Chase Products Co. - Executive Summary |
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Chase Products Company (CPC) is committed to worker and public safety in the operation of our facility. This commitment to safety is demonstrated by the resources invested in accident prevention, such as personnel training programs and engineering and administrative controls in our process. CPC utilizes the elements of a process safety management (PSM) program to ensure that our propellant storage system is operated in the safest manner achievable. CPC manufactures an extensive list of aerosol type products. Some examples of these products include personal hygiene (i.e., spray deodorants, hair spray, etc.) and residential use (i.e., glass cleaner, insecticides, and spray paints). CPC uses an aerosol propellant storage system to contain their A31(100% isobutane); A46 (85% isobutane/15% propane); and A80 (60% propane/40%n-butane) gases which are used as the primary propellants in their aerosol products. The system consists of three on-site USTs each having a maximum storage capacity of 18,000 gallons and one 30,000-gallon railcar. The USTs and railcar are connected to a series of pumps and conveyance pipes, which ultimately transfer the propellants to 16-ounce product cans. Because CPC's aerosol propellant storage system is subject to OSHA PSM standards, the system falls under Program 3 requirements according to EPA's Risk Management Program. No additional RMP processes were identