Triclad, Inc. - Executive Summary

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INTRODUCTION--  Fasse Paint Company, Inc. is the parent company of Triclad, Inc. and holder of the EPA Systems Facility Identifier number WID982063968.  Fasse Paint is an industrial paint blending facility specializing in color matching, small batch mixing, custom packaging and warehouse/shipping programs.  This Company does not manufacture coatings, but instead mixes and blends to customer specifications.   Triclad, Inc. is the paint and propane blending operation producing aerosol paint cans from materials mixed at Fasse Paint Company.  This operation relies on a significant source of propellant maintained on site.  The same properties that make the propane blend valuable a a propellant also make it necessary to strictly  observe  safety precautions.  Specific details of the blend are discussed in Section 2 below, The Stationary Source and Regulated Substance Handled.   Propellant must be handled to prevent unnecessary human exposure,  to reduce the threat to our own personal health  
as well as our co-workers,  and to reduce the threat to nearby members of the community.  It is our policy to adhere to all applicable Federal and State rules and regulations.  Safety depends upon the manner in which we handle propellant,  the safety devices inherent in the design of this facility, and thorough training of employees.  Due to it's success, Triclad Inc. is moving into it's new facility at the time of this submission.  Design concepts and plans  developed by Fasse Paint Company and the certified and registered propane installation contractor were preapproved by stated and local officials prior to construction.  The facility was inspected prior to operation so that it complies with Chapter Comm 11, Wisconsin Administrative Code and NFPA-58.   
 
 
1.  Accidental Release Prevention and Emergency Response Policies: 
 
The emergency response program is based upon the NPGA's LP-Gas Safety Handbook, "Guidelines for Developing Plant Emergency Procedures" and "How to Control LP-Gas Le 
aks and Fires".  With the need for expansion, Triclad, Inc. has moved to a new location with startup in June, 1999.  A new propane blend storage and delivery system was constructed by a leader in the propane blend storage tank field.  Inspection and review was completed by District and Section Inspectors with the Wisconsin Department of Commerce, Safety and Buildings Division-Gas Systems.  Every effort was made in the original plan to anticipate and prevent accidental release and incorporate any equipment necessary to achieve that goal.   
 
The Emergency Response Plan developed for OSHA compliance contains the following elements:  1) Personnel roles, lines of authority, and communication procedures; 2) Pre-emergency planning; 3) Emergency recognition and prevention; 4) Emergency medical and first-aid treatment; 5) Methods or procedures for alerting onsite employees,; 6) Safe distance and places of refuge; 7) Site security and control; 8) Evacuation routes and procedures; 9) Decontaminat 
ion procedures; 10) Critique of response and follow-up, and; 11) Personal protective and emergency equipment. 
 
