TruServ Manufacturing - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

1.1    SOURCE 
The TruServ Manufacturing Company (TruServ) facility located in Cary,  
Illinois, is subject to the United States Environmental Protection Agencys  
(USEPAs) Risk Management Program (RMP) for Accidental Chemical Release  
regulation (40 CFR 68) because it has two independent processes that  
contain mixtures of propane (Chemical Abstract System [CAS] number 74- 
98-6) and n-butane (CAS number 106-97-8) exceeding 10,000 pounds.  The  
mixtures are used as propellant for aerosol paint cans.  The two processes  
are: (1) propellant injection into aerosol cans (the propellant process), and  
(2) finished goods warehousing. 
Propellant is a gas at ambient temperature and pressure and is stored in  
an 18,200-gallon water capacity storage tank at a pressure of  
approximately 70 to 80 pounds per square inch gauge (psig).   
Administrative controls in place at the facility, including written loading  
procedures, limit the tank fill volume to 85 percent of 
capacity, resulting in  
a maximum on-site propellant mass of 68,548 pounds.  The storage tank  
and transfer piping are located outdoors. 
Finished goods are transferred to the on-site warehouse for storage and  
distribution.  Mixtures of propellant, flammable liquids, and paint solids  
are stored in 15- to 20-ounce cans.  Approximately 250,000 pounds of  
propellant may be stored in the well-protected warehouse at any one time. 
Propellant is a flammable and potentially explosive gas.  The propellant is  
not inherently toxic. 
The TruServ propellant filling system consists of the single storage tank,  
piping from the storage tank to a small propellant fill room, and two  
aerosol can filling machines.  A pump is used to transfer the propellant  
from the storage tank into the propellant fill room.  The filling machine  
regulates the incoming pressure of the propellant and injects the  
propellant into 15- to 20-ounce aerosol cans.  The equipment and  
g piping are part of a closed system, thereby minimizing the  
potential of a large release. 
The propellant filling system is protected by specific safety systems and  
hardware which include safety relief valves, excess flow valves, and safety  
interlocks and alarms.  Safety relief valves protect the storage tank and the  
piping to the propellant filling machine.  Excess flow valves are located at  
all inlet and outlet connections to the storage tank.  The excess flow valves  
close if a larger-than-normal flow of propellant from the vessel were to  
occur.  Gas detectors and alarms within the filling room monitor the  
ambient air to ensure proper operation of the system.  Abnormally high  
concentrations of propellant within the propellant fill room will actuate  
special exhaust equipment and, if levels continue to rise, shut down the  
Once filled and packaged, cartons of aerosol cans are transferred to the  
finished goods warehouse.  In the warehouse, the cans are stored in a  
sprinklered rack system until they are shipped off site. 
Propellant filling is accomplished in a closed system.  Historical releases of  
propellant have included only small volumes infrequently released from  
the filling machine inside the propellant fill house.  While these incidents  
can impact employees, they have not historically lead to a release that  
would result in a potential off-site impact. 
Consistent with the RMP rule requirements, two specifically defined  
release scenarios, a worst-case release and an alternative release, were  
analyzed to determine the maximum distance to predetermined  
endpoints.  The release scenarios analyzed and the endpoints evaluated  
are based on the guidance contained in the USEPAs Risk Management  
Program Guidance for Propane Storage Facilities (The Propane Guidance),  
dated March 4, 1998, and the USEPAs Offsite Consequence Analysis  
Guidance (OCAG) dated April 1998. 
2.1.1    Wor 
st-Case Scenario 
The worst-case scenario assumes that a catastrophic failure of the  
propellant storage tank results in a release of the largest quantity of  
propellant stored at the facility.  Administrative controls limit this  
maximum quantity to 15,470 gallons or 65,548 pounds.  In the worst-case  
scenario, the released material is assumed to form a vapor cloud which  
comes into contact with an ignition source and detonates.  The endpoint  
for this release is defined as an overpressure of 1 psi caused by the  
explosion and is considered the threshold for potential serious injuries to  
people as a result of property damage caused by an explosion.  The  
distance to the endpoint for the worst-case scenario is 0.33 miles (1,745  
Although the worst-case consequence analysis is required by the RMP  
rule, a worst-case occurrence is considered a highly unlikely event.  The  
likelihood of a catastrophic failure of the storage tank is extremely remote  
because of the following: 
e storage tank is designed and constructed in accordance with the  
American Society of Mechanical Engineers (ASME) Boiler and Pressure  
Vessel Code (Section VIII).  The tank is operated well below its design  
pressure of 250 psig and, because of safety factors built into the ASME  
Code, significantly higher pressures would be required to cause  
catastrophic failure of the tank. 
