Environmental Protection Agency Risk Management Plan 5393 Ohio

                             Executive Summary 21-JUN-1999

Von Roll America, Inc, East Liverpool, OH 43920

Executive Summary
Environmental and Safety Policy:
It is the policy of Von Roll America Inc. (Von Roll) to conduct itself
as a good corporate citizen, to be a responsible member of the
region's industrial community, and to comply with all federal, state,
and local environmental laws and regulations. Von Roll strives
continuously to maintain safe operations and implements safe operating
procedures in all processes at the facility.
Von Roll practices a proactive approach with respect to communications
with East Liverpool and neighboring communities. A monthly newsletter
is published and distributed to 1200 people including employees,
regulators, local residents, and elected officials. The facility's Web
Page provides information on safety,
environment, training, plant improvements, tours, and other pertinent
information. Voluntarily, monthly meetings are held with two local
citizens groups (Community Advisory Council and East Liverpool Liaison
Committee) for updates on plant operations, permitting, and safety.
Communication channels are also established through participation of
facility employees in local civic organizations such as the Kiwanis,
Rotary, and Lions.
In short, Von Roll maintains safe operations at the facility and
practices open communication with the local community, many of whom
are employees of the facility.
Facility Operations and Setting:
Von Roll operates a hazardous waste treatment, storage, and disposal
facility (TSDF) in East Liverpool, Ohio. Solid and liquid wastes
within permit specifications are received in the facility and
thermally treated in a rotary kiln incinerator. The facility has a
final permit status under the Resource Conservation and Recovery Act
of 1976 (RCRA).
Wastes are received at the facility in liquid, solid, and semisolid
form in packages (lined boxes, fiber packs, metal cans, drums, and
reusable containers) or in bulk (dump trucks or tank wagons). The
wastes are pre-approved and registered in a computerized tracking
system. Upon arrival, the wastes are weighed and the associated
paperwork reviewed to verify compliance with regulatory requirements.
The wastes are sampled and, after approval, directed to the
appropriate process treatment area. Bulk solids are emptied directly
into storage pits, then transferred into the feed hopper of the kiln
by a clamshell bucket crane. Bulk liquid wastes are unloaded under a
roof in a diked, concrete area. The tankers are purged with nitrogen.
Fugitive emissions are captured and ducted to the incinerator or
treated through activated carbon units. Limited types of bulk liquid
wastes are pumped directly to the kiln from the tankers. Drummed
wastes are processed under a roof in the drum processing building.
Organic waste blending occurs in an indoor tank farm.
All waste handling, storage, and treatment areas are concrete diked
and contain collection sumps to capture any spilled materials. In
addition, overhead ventilation hoods that vent to the incinerator or
activated carbon units service all handling areas.
The facility is located approximately 30 miles northwest of
Pittsburgh, Pennsylvania on the Ohio River in East Liverpool,
Columbiana County, Ohio. The facility is located directly across the
Ohio River from West Virginia and less than one-half mile from the
Pennsylvania-Ohio border. The area in the immediate vicinity is mixed
residential and commercial, with some light industrial activity
present. The facility is situated on a 21.5 acre tract. The site is
bordered on the north by Conrail railroad tracks, on the west by an
industrial supply company (GRH Co.), and on the south and east by the
Ohio River. The area immediately surrounding these properties is zoned
medium-high density residential use.
The topography of the area is gently rolling, except in the immediate
vicinity of the site where the Ohio River forms a steep river valley.
Considering the local and regional topographic elevations near the
site, it is likely that the winds will be channeled along the valley,
with predominant wind flow to the east-northeast. The closest
incorporated areas to the facility include East Liverpool, Ohio;
Chester, West Virginia; Wellsville, Ohio; and Midland, Pennsylvania.
Regulated Substance(s):
Von Roll does not generate any appreciable amount of waste or
chemicals at the facility. All chemicals at the facility are received
from waste generators around the nation. The facility receives wastes
from various generators and the constituents of the wastes vary. It is
impossible for Von Roll to predict the type of waste entering the
facility. However, only wastes conforming to pre-selected profiles are
accepted at the facility. The waste profiles include constituents and
ranges of percentage of the constituents. The waste profiles are the
basis of determining the regulated substances for the Risk Management
Program.
Based on a comprehensive review of waste profiles received at the
facility in the calendar year 1998, the following regulated substances
could be reasonably expected to be present at the facility at any
given time above the threshold quantity (TQ) established pursuant to
the Risk Management Program (RMP):
' Ethyl ether, chloroform, carbon disulfide, vinylidene chloride,
methyltrichlorosilane, pentane, furan, crotonaldehyde, hydrofluoric
acid, and trichlorosilane.
The regulated substances are present in five processes; namely: i) the
organic waste tank farm; ii) the drum storage area; iii) the
pump-out/blend tanks; iv) the drum conveying area; and v) the direct
feed to the kiln.
Worst-Case Release Scenario:
The worst-case release scenario (WCS) for toxic substances was based
on the catastrophic rupture of the single largest vessel in the
organic tank farm, in which 100,000 lbs of furan in a waste mixture
was considered to be spilled in a diked area. Furan was assumed to be
evaporating after the spill. Administrative controls on the maximum
quantity of furan was considered, based on the permitted waste
profile. Credit was taken for passive mitigation such as indoor
release into a diked area. The WCS for flammable substances was a
theoretical spill of 340,000 lbs of a mixture containing pentane from
the largest tank in the tank farm, evaporation of pentane from the
liquid pool, and subsequent vapor cloud explosion.
RMP default meteorological data were selected and EPA's RMP*COMP
software was used for determining off-site impact. The WCS for both
toxic and flammable substances were shown to have off-site impact.
Worst-case release scenarios from other covered processes at the
facility did not impact any additional public or environmental
receptors.
Von Roll believes that the WCS (i.e. catastrophic rupture of a tank in
the tank farm) is extremely unlikely. First, the tank is at ambient
pressure and temperature and is located indoors within a secured
building. Second, per the existing process safety management (PSM)
practices at the facility for this process, the tanks are regularly
inspected and tested for mechanical integrity. Third, the area is not
known to have earthquakes. Fourth, the WCS assumes that active
mitigation measures are not functioning. Finally, a catastrophic
release from such tanks has never been reported in the industry. The
impact distances for these scenarios therefore are highly conservative
and are not realistic.
A recent EPA analysis of potential accidental release scenarios at the
facility identified a most conservative on-site spill of only 5,000
gallons, or approximately 12% of the quantity considered in the WCS.
Alternative Release Scenarios:
Several alternative release scenarios (ARS) were evaluated for the
process. The scenarios were selected based on process hazard analyses
performed by the facility, EPA guidelines, and industry guidelines.
Von Roll believes that these scenarios are more likely than WCS,
though still unlikely in view of the on-going PSM practices. The ARS
was a spill from a tank in the organic tank farm. One ARS was
considered for each toxic substance. For flammable substances, the ARS
was a release of a mixture containing pentane and subsequent pool
fire. Administrative controls and passive mitigation were considered
as in the case of WCS. Additionally, active mitigation by on-site
responders was also considered to contain the spill within 10 minutes.
RMP default meteorological data was selected and EPA's RMP*COMP
software was used for determining off-site impact. For ARSs for toxic
substances, the distance to the endpoint for the various regulated
substances was between 0.1 mile and 0.7 mile (furan). For flammable
substance, the impact distance of ARS was 0.07 miles.
Accident Prevention Program:
The Von Roll facility has developed and implemented a PSM program for
the processes covered by the RMP. Von Roll performs daily, monthly,
and annual inspections of all process components. Safe operating
procedures are regularly reviewed and updated whenever necessary. The
operators are regularly trained on handling wastes in the various
process areas and on emergency response actions. Deluge systems are
installed at all possible areas of release to contain fires. In
addition, any release within the buildings is vented to the
incinerator or activated carbon system, which operates continuously.
In November 1998, Von Roll became the first commercial hazardous waste
incineration facility to obtain certification to the ISO 14001
standard, the international standard for environmental management. As
part of the process, Von Roll has critically reviewed safety and
health issues at the facility and has taken appropriate measures to
exceed all standards. The ISO certification demonstrates Von Roll's
commitment to the employees and the community by maintaining safe
operations.
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. Von Roll is committed to maintaining
this safety record.
Emergency Response Program:
The facility is not included in the community emergency response plans
of Columbiana County. However, the facility has developed and
implemented an emergency response plan. The emergency plan includes
emergency and incident notification reporting, emergency health care,
emergency response actions, training and drills, and an incident
prevention program, which fulfills all requirements of RMP. Emergency
response training is part of the plan and the most recent training was
performed in April 1999. The facility's emergency response plans are
coordinated with the East Liverpool Fire Department. The plan was
updated in March 1998 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 county LEPC and city fire
department.
Planned Safety Improvements:
Von Roll believes that the processes at the facility are operated and
maintained in a safe manner. There are no additional plans for changes
specific to the processes covered by RMP. However, improving safety is
continuously ongoing at the facility. Von Roll plans to take all
necessary, realistic, and technically and economically feasible
actions to improve safety, whenever determined to be necessary.
_________________________________________________________________

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This site was updated on June 18, 1999

 RMP Facility ID: 1000 0006 8099 5393
EPA Registration
Prepared: Aug 24 19:25:54 1999Author: RMPinfo@ombwatch.org