 
2.  The Stationary Source and Regulated Substance Handled. 
 
The purpose of this facility is to produce aerosol paint cans.   Propane under the product name Liquified Petroleum Gas Blend and trade name A-80 Aerosol Grade Propellant is used in our aerosol operation to provide propellant in the spray cans.   Maximum amount of propellant stored on site is 53,040 pounds with the tank filled to 90% maximum capacity.  The composition of the blend is 58.8 propane (31,188 lbs.),  40.2 Isobutane (21,322 lbs.), .9 normal butane (477 lbs.), and .1 ethane (53 lbs).  The propellant is received by truck transport and stored in a single 12,000 gallon tank.  Fences and safety yellow concrete posts protect the tanks from collision with vehicles.  Valves on the tank are regularly inspected and protected from weather.  Propane is pumped from the storage tanks to the propellant room as a liquid u 
sing a vane pump.  Pipes transporting the propellant to the injection room are insulated to protect it from varying weather conditions and the effect it may have on the stability of the propane.  Vegetation is controlled to be sure that the pipes remain visible and in good repair.  The propellant room is a separate, explosion proof structure located adjacent to the main facility.  It is constructed of three fire walls and a relief wall.  A check valve in the propellant room prevents fire from traveling back to the propane tank.  An air line bleeds remaining propane in the lines to a vent in the roof.   As the propane is injected into the aerosol can in liquid form, it converts to gas to fill the vacuum in the can.   In the rare event that a can should fail as the propane is expanding, the contents would be released in the safety and protection of the concrete walls of the propellant room where ignition sources are minimal, limited to mechanical operation and closely monitored.  A relea 
se of propane in the propellant room is detected by sensors.  These sensors trigger an alarm in the aerosol department, shut down production, and immediately start two-heavy duty exhaust fans on the relief wall of the propellant room. Any release or concentration of propane is immediately dissipated.  Readings on the alarm system indicate the status of the leak to personnel so that appropriate emergency action can be taken.  A propane release in the propellant room is a rare occurance of approximately one in 900,000 cans.  After the aerosol can successfully completes the propane injection process, it is moved back into the main facility on a conveyer and submersed in a 130 degree water bath.  This process has a two-fold purpose.  Along with testing for quality assurance,  it provides a safe cusion for propane release should the quality assurance test fail.  If a leak occurs in the seal of the aerosol can, the propellant in the can converts from liquid to gas and vaporizes under water.  
As a vapor, it rises to the surface and evaporates into the air.  A plexiglass cover protects employees in the area and contains propane emisions.  Emergency response policies are outlined the Company Emergency Response Plan.  Employees are fully trained on the guidelines of this plan. 
 
 
3.  Worst Case Scenario and the Alternative Release Scenario Including Administrative Controls and Mitigation Measures to Limit the Distance For Each Reported Scenario. 
 
Worst case scenario is vapor cloud explosion, and alternative release is vapor cloud fire.  For these two events, passive and active mitigations are similar.  In the development of this new propane storage tank and delivery system, considerable attention was given to protecting the surrounding industrial sites and adjacent mobile home park.  For that reason, the tank was located as far from the residential area as feasible.  The design includes a system of emergency shutoff, back pressure, and pop action pressure relief valves for lar 
ge storage containers.  Design and construction of the storage tank, delivery pipeline, injection room, packaging equipment and conveyors, and site security were done by leaders in the propane field.  The tank is protected by cement posts, fencing and guard rails.   Active mitigation is the emergency shutdown systems, a deluge system, and a water curtain established between the storage tank and the mobile home park. 
 
 
4.  The General Accidental Release Prevention Program and the Specific Prevention Steps. 
 
This facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations.  This facility was designed and constructed in accordance with NFPA-58.  Specific prevention steps are discussed in the above section on mitigation. 
 
 
5.  Five-year Accident History 
 
This new storage tank and delivery system is scheduled for start up in late June, 1999.  However, it should be noted that through the efforts of management and employees, this company 
has not had a propane or chemical accident on the current site since the business was established.  
 
 
6.  The Emergency Response Plan 
 
This facility's Emergency Response Plan is based upon the NPGA's LP-Gas Handbook, "Guidelines for Developing Plant Emergency Response Procedures" and "How to Control LP-Gas Leaks and Fires".   This information is combined with OSHA suggested procedure.  Employees are trained on all aspects of emergency response and that training is documented in the Health and Safety Files located in the Industrial Division office.  We have discussed this program with the Sheboygan County Local Emergency Planning Committee and the Sheboygan Falls Fire Department.  A representative of the Sheboygan Falls Fire Department visited the previous propane site on June 22, 1998 and again on the new site in June, 1999 for inspection certification. 
 
 
7.  Planned Changes to Improve Safety 
 
As a result of thorough research and planning, Triclad, Inc. has constructed a state of the  
art storage and delivery system.  Improved  safety changes will be evaluated and completed in conjunction with NFPA-58 revised editions.  The clean five-year plus accident history is proof that Triclad, Inc. is committed to a proactive safety policy.
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