 Access to the tank by unauthorized personnel is prevented through  
fencing and guarded entranceways.  The tanks placement separated  
from most plant activities minimizes the potential for inadvertent  
contact with plant traffic. 
 The appearance of the external surface of the storage tank is visually  
inspected on a routine basis and repairs are arranged when necessary. 
 The vessel is designed, installed, operated, and maintained in  
accordance with National Fire Protection Association (NFPA) Liquefied  
Petroleum Gas Code (NFPA 58). 
 The vessel is protected from overpressure through the installation of  
two safety relief valves (SRVs). 
 The propellant is non-corrosive. 
2.1.2    Alternative-Release Scenario 
USEPA specifies that an alternative-release scenario be evaluated that is  
more likely to occur than the worst-case scenario and is significant  
enough to impact off-site areas (i.e., the endpoint must be located beyond  
the facility boundary). 
Because the TruServ facility has not experienced a propellant release to  
use as a model alternative scenario, the scenarios discussed in the  
USEPAs OCAG and Propane Guidance documents were considered the  
most appropriate for analysis.  The release scenario chosen assumes that  
the two safety relief valves lift for a 5-minute period.  The resulting vapor  
cloud is assumed to contact an ignition source and a vapor cloud fire  
results.  No active  or passive  mitigation is assumed for this scenario.  The  
endpoint for this release, the lower flammability limit (LFL), is considered  
to provide a reasonable, but not overly conservative, es 
timation of the  
possible extent of a vapor cloud fire.  The LFL for the propellant is 1.8  
percent.  The distance to the endpoint for the alternative-release scenario is  
0.10 miles (528 feet). 
Although an alternative-case release consequence analysis is required by  
the RMP rule, a release that is large enough to reach an endpoint beyond  
the facility boundary is not likely to occur.  The facility has never  
experienced an SRV release resulting from vessel overfilling.   
Additionally, the facility has a training course for propellant system  
operators that includes the vessel filling task, requires its operators to  
regularly monitor the level gauge during filling operations, and requires  
operators to remain present during all offloading operations.  Also,  
propellant vapor that is released may disperse without harmful effects. 
2.2.1    Worst-Case Scenario 
Consistent with the RMP rule requirements, a worst-case release from the  
largest single container w 
as analyzed to assess the maximum distance to a  
flammable endpoint.  The release scenarios analyzed and the endpoints  
evaluated are based on the guidance contained in the USEPAs Propane  
Guidance and the OCAG. 
The worst-case scenario assumes that failure of the largest single  
container, a 20-ounce aerosol can, results in a release of propellant and  
flammable liquid vapor.  The released material is assumed to form a vapor  
cloud which comes into contact with an ignition source and detonates.   
The endpoint for this release is defined as an overpressure of 1 pound per  
square inch caused by the explosion and is considered the threshold for  
potential serious injuries to people as a result of property damage caused  
by an explosion.  Based on the contents of a 20-ounce aerosol can, the  
distance to the endpoint for a worst-case release is 35.3 feet (0.007 miles),  
which is contained within the building.  No public receptors are located  
within the endpoint distance.   
3.0    ACCIDENT H 
There have been no accidental releases of propellant at the TruServ Cary  
facility in the last 5 years that have resulted in death, injury, or significant  
property damage on site or off-site death, injury, property damage,  
evacuation , sheltering in place, or environmental damage site. 
TruServe has carefully considered the potential for accidental releases of  
propellant, such as the aforementioned occurrences of the worst-case and  
alternative-release scenarios.  To help minimize the probability and  
severity of a propellant release, a prevention program that satisfies the  
Occupational Safety and Health Administration (OSHA) Process Safety  
Management (PSM) of Highly Hazardous Chemicals standard  
(29 CFR 1910.119) has been implemented at the Cary, Illinois, facility.  The  
major objective of this prevention program is to implement a management  
system that prevents releases of propellant, especially in situations that  
could expo 
se employees and others to serious hazards.  The program  
employs a systematic approach to evaluating the whole process including  
process design, process technology, process changes, operational and  
maintenance activities and procedures, non-routine activities and  
procedures, emergency preparedness and procedures, training programs,  
and other interrelated elements that effect the propellant system. 
The key components of the prevention program are summarized below: 
 Process safety information regarding the propellant system has been  
developed, documented, and made available to facility operators.  This  
information is used to fully understand and safely operate the  
propellant system. 
