Atlas Roofing Corporation, LaGrange Facility - Executive Summary |
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REDACTED VERSION Atlas Roofing Corporation. Risk Management Program Executive Summary 1.0 Introduction Atlas Roofing Corporation operates a foam insulation products facility in LaGrange, Georgia. Due to the quantity of a flammable hydrocarbon stored at the facility the facility is subject to the United States Environmental Protection Agency's Risk Management Program. The purpose of the Risk Management Program is to prevent or reduce the severity of an accidental release of a hazardous chemical. Among the requirements of the Risk Management Program is the submission of a Risk Management Plan (RMP) summarizing the overall program. The following information is an Executive Summary of the information contained in the Risk Management Program. This Executive Summary includes a description of the company's accidental release prevention and safety policies, a facility and process description, an explanation of the accidental release scenarios studied, a five-year accident history, and details of the facility's accidental release prevention program. 2.0 Accidental Release Prevention Policies Atlas Roofing Corporation takes great care to ensure the safety of its employees and the surrounding community. Corporate and facility policies and safety programs are stressed in all aspects of facility operations. Atlas Roofing Corporation's safety program provides rules and guidance for safe working methods in the operation, maintenance, and construction of the facility. The safety program includes the required personal protective equipment and safe work practices including lockout and tagout, hot work permitting, confined space entry, forklift operation, and flammable and toxic chemical handling. Employees are trained in the safe operation of the facility. 3.0 Facility and Process Description The Atlas Roofing Corporation, LaGrange facility, manufactures foam insulation products for use in the housing industry. The manufacture of foam insulation products proceeds as f ollows: Raw materials are transported to the facility by rail car and truck. The chemicals are transferred from the rail cars or trucks to individual storage tanks except for some minor ingredients that are stored in drums or totes. The materials are transferred as needed to holding tanks and then to mixing tanks according to the foam formulation. From the mixing tanks, the foam is poured onto a conveyor line that moves the foam through each step of processing. The liquid foam is poured onto a facer material in evenly spaced intervals and the foam and facer travel to the laminator to be heated. In the laminator, the foam rapidly solidifies and expands to the predesignated thickness. Next, the foam moves down the line to be cut to premeasured lengths. Once the foam is cut to size, it is stacked, wrapped, and sent to the warehouse for shipping to customers. 4.0 Regulated Substances Present One flammable hydrocarbon stored at the facility is subject to the Risk Management Program regu lations. Atlas Roofing Corporation is claiming the exact identity of the substance as Confidential Business Information. 5.0 Release Scenarios As required by the Risk Management Program regulations, Atlas Roofing Corporation determined the offsite impact of an accidental release for both a worst case release and an alternate release scenario. The regulations define the worst case release as the loss of the entire maximum inventory of the largest tank or vessel. The regulations require that the offsite impact of the worst case release be calculated using very conservative, worst case, weather conditions. USEPA has published reference tables to be used in calculating the distance offsite that an accidental release would travel. These tables employ very conservative assumptions and therefore provide conservative estimates of the offsite distance that an accidental release would travel. Atlas Roofing Corporation used the USEPA reference tables to calculate a worst-case offsite impact r adius. Atlas Roofing Corporation also calculated the offsite impact distance for an alternate, more realistic accidental release scenario. This release scenario took into consideration safety systems and controls in place to reduce the severity of an accidental release and considered a more realistic release rate of the flammable chemical. The alternate release considered resulted from a hose rupture caused by a pull-away during tank filling. The release was assumed to result in a vapor cloud explosion. 6.0 Accidental Release Prevention Program The facility's accident prevention program includes each of the elements required by the Risk Management Program regulations. 6.1 Process Safety Information Atlas Roofing Corporation has gathered the necessary documentation of safety information on the covered process including the maximum/minimum pressure, temperature, and inventory in covered tanks, the tank and piping materials of construction, documentation of design codes and standar ds used for the tanks and piping, and a description of safety systems in place. This information is periodically reviewed to ensure that the process is constructed according to good engineering practices. 6.2 Process Hazard Review A Process Hazard Review has been conducted on the covered processes to determine the potential hazards of the process and to determine the possible equipment failures or human errors that could lead to a release. The results of the review were used to determine the appropriate safeguards needed to prevent failures or errors that could lead to a release. 6.3 Operating Procedures Written operating procedures have been developed for operations. The purpose of the written operating procedures is to make sure that each employee before operating a process is knowledgeable of the correct operating methods, is aware of the chemical hazards present, and is qualified to respond correctly in an emergency situation. 6.4 Training New employees are trained in the safe operation of plant processes and their performance is periodically evaluated. As needed, refresher training is provided. Employees are given safety training and are trained in the emergency response procedures discussed in Section 8.0. 6.5 Maintenance Written maintenance procedures and training guide the safe work practices of maintenance employees and ensure that they are made aware of the potential hazards of the plant processes. A hot work permitting program, lockout tagout procedures, and confined space entry procedures have been put in place to protect maintenance workers while servicing equipment. Preventive maintenance inspections and testing are schedule based on manufacturers recommendations so that aging equipment can be replaced before failing and possibly causing an accidental release. 7.0 Five Year Accident History No serious accidents have occurred at the facility in the last five years. 8.0 Emergency Response Coordination A facility whose employees will not respond to accidental releases of regulated substances must coordinate response actions with the local emergency responders. The facility has satisfied this requirement. 9.0 Planned Future Safety Enhancements Planned safety enhancements include the continued development of the facility's preventive maintenance program and ongoing safety training and new employee orientation. Together, these programs will continue to ensure the safety of employees and the community. |