STEEL HEDDLE MANUFACTURING - Executive Summary |
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EXECUTIVE SUMMARY: THE ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The accidental release prevention and response policies have been documented in the Best Management Practices Plan, the Spill Prevention Control and Countermeasures Plan, and the Contingency Plans and Emergency Procedures. It is Steel Heddle's policy to do all within its power to prevent accidental releases of all materials which might be hazardous human health and/or the environment. It is not the policy of Steel Heddle to have trained personnel on-site to try and respond to an emergency situation created by an accidental releases. Rather, Steel Heddle has contacted local emergency response personnel who have agreed to respond to such situations. Accidental releases will be reported to the Plant Emergency Response Coordinator who will determine response action needed and see that such action is taken in a timely fashion. Spills that could be hazardous to human health and safety and/or the en vironment will be handled in accordance with the Accidental Release Measures on the Material Safety Data Sheet and the Contingency Plans and Emergency Procedures for the facility. These procedures require that local authorities that are trained in emergency response measures be contacted immediately to handle the situation. THE FACILITY AND REGULATED SUBSTANCE HANDLED Steel Heddle, Westminster Plant, is located in Westminster, South Carolina. It consists of one large manufacturing building, approximately 126,000 square feet, situated on 18 acres. It is located at the intersection of S.C. Highway 183 and S.C. Road 37-109. It is surrounded to the north by farmland and undeveloped property. To the south, across S.C. 37-109 is the Valentine Plant. To the west, across Highway 183, is FSOKJVB Church and AJR JAR General Repair. The plant employs appx. 100 people and operates 24 hours per day, seven days per week. The facility manufactures precision flat wire which requires rolling , heat-treating, and hot dip plating. The regulated substance is anhydrous ammonia (CAS #7664-41-7) stored in an appx. 10,000 gallon (50,000 pound) tank. This tank has been in service for this purpose for over fifteen years with no failures of the tank. The tank is secured by a chain-link fence that surrounds it entirely. The tank is located outside the main building and away from personnel who work inside. It is located away from direct heat and is not in close proximity to incompatible materials. The ammonia is in a pressure-vaporized state and is piped through above-ground lines to four disassociation chambers inside the building where it is separated into hydrogen and nitrogen for use in a heat treating process. THE WORST CASE RELEASE SCENARIO AND ALTERNATIVE RELEASE SCENARIO INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT DISTANCES FOR EACH REPORTED SCENARIO The modeling for worst case and alternate case scenarios was conducted by the SC DHEC Air Modeling Section using RMP*Comp. The worst case scenario would be a release of the total contents (appx. 50,000 pounds) of anhydrous ammonia into the surrounding area over a 10 minute time period. This scenario does not consider any administrative controls that would limit the quantity released to below the maximum capacity of the tank. The estimated distance to toxic endpoint would be 3.4 miles assuming a wind speed of 3.4 miles per hour. The alternative scenario would be a release of 2500 pounds over a 20 minute time period. No active or passive mitigation systems were considered when developing this scenario. The estimated distance to toxic endpoint would be 1.2 miles assuming a wind speed of 6.7 miles per hour. The plant Emergency Response Coordinator will assure that no water is added to the spilled material which would serve to warm the cryogenic liquid and result in greater gasification. The Emergency Response Coordinator will allow the material to autorefrigerate, if possible, and reduce the vapor release. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS This facility is classified as a non-generator of hazardous waste. However, it does fall under spill control regulations and measures have been taken to prevent accidental releases of all substances used in the manufacturing processes. Potential spill sources have been assessed in the Best Management Practices Plan and the Spill Prevention Control and Countermeasures Plan. These potential spill sources are inspected routinely, and preventive maintenance is performed by a trained maintenance staff. The anhydrous ammonia dissociation system is inspected for leaks at regularly scheduled intervals as a means by which to prevent significant releases to the environment. THE FIVE YEAR ACCIDENT HISTORY This facility has not had an accidental release of anhydrous ammonia over the past five years. THE EMERGENCY RESPONSE PROGRAM Arrangements have been made with the fo llowing agencies that have agreed to respond in the event of an emergency situation. Oconee Memorial Hospital Westminster Fire Department Oconee County Sheriff's Department Oconee County Emergency Preparedness Agency Up-dated copies of Steel Heddle's Contingency Plans and Emergency Procedures with reference to R.61-79.264 Subpart D are sent to the agencies. PLANNED CHANGES TO IMPROVE SAFETY Steel Heddle is doing a feasibility study on possibly eliminating the use of anhydrous ammonia by purchasing hydrogen and nitrogen separately for use in the heat treating lines. Hydrogen would be stored in quantities below the threshold requiring regulation under this standard. Nitrogen does not fall under the requirements of this standard. |