Hydrosol, Inc. - Executive Summary |
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DESCRIPTION OF FACILITY Hydrosol, Inc. is a custom packager specializing in aerosol consumer, industrial, institutional, and commercial products. Included in these types of products are items such as spray paints, automobile maintenance products, household products, and industrial and institutional products. The overall production process is a highly integrated operation involving management of incoming chemical and non-chemical raw materials; compounding, blending, mixing and storage of the chemical raw materials into packageable forms; packaging of these compounded materials into aerosol containers; and the temporary accumulation of these packages in warehousing areas prior to shipment. Our physical plant site consists of two buildings located on approximately 8.5 acres. The main building, located centrally within the property, contains office, laboratory, warehousing, production, maintenance, and shipping and receiving areas. The other building, designated Building 6, contains laboratory, warehousing, production, and shipping and receiving areas. The plant site also has a propellant storage tank farm that contains 20 tanks; three underground storage tank fields containing 45 tanks; one aboveground storage tank area containing one tank; two tank truck off-loading areas; and a propellant off-loading area. It is the propellant storage tank farm and the related process of packaging aerosol cans that is the subject of this Risk Management Plan. The tanks in the propellant storage tank farm range in size from 1,840 gallons to 30,000 gallons. The total capacity of these tanks is 189,000 gallons, but our internal operating guidelines limits the maximum amount to 170,000 gallons. The materials stored are propane, butane, various blends of these two materials, difluoroethane, and normal pentane. Only propane and butane are stored in the 30,000 gallon tanks; all blends and the other two propellants are stored in smaller tanks. APPROACH TO SAFETY At Hydrosol, w e are committed to performing all operations, both chemical and non-chemical, in ways that are as safe as possible. We know that many of the raw materials we use are hazardous and that proper operating procedures and employee training programs will minimize the risks associated with those hazards. We have established many operating procedures and have enacted employee safety training programs, both on our own and in conjunction with the requirements of the OSHA Process Safety Management regulations, as well as applicable state codes and regulations, that are designed to prevent system failures that could endanger our employees and the community. We maintain an open dialogue with the local fire departments, in addition to an open door policy, that encourages cooperation and guidance. To prevent unintended access by third parties, we do restrict access to the facility to employees, authorized contractors and authorized visitors. WORST CASE RELEASE SCENARIO We used the RMP Comp and the RMP Guidance for Propane Storage Facilities in analyzing this scenario. This analysis assumes that the entire contents of our largest tank is released, a vapor cloud forms (with all the mass of the tank within the flammable range), and a detonation occurs. The analysis incorporates a 10 percent yield factor for TNT-equivalency models. The distance to endpoint is defined as the distance over which a minimum pressure of one (1) pound per square inch (psi) occurs from the pressure wave formed by the detonation. Our largest tank has a maximum capacity of 30,000 gallons but our administrative controls, as well as the RMP Guidance for Propane Storage Facilities, limits the amount of propane in storage in this tank to 26,400 gallons (114000 pounds). Based on the calculations in RMP Comp, the distance to endpoint is 0.4 miles. The population within the area is estimated to be 2600. Also located within the circle are commercial, office, and industrial areas and one recreational park; n o environmental receptors are present. ALTERNATIVE RELEASE SCENARIO We have determined that an event more likely to occur would be a vapor cloud fire that was the result of a piping break-away. This could occur either during delivery of materials or as a result of an in-plant impact. If this were to occur, minimum amounts of propane would be released because the excess flow valves would close, thereby limiting the amount to 3830 pounds. In the event of a fire, the deluge system would be automatically activated. This would further reduce the amount of material that would be involved. For this scenario, the RMP Comp calculations give the distance to end point as 0.08 mile. The population within the area is estimated to be 22. Also located within the circle are commercial, office, and industrial areas; no environmental receptors are present. ACCIDENTAL RELEASE PREVENTION PROGRAM As described earlier, we are committed to operating our plant safely. In order to acomplish this , we have reviewed all standard operating procedures, including those required by OSHA's Process Safety Management regulations, as well as those that we developed in order to maintain our operation. We train our employees in those procedures that they are expected to follow in performing their duties and provide review training at appropriate intervals. We installed and maintain automatic devices designed to prevent and respond to the release of the materials involved in our operation. FIVE YEAR ACCIDENT HISTORY On June 29, 1995, a fire occurred in one of our propellant filling areas. It was immediately extinguished by our automatic fire suppression system. The fire apparently was caused by a spark that ignited propellant that was released from a damaged aerosol can. We determined that the spark was the result of a static charge build-up that was caused by the particular product contained in the discharging can. Four employees sustained minor injuries; physical damage was mino r. Operations continued the next day after cleanup of the affected area. All safety measures were reviewed and appropriate changes were made. The incident did not involve the propellant storage area. There were no off-site consequences. On May 17, 1999, a fire occurred in one of our batch mixing tanks. It was immediately extinguished by our automatic fire suppression system. The fire was caused by an unknown ignition source that ignited solvent vapors that occupied the vapor headspace of the mixing tank. No employees were injured; physical damage was minor. Except for the mixing tank involved in the incident, operations continued the next day after cleanup of the affected area. All safety measures were initially reviewed and no changes were made. Work practices involving the affected tank are still under review as is the investigation into the cause of the ignition. The incident did not involve the propellant storage area. There were no off-site consequences. EMERGENCY R ESPONSE PROGRAM Our emergency response plan is written in order to comply with OSHA requirement as well as those of other applicable standards. Situations covered by our plan include fires, tornadoes, hazardous materials incidents, and personal injuries. Actions to be taken in these situations include initial fire fighting measures, evacuations, hazardous materials containment procedures, and appropriate first-aid measures. All employees are trained in the proper methods of plant evacuation in the event of a fire. Members of the safety team receive additional training in order to assist in plant response emergencies so that efficient plant evacuations can be effected and that equipment can be secured in apppropriate manners until professional help arrives. Some safety team members, as first responders, also receive portable fire extinguisher training. All fire alarms, whether remotely sensed or manually activated, are automatically transmitted to the local fire department for r esponse. This department is involved in routine inspections of our facility and also in awareness training of other local fire departments at our plant. PLANNED CHANGES TO IMPROVE SAFETY Because of the extensive investigations required prior to the submission of this Plan and any changes that were made as a result of those investigations, no changes are presently planned regarding methods and practices to improve safety. However, if we become aware of a situation that provides for additional operational safety and it requires changes to our overall operating plan, we will not hesitate to evaluate the proposal and make whatever changes that are necessary. |