    The performance of a formal process hazard analysis (PHA) on the  
propellant system using the What-if... technique.  A team with  
expertise in engineering, operations, maintenance, and safety  
evaluates the existing system in depth and developed  
recommendations to improve the safety and opera 
bility of the  
propellant system.  The PHA addresses: (1) process hazards;  
(2) previous incidents; (3) engineering and administrative controls  
applicable to the hazards; (4) the consequence of control failure;  
(5) facility siting; (6) human factors; and (7) a qualitative evaluation of  
possible safety and health effects of control system failures.  The PHA  
resulted in multiple procedural and/or hardware recommendations  
to improve the safety and operation of the propellant system.   
TruServe has resolved all of the PHA recommendations.  The PHA  
will be updated and revalidated every 5 years. 
    Written standard operating procedures (SOPs) are used to provide the  
basis for proper and safe operation of the propellant system.  The  
SOPs include procedures for normal operation, startup, shutdown,  
emergency operation, and emergency shutdown. 
    Formal authorization systems are in place to ensure that system  
changes or expansions are as safe as the original design, and that an  
ndent recheck confirms that the changes are consistent with the  
engineering design and can be safely operated prior to startup. 
    Operators and mechanics working in the propellant fill building or  
who are responsible for unloading propellant from tank cars receive  
training on the process hazards, process safety information, SOPs and  
emergency response actions related to the propellant system.  The  
training program ensures that the operators understand the nature  
and causes of problems arising from system operations and serves to  
increase awareness of the hazards particular to the propellant system. 
    A mechanical integrity program has been implemented and includes:   
(1) routine system inspections to identify unusual or increasing  
vibration, incipient leaks, or other indications of potential upsets or  
failures; (2) replacement or testing of pressure relief valves on the  
storage tank every 10 years; and (3) periodic testing of gauges,  
monitoring devices, and safety interloc 
    Prior to the performance of any hot work (i.e., spark or flame  
producing operations such as welding, cutting, brazing, grinding), the  
work must be approved by executing a written hot work permit to  
verify precautions have been implemented to prevent fire. 
    Contractors that are hired to work on, or adjacent to, the propellant  
system are pre-qualified based on their knowledge of propellant  
systems and their demonstrated ability to work safely. 
    All incidents that cause or might have caused an accidental or  
unexpected release of propellant are subject to a formal investigation. 
    A compliance audit of the prevention program is completed every  
3 years to verify that the appropriate management systems are in  
place and are being properly implemented. 
    The prevention program includes an extensive employee participation  
program involving TruServ employees from all levels of the  
organization and from all areas within the plant (i.e., production and  
maintenance).  This 
program considers that employees who work on  
the propellant system are the most knowledgeable about it and are  
best able to easily, effectively, and regularly recommend changes or  
improvements which enhance safety. 
Although a formal, documented prevention program is not required by  
the RMP rule for Program 1 processes, a number of design and operational  
controls are in place to decrease the severity or prevent the occurrence of a  
fire or explosion.  The most significant controls are described below. 
    The warehouse is designed as an aerosol storage area per the NFPA  
Manufacture and Storage of Aerosol Products (NFPA 30B). 
    The rack storage system is designed for flammable materials storage  
per the NFPA Code for the Rack Storage of Material (NFPA 231C). 
    Potential sources of ignition are restricted from the warehouse. 
     The warehouse and rack system are fully sprinklered. 
The TruServ, Cary facility has imple 
mented a detailed written Emergency  
Action Plan (EAP).  The EAP is intended to address all emergencies at the  
facility, including incidents related to a release of propellant. 
The EAP includes awareness and response training for plant employees,  
coordination with the local fire department, and evacuation of personnel  
in the facility.  The EAP identifies specific individuals and their  
responsibilities, and identifies procedures for emergency medical care. 
In accordance with 40 CFR 68.185, I hereby certify that the information  
and Risk Management Plan for anhydrous ammonia, contained herein, is  
to the best of my knowledge, information, and belief formed after  
reasonable inquiry, true, accurate, and complete. 
                   Robert E. Simmons 
                   Vice President of Manufacturing 
     Active mitigation means equipment, devices, or technologies that require hu 
mechanical, or other energy input to function.  Active mitigation for compressed  
gases may include automatic shut-off valves, rapid transfer systems, and scrubbers. 
     Passive mitigation means equipment, devices, and technologies that function without  
human, mechanical, or other energy input.  Examples include enclosures  
(e.g., buildings) for compressed gases and secondary containment dikes for liquids. 
     Please note that the USEPAs RMP*Submit software, version 1.0.7, does not allow  
entry of such a small release amount and endpoint distance.  The release amount in  
the data elements section of RMP*Submit is, therefore, reported as 1 pound and the  
endpoint distance as 0.01 miles.
Click to return to beginning