TACC International Corp - Cartersville Plant - Executive Summary |
|
Executive Summary: Environmental and Safety Policy: TACC International Corporation (TACC) is committed to improving the environment through the products and services that it offers and to providing its products and services in a manner demonstrably protective of human health, safety and the environment. It is the policy of TACC to minimize risk and protect employees and others in the vicinity of its operations by employing safe technologies and operating procedures and by being prepared for emergencies. To this effect, TACC has developed and implemented an Integrated Compliance Plan (ICP) for compliance with all applicable environmental and safety regulations. Facility Description: TACC operates an adhesive manufacturing facility located in Cartersville, Bartow County, Georgia. The facility covers an area of approximately 7.1 acres. The facility building houses manufacturing, office, and warehouse space. Other structures on the site include three aboveground storage tanks (AST) and associated aboveground piping. The vicinity of the site is a light commercial and industrial area. Regulated Substance(s): Based on a comprehensive review, TACC has identified the following substances regulated by the United States Environmental Protection Agency's (EPA) Risk Management Program (RMP) (regulated substances) at the facility: i) isopentane; ii) dimethyl ether; and iii) a 50/50 mixture of propane and isobutane. The maximum quantities available on site (facility-wide) are 33,600 lbs of isopentane; 56,100 lbs of dimethyl ether; 34,120 lbs of propane; and 34,120 lbs of isobutane. All of these regulated substances are above the threshold quantity (TQ) for applicability of RMP. The provisions of the RMP therefore apply to the processes using these regulated substances. Isopentane, dimethyl ether, and the propane/isobutane mixture are used in the manufacturing processes at TACC and are stored in horizontal, aboveground tanks with capacities of 8,000 gallons, 12,000 gal lons, and 18,000 gallons, respectively. Worst-Case Release Scenario: The worst-case release scenario (WCS) was based on the catastrophic rupture of the single largest vessel in each process, which corresponds to the three ASTs. As per the RMP, the entire quantity of the substance was considered released. An administrative control in place for each of the tanks limits the maximum fill to 85% of tank capacity. The only passive mitigation measure in place is a concrete dike around the 8,000-gallon isopentane tank. Both the administrative controls and the concrete dike on the isopentane tank were considered when modeling the worst-case releases. RMP default meteorological data was selected and EPA's RMP*Comp software was used for determining the impact distance. The scenarios were shown to have off-site impacts. TACC believes that the worst-case scenarios are extremely unlikely. First, the tanks are designed to withstand a pressure of 250 psig, but operate at much lower pressures (5 -70 psig). Second, per the existing safety practices at the facility for these processes, the tanks are regularly inspected and tested for mechanical integrity. Finally, the area is not known to have earthquakes or tornado activities. Alternative Release Scenario: Several alternative release scenarios (ARS) were evaluated for the process. The scenarios were selected based on EPA guidelines. TACC believes that these scenarios are more likely than the WCS, though still unlikely in view of the on-going safety practices. As for the WCS, the administrative control limiting the maximum fill of each AST to 85% of tank capacity was considered, as well as the concrete dike for the isopentane tank. RMP default meteorological data was selected, and EPA's RMP*Comp software was used for determining off-site impact. For the ARSs considered, the distance to the endpoint for the various regulated substances was between 0.005 mile and 0.2 mile. Accident Prevention Program: The TACC facility ha s developed and implemented a Contingency and Emergency Response program for the processes using hazardous substances. TACC performs regular inspections of all process components. Safe operating procedures are regularly reviewed and updated whenever necessary. Employees are regularly trained in handling hazardous substances, operating equipment safely, and in emergency response actions. Five-year Accident History: There have been no accidental releases from any of the covered processes at the facility in the last five years, which meet the reporting criteria of the RMP. Emergency Response Program: The facility is not included in the community emergency response plans of Bartow County. However, the facility has developed and implemented an emergency response plan that meets the requirements of EPA's Integrated Contingency Plan (ICP). The emergency plan includes emergency and incident notification reporting, emergency health care, emergency response actions, training and drills, and an incident prevention program. The facility's emergency response plan has been coordinated with the Coosa Valley Regional Development Center. The plan has been updated in February 1999 and will be updated whenever there are changes at the facility that may impact emergency response actions. Copies of the plan are made available to the local LEPC and fire department. Safety Improvements: TACC believes that the processes storing and using the regulated substances are operated and maintained in a safe manner. There are no additional plans for changes specific to this process. However, improving safety is an on-going practice at the facility. TACC plans to take all necessary, realistic, and technically and economically feasible actions to improve safety. |