgated as Title 29 of the Code of Federal Regulations Chapter 1910, Section 119 (29 CFR 1910.119), and OSHA's Hazardous Operations and Emergency Response regulations (29 CFR 1910.120). Stationary Sources and Regulated Substances At SIP's Plant #2, trimethylamine (TMA) is reacted to produce a product for industrial distribution. SIP's system consisting of a pressurized storage vessel, a reactor vessel, and associated piping can contain a quantity of TMA in excess of the 10,000 pound threshold given in Appendix A of 40 CFR 68. Worst-case Release Scenario As required by 40 CFR 68 Subpart B, SIP has evaluated a worst-case release scenario for trimethylamine using the parameters specified by the EPA. SIP's worst-case release scenario is the rupture of the largest single tank (pressurized storage vessel). In developing the release parameters of this Worst-case Scenario, SIP considered that the quantity of the TMA vaporizes resulting in a vapor cloud explosion. Since the mod el was based on a TNT-equivalent method, a yield factor of 10 percent of the available energy released in the explosion was used to determine the distance to the explosion endpoint. No passive mitigation was considered since the TMA storage tank is located outside and adjacent to Plant #2. Using the EPA's RMP*Comp( program, it was determined that the distance to the explosion endpoint in this worst-case scenario has the potential to result in an offsite release. The worst-case release scenario was developed following EPA regulations and is not considered to be a likely release scenario. Alternative Release Scenario SIP evaluated several options to be considered as alternative release scenarios. After careful consideration, SIP decided that the scenario more likely to occur than the worst-case scenario, which could result in an offsite consequence, is the failure of a transfer hose during TMA loading operations. It is assumed that a TMA release from a transfer hose failure would result in a vapor cloud fire. In developing the release parameters of the Alternative Release Scenario, SIP considered average response time to shut the system down and excess flow valves as an active mitigation. Using EPA's RMP*Comp( program and EPA's RMP Offsite Consequence Analysis Guidance Document, the distance to the lower flammability limit (LFL) endpoint in the alternative release scenario has the potential to result in offsite consequences. Accidental Release Prevention Program To prevent and mitigate accidental releases of trimethylamine, SIP has implemented several precautionary measures. SIP is in the process of developing a process safety management (PSM) program as required by OSHA regulation 29 CFR 1910.119. Portions of the PSM have been conducted and are complete. As such, the TMA system has been evaluated for release potential. Some of the controls installed to prevent catastrophic releases of TMA are process equipment (vents, relief valves, check valves and ma nual shutoffs) and automated controls (interlocks and automatic shutoffs via remote switch). SIP has developed standard operating procedures (SOPs) with incorporated safety measures for all employees and contractors that have contact with the TMA system. SIP encourages employee participation in the development of the control measures used at the plant. Employees have the opportunity to voice opinions, concerns, questions, or ideas during the monthly training sessions or during the quarterly safety meetings. For topics that require more immediate attention, SIP employees may approach their supervisor directly or place suggestions in the suggestion box. SIP understands that maintaining the system in good working order is essential to preventing accidental releases. As such, SIP will conduct preventive maintenance on the process equipment on a monthly basis. The preventive maintenance program will be scheduled, documented and managed to ensure that regular maintenance occurs on the system. To confirm that control measures are effective in maintaining the safe operation of the plant, regularly scheduled audits will be performed on the TMA system. In accordance with the PSM program, SIP will conduct compliance audits every three years. Since the TMA system was recently installed this year, the first compliance audit will be conducted in the year 2002. Five-Year Accident History Over the last five years, SIP has not experienced an accidental offsite release of trimethylamine. Emergency Response Program SIP has documented emergency response procedures in order to facilitate response efforts in the event of an offsite TMA release. Included in the emergency response program are measures to be taken internally by SIP and procedures to inform local emergency response agencies. SIP has chosen to be a "non-responder" facility. As such, they are required to coordinate with local response agencies to ensure that they will be prepared to respond to an emergency a t SIP. Conversely, SIP has trained on-site personnel to respond to accidental TMA releases and other emergencies in early development. These personnel are trained in accordance with 29 CFR 1910.120, OSHA's Hazardous Operations and Emergency Response regulations according to their duties and function. They receive annual update training. To assure that the local municipal response agencies are familiar with SIP's emergency response procedures, copies of the emergency response document will be submitted for review and approval by the local fire department and the Spartanburg County Local Emergency Planning Committee (LEPC). In the event of a TMA release resulting in offsite consequences, the general public will be notified by the LEPC. Planned Changes to Improve Safety SIP has implemented a continuous training program to improve safety awareness. |