AEROSOL SYSTEMS - Executive Summary

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APRIL 1999 
The purpose of Aerosol Systems' Risk Management Plan is to prevent accidental releases and reduce the severity of those releases that do occur. 
It is the continuing policy of Aerosol Systems to conduct its operations in compliance with all applicable laws and regulations (including other EPA regulation, general OSHA standards, OSHA Process Safety Management, NFPA standards and ASTM and ASME standards), to monitor operations to insure compliance, and to avoid creating any unacceptable risks to the environment. 
Aerosol Systems has and will continue vigorously to: 
-    Establish and maintain programs to assure that environmental laws and regulations applicable to its products and operations are known and obeyed. 
-    Adopt its own standards where laws or regulations may not be adequately protective, and adopt, where necessary, its own standards where laws do not exist. 
-    Work constructively with government agencies, trade associations and 
others to develop balances, cost effective and realistic laws, regulations, and standards to protect public health and the environment. 
To carry out this policy Aerosol Systems will, therefore, continue to: 
1.    Identify and control employee safety, public health, or environmental hazards stemming from its operations and products and conduct management audits of installed control equipment; 
2.    Initiate ongoing waste minimization programs which, by process improvement or other methods, will endeavor to continually reduce the levels of emissions and volume of waste disposal; 
3.    Curtail any manufacturing operation if the safety or environmental impacts are unacceptable until such time as corrective action has been complete; 
4.    Provide training to employees at all levels to acquaint them with their responsibilities for reporting and methods of operating equipment, and handling and transporting hazardous materials in a safe and environmentally acceptable manner 
5.    Assign responsibility and a 
uthority for actions and decisions required to achieve this commitment for high standards of safety and environmental management; 
Every employee is expected to adhere to the spirit as well as the letter of this policy.  This policy should be accomplished by acting so as to prevent environmental problems from arising, rather than reacting to problems which have developed.  Company managers have a special obligation to keep informed about safety and environmental risks and regulations and to advise promptly of any adverse situation that comes to their attention. 
Facility Description 
Aerosol Systems is located at 9150 Valley View Road, Macedonia, Ohio. 
The facility is located approximately 1/8 mile northwest of the intersection of Valley View and Highland Roads. The plant occupies approximately 4.5 acres. 
Aerosol Systems, packages aerosol products used for lubricating, cleaning and coating. The facility uses mixing, dispensing, filling, gassing, capping, labeling and packaging equipme 
nt in its processes. Operations began at this facility in the early 1970's.    
The functional departments that make-up the packaging process include:  mixing, raw material storage, maintenance, filling, gas house, labeling, inspection and shipping. 
Hazardous chemicals are handled primarily by mixing room, gas house and maintenance employees. 
The plant houses the packaging lines, mixing room, drum room, shipping, receiving, and maintenance operations.  Offices occupy the front of the building on 2 floors.  A second floor above the maintenance department is used for storage.  Flammable chemicals are stored in the drum room.  Packaged, finished goods are stored for a short period in the shipping area.  The receiving area is used primarily for caps, boxes and other packaging materials.  Some non-flammable chemicals are stored in the receiving area also.  Hazardous wastes are accumulated in a designated area of the mixing room and stored in a designated area of the [email protected] drum room. 
The fro 
nt side of the building is landscaped (grassed) to the street.  A fire hydrant is located in the lawn area centrally located in front of the plant.  Across Valley View Road is a residential area. 
The south side of the plant is adjacent to a paved parking area that services a commercial building located further south.  
Two tank farms are located on the west side of the building.  One of the tank farms is located adjacent to the building near the southwest corner.  This tank farm consists of 10 compressed gas containers that hold propellants used in the packaging process. The area around the tank farm is graveled and is used for a driveway. This is the location of the worst-case release and alternative release scenarios. 
The other tank farm is located approximately 100 feet west of the building.  The gravel strip between the tank farm and the building is used as a driveway and for parking.  This tank farm consists of 16 solvent tanks and is surrounded by two poured concrete dikes that ha 
ve a capacity in excess of 110% of any given tank.  A curbed concrete pad is situated adjacent to the tank farm and provides containment for spills that may occur during tank filling operations.  A pump house, just south of the tank farm and it is used to transfer chemicals from the tanks to the plant.  The pump house is surrounded by a dike.  Piping runs from the pump house to the plant within a poured concrete trench that is covered with steel decking to allow traffic to pass over. 
The balance of the west side of the facility is a gravel drive and parking area that provides access to the drum room dock and shipping dock.  
The north side of the facility consists of a gravel driveway, parking area and provides access to the receiving docks. 
Flammables:  Worst-Case Release Scenario 
    In order to provide the maximum safety benefit from this risk management plan, Aerosol Systems conducted an offsite consequence analysis. This analysis was performed to determine the potential consequences 
of an accidental chemical release.  
   The theoretical worst-case event in the case of an accidental release would occur with the largest tank in the propellant tank farm. The scenario was chosen because it was determined that it would cause the greatest off-site consequences to the farthest endpoint. The largest tank in the propellant tank farm is tank T-26 that holds a flammable hydrocarbon gas blend of propane and n-butane.  The worst-case scenario would assume that the tank suffers a total structural failure, releasing the entire contents of the tank. An explosive vapor cloud would be formed. Using calculations provided by EPA in the RMP Offsite Consequence Analysis Guidance, May 24, 1996,  
      this vapor cloud would have a consequence distance of 0.32 miles. Public receptors effected in the radius include residences, a recreation area and major commercial, office and industrial areas. There are no environmental receptors in this area. There were no passive mitigation measures th 
at were considered in the defining of the release quantity or rate for this scenario. 
   Flammables:  Alternative Release Scenario 
While the worst-case event can happen, its probability is quite low. It is safe to assume that a more realistic, alternative release would occur. One such scenario might occur during the transfer of the flammable hydrocarbon gas blend from the tank truck to the storage tank. It is possible that the transfer hose could rupture, causing the release of the flammable gas until someone shuts off the pump on the tank truck. This alternative release scenario assumes that the tank truck driver or the Aerosol Systems tank farm attendant respond and stop the release within five minutes. Based on calculations provided in EPA Risk Management Program Guidance for Propane Storage Facilities (40 CFR Part 68), October 1998, the consequence distance for this scenario (due to an explosive vapor cloud) would be 0.1 miles. Public receptors in this radius include residences and 
major commercial, office and industrial areas.  There are no environmental receptors in this area. There were no passive mitigation measure considered in defining the release quantity or rate.  
Accidental Release Prevention Program - Level 3 
In order to help ensure the safety of Aerosol Systems' employees, its neighbors and the environment a comprehensive accidental release prevention program is in place. This plan encompasses process controls, training for employees, equipment maintenance, compliance audit procedures, incident investigation procedures, employee participation plan and a contractor safety program. Aerosol System remains committed to the prevention of accidental releases. 
1) Process controls are equipment and associated procedures used to prevent or limit releases from the facility. Aerosol Systems has numerous process controls in place to achieve maximum safety including: 
Vents - An opening for the discharge or release of pressure from tanks, vessels or processing e 
quipment. Vents are used in all areas of the process including, supply pumps,  tanks, and return lines.   
Pressure Relief Valves - a valve that relieves pressure beyond a specified limit and recloses upon return to normal operating pressure. All flammable propellant tanks are equipped with dual pressure relief valves sized in accordance with NFPA 58 Standard for Storage and Handling of Liquefied Petroleum Gases. 
Check Valves - a device for automatically limiting the flow in a piping system to a single direction in the event of an emergency. 
Manual and Automatic Shutoffs - control device to shutoff the flow to a pipe or vessel when process conditions are exceeded. 
   Alarms and Procedures - procedures to activate an alarm system. 
   Grounding Equipment - all tanks are grounded to avoid explosion. 
   Excess Flow Device - a device to protect downstream equipment from surges. 
2) General awareness training and evacuation procedures are provided for all Aerosol Systems employees. Specified employe 
es including, tank farm attendants, gashouse operators, propellant receiving personnel and maintenance personnel receive training in accordance with OSHA 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals. This training includes an overview of the process, standard operating procedures, emergency operations, preventative maintenance procedures and safe work practices. Included in this training program are tank truck unloading procedures and start-up and emergency shutoff procedures. 
3) Aerosol System has developed and implemented a computerized preventative maintenance program that routinely schedules necessary tests, inspections and required maintenance on process equipment throughout the facility. Included in this maintenance program is a daily inspection of the tank farm by maintenance personnel. Additionally, all maintenance employees are trained in the procedures applicable to their job functions to assure that they can perform their job tasks in a safe manne 
4) To verify that the procedures and practices in place are adequate and being followed, Aerosol Systems conducts a compliance audit at prescribed intervals. Where deficiencies are discovered, Aerosol Systems will take prompt corrective action to resolve all issues. 
5) Aerosol Systems has established an incident investigation team responsible for investigating actual or near-miss incidents that resulted in, or could have resulted in a catastrophic release of hazardous materials. Specific procedures and reporting forms have been developed. 
6) Aerosol Systems has prepared a written employee participation plan which also complies with OSHA 29 CFR 1910.119. The purpose of this plan is to ensure that employees are kept informed about relevant safety issues on the job. Aerosol System has involved employees from production, human resources, technical services and plant engineering in this plan. Aerosol Systems holds bi-monthly meetings of the Safety Committee. 
7) Contractor safety rules ha 
ve been developed to ensure the safety of contract employees as well as Aerosol Systems employees during the performance of all contracted work. All affected contractors are required to attend a pre-job meeting to discuss these safety rules. These rules include, safety equipment, accident reporting, hazardous chemical awareness, hot work permits, vehicle control, emergency procedures and confined space entry. 
Accident History 
Reportable accidents, as defined in reference to this rule are, a release from a covered process that involves a regulated substance held above its threshold quantity that has caused at least: on-site deaths, injuries, or significant property damage or known offsite deaths, injuries, property damage, environmental damage, evacuations or sheltering in place. This rule requires a five-year accident history to be reported. Aerosol Systems is proud that it has had no accidents in this reportable time and will strive to continue this safety record. 
Emergency Respon 
se Plan 
In accordance with OSHA Process Safety Management and EPA hazardous waste requirements, Aerosol Systems has an emergency response plan in place. 
Since Aerosol Systems employees are trained only on incidental response, further response efforts have been coordinated with local emergency responders including, local police and fire departments, county LEPC, EPA district office and local medical facilities. 
Even with these coordination procedures in place, Aerosol Systems' emergency response plan has detailed descriptions of the following: responses to an emergency, personal injury and first aid, an emergency notification list, a hierarchy of responsible personnel, emergency response equipment, emergency responders list, and an emergency evacuation plan. All employees are trained with a basic hazard awareness and evacuation procedures. Aerosol Systems also conducts routine drills with the coordination of the local fire department.  
Proposed Safety Improvements 
Aerosol Systems is  
currently investigating several options for safety improvements at the facility.  It is an ongoing goal to continually strive to achieve maximum safety protection for our employees and surrounding community. The safety improvements being discussed are: 
1) Quarantine Zone - We are planning on installing gates to insure that no traffic is allowed to enter the area when propellant tank trucks are being unloaded. This would minimize the possibility of a spark or static charge from a passing vehicle causing an explosion during the unloading process. 
2) Water Cannons - In an effort to increase safety, we are looking into installing water cannons on the exterior walls of the facility to cool the propellant tanks in the event that there was a fire in the area. This improvement would obviously limit the degree of severity in any release situation. 
3) E-Stops - are being rewired in the propellant tank farm to meet updated codes. 
4) Driveway Resurfacing - Aerosol Systems would like to cement the  
driveway area where propellant tank trucks are unloaded. The area would be designed in such a way to account for a potential hose rupture and would be able to contain up to 500 gallons of liquid propellant. 
5) Employee Safety Training Refresher Course - Our propellant supplier has offered to come to the facility and give a complete training class on the safe handling of propellants to applicable personnel. 
Aerosol Systems has a good safety record in terms of accidents and releases and will aim to keep our employees, our facility, our neighbors and the environment safe from a catastrophic event. The extensive prevention plan in place at the facility speaks to the success of our safety record. The many controls and procedures are part of the everyday routine of running the facility. In the unlikely event of a release, Aerosol Systems has prepared our employees and our outside responders on the best actions to quickly and safely mitigate the situation.  Our proposed safety ch 
anges speak to our commitment to maintain our safety record into the future.
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