Kleerdex Company - Executive Summary

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General Executive Summary for Propane Storage Facilities 
1. Accidental Release Prevention and Emergency Response Policies 
The primary function of Kleerdex Company is to act as a plastic sheet manufacturing facility.  By virtue of the flammable effects associated with propane, it is necessary to observe certain safety precautions in handling propane to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as the health of our co-workers, and to reduce the threat to nearby members of the community.  We are strongly committed to employee, public and environmental safety.  Safety at our facility depends upon the manner in which we handle propane as well as on the various safety devices incorporated into the design of our equipment.  Furthermore, comprehensive training received by our employees adds to the inherent safety of our facility. 
Our emergency response program is based upon the NPGA's LP-Gas Safety Handbook.  In addition to the presence of ap 
propriate controls to prevent possible releases of propane, if a release does occur, we are completely coordinated with Columbia County Emergency Services, which provides highly trained emergency response personnel to control and mitigate the effects of the release. 
2. The Stationary Source and the Regulated Substances Handled 
The primary purpose of this facility is to provide propane for space heating fuel, with a secondary use of refilling forklift fuel cylinders.  Propane arrives at our facility via truck and is stored in one storage tank.  This facility has equipment for unloading trucks and equipment to fill portable cylinders.  Access to this site is restricted to authorized facility employees, authorized management personnel and authorized contractors.  
The regulated substance handled at this facility is propane.  The maximum amount of propane that can be stored at this plant is 110,000 lb. 
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), Includi 
ng Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario 
We have calculated worst case release scenarios based on the NPGA approved TNO-Multi energy method.  For alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for propane involves a catastrophic release from Bulk Propane Storage.  The scenario involves the release of 110,000 lb. of propane. It is assumed that the entire quantity is released as a vapor that finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion.  Under worst case weather, the maximum distance of 0.32 miles was obtained corresponding to a flammable endpoint of 1 psi overpressure.   
The alternative release scenario submitted for Program 2 and 3 flammable subs 
tances involves a release from Bulk Propane Storage resulting in a Vapor Cloud Fire.  In this scenario 66,000 lb. of propane is released in 10 minutes.  The release is also controlled by active mitigation measures that include excess flow valve(s).  Under neutral weather conditions, the maximum distance to the flammable endpoint of Lower flammability limit of 2.3% is 0.12 miles. 
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.  This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition.  
The following sections briefly describe the release prevention program that is in place at our stationary source. 
Safety Information 
Kleerdex Company maintains a detailed record of written safety information, which describes the chemical hazards, operating parameters and e 
quipment designs associated with all aspects of our distribution facility.   
Hazard Review 
A checklist methodology is used to carry out hazard reviews at our facility. The reviews focus on operating procedures, equipment functions and handling practices to identify possible hazards.  The studies are undertaken by a team of qualified personnel with extensive knowledge of facility operations and are revalidated at a regular interval of 3 years.  Any findings related to the hazard reviews are addressed in a safe and timely manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Kleerdex Company maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved with the pr 
Kleerdex Company has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes.  New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently.  Refresher training is provided at least every year and more frequently as needed.   
Kleerdex Company carries out documented maintenance checks on process equipment to ensure proper functioning.  Maintenance activities are carried out by qualified personnel with previous training in these practices.  Furthermore, personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Compliance Audits 
Kleerdex Company conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are  
being implemented.  These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.   
Incident Investigation 
Kleerdex Company promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of propane. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from recurring.  All reports are retained for a minimum of 5 years. 
5. Five-year Accident History 
Kleerdex Company has had an excellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, there has been no accidental release during this period.   
6. Emergency Response Plan 
Kleerdex Company carries a written emergency response plan to deal with accidental releases of propane.  The plan includes all aspects of emergency response including adequat 
e first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
Our facility's emergency response plan is based upon the NPGA's LP-Gas Handbook. 
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced.  In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.          
7. Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program.    Installation of break-away shutoffs and installation of bollards at the truck unloading station are some of the major steps we want to take to improve safety at our facility.  These changes shall be implemented by 12/31/99. 
8. Certification Statement 
The undersigned certifies that to the b 
est of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
Name: Victor Klein 
Title: Vice President of Manufacturing 
Date signed: 06/17/99
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