Liberty Manufacturing, Inc. - Executive Summary |
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EXECUTIVE SUMMARY Facility Overview: The Liberty Mfg., Inc. facility in Liberty, SC is a textile manufacturing operation primarily providing woven and finished denim products. The facility is regulated under RMP due to onsite chlorine storage being in excess of the 2500 toxicity RMP applicability threshold in a single process. The facility's only RMP covered process is the chlorine storage system which provides fecal ellimination in wastetreatment operation. The covered process consists of two (2) tanks with the single largest vessel storing a maximum of 2,000 pounds. Chemical Safety Overview: The facility's overall approach and commitment to chemical safety is demonstrated by 1) the existing management, training, procedure and maintenance systems already in place at the facility, and 2) the hazard assessment, prevention program and emergency response provisions implemented specifically for chlorine in response to the RMP requirements. The management structure and oversight to ensure safety is documented in the facility's RMP and includes compliance with applicable regulations, codes and standards (US EPA 40 CFR 68). Release Scenario's: Worst-case and alternative release scenario assessments were conducted for the facility's single largest vessel based on US EPA's Offsite Consequences Analysis guidance. The worst case scenario assumes that a 2000 lb. cylinder is released over a period of 10 minutes. anda alternative scenario assumes a 3/16" diameter transfer hose failure with a release rate of 87 lb./min. and public receptors were determined to be located within the impact zone of both the worst-case and alternative releases. The resulting worst-case and alternative release impact zones were (1.3) miles and (0.2) miles, respectively. Five-Year Accident History: The facility has had no RMP reportable accidents/releases of chlorine within the five years proceeding RMP submittal. Prevention Program: The facility has implemented a Program 3 le vel Prevention Program, as required by the RMP rules, in accordance with US EPA, and vendor guidance for chlorine. These prevention program provisions are specifically intended to minimize the probability and/or consequences of any accidental chlorine release from the facility and include such measures as a system hazard review, operating and maintenance procedures, training, compliance auditing, a management system and updates, etc. The facility prevention program is an ongoing system based on periodic training, incident investigations, audits, procedure revisions, and RMP updates as required to reflect facility change and RMP requirements. Emergency Response Program: The facility has coordinated response with the City of Liberty Fire Department to ensure that they will respond to any accidental release from the chlorine system. The facility has also established a notification mechanism to ensure the Fire Department will be properly notified when any response is needed for a ch lorine release. Based on this coordination with the local emergency responders, the facility is not required to implement additional RMP emergency response program requirements. Safety Management and Changes: The facility is committed to ensuring its operations are safe and in accordance with all RMP requirements, and has established a senior manager responsible for RMP development, implementation and compliance. This manager is committed to maintain the safety of the RMP covered chlorine system through active adherence to the appropriate procedures and codes. To ensure that the appropriate changes occur as necessary to maintain/improve safety, ongoing hazard reviews, training, audits, maintenance and investigations will be conducted as required by RMP. Updates to the RMP will be completed as necessary in response to these activities. Summary: As documented in this submittal, the RMP for the facility has been completed in accordance with all 40 CFR 68 requirements and the facility has certified RMP compliance. |