Southern States Cooperative- Cleveland, NC (3101) - Executive Summary |
|
EXECUTIVE SUMMARY (Site: 3101) The accidental release prevention and emergency response policies at your facility: This facility handles formaldehyde (33% solution), which is considered to be a regulated toxic substance by EPA. We observe all necessary safety precautions in handling formaldehyde to prevent unnecessary human exposure, to reduce the threat to our own personal health and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable federal, state and local rules and regulations. Safety depends upon the manner in which we handle formaldehyde, the safety devices inherent to the design of this facility, the safe handling procedures that we use and the training of our personnel. This facility complies with all requirements for formaldehyde storage. If an emergency were to occur, it is our policy to notify the local emergency response agency. A description of your facility and the regulated substances handled: The primary purpos e of this facility is feed production. We receive formaldehyde by transport truck and store it as a liquid in an atmospheric vessel. Access to the process is restricted to authorized employees and contractors. The maximum amount of formaldehyde that can be stored at this facility is 6,400 gallons (water capacity). The worst case and alternative release scenarios: The worst-case release scenario is failure of one 6,400 gallon tank when filled to its maximum allowable capacity, resulting in a release of formaldehyde. The distance to the endpoint of 140 ppm is 1.50 miles, based on RMP Comp, EPA's release analysis software. This distance extends beyond the facility boundary and there are estimated to be 478 residents and a school within the distance to endpoint. The alternative release scenario consists of the release of 1,450 pounds of formaldehyde solution over a period of ten minutes due to a leaking pipe. The operator observes the leak and isolates the leaking pipe by closing the shut-off valves. The distance to the endpoint of 140 ppm is 317 feet, based on RMP Comp. This distance extends beyond the facility boundary and there are no receptors within the distance to endpoint. The general accidental release prevention program and chemical-specific prevention steps: This facility complies with EPA's accident prevention rule and all applicable state and local codes and regulations. The formaldehyde system is designed, installed, and maintained in accordance with federal and state law. Process Safety Information We maintain safety information that describes the chemical hazards, operating parameters and equipment designs associated with our formaldehyde storage facility. Process Hazard Review Our Environmental, Health, Safety and Security (EHSS) team conducts comprehensive studies and reviews to ensure that hazards associated with our processes are identified and controlled efficiently. These activities are undertaken by a team of qualified personnel w ith expertise in process operations and are revalidated at a regular interval. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures We maintain written operating procedures for operation of the formaldehyde storage facility. These procedures address various modes of operation including initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is readily accessible to operators. Training We have 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 three years. Maintenance Our EHSS team performs thorough annual maintenance inspections on process equipment to ensure proper operations. Basic visual inspections are performed by facility operators on a more frequent basis du ring loading and unloading of formaldehyde delivery vehicles. Process equipment examined by these checks includes: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are performed by qualified personnel that have been trained in safe maintenance practices. Any equipment deficiencies are corrected in a safe and timely manner. Compliance Audits We conduct compliance audits on a regular basis to confirm that the provisions set out under the RMP rule are being implemented. These audits are performed at least every 3 years and any corrective actions required as a result of the audits are undertaken in a timely manner. Incident Investigation We promptly investigate any incident that has resulted in, or could reasonably result in, a catastrophic release of formaldehyde. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to pr event the incident from reoccurring. All reports are retained for a minimum of 5 years. Five-year accident history: Due to our comprehensive safety program, this facility has never had an accident involving formaldehyde that caused deaths, injuries, property or environmental damage, evacuations, or shelterings in place. The emergency response program: It is company policy for each of our facilities to maintain an Emergency Action Plan & Emergency Response Plan. This plan addresses chemical inventory, evacuation procedures and instructions for notifying emergency response agencies. This plan is reviewed on an annual basis and is included in the employee training program. In the event of an emergency, it is our policy to notify the local emergency response agency and request that they respond to the emergency. Planned changes to improve safety: We will continue to implement our safety program to guarantee that our facility is operated in a safe and reliable manner and to ensur e the safety of our employees and the surrounding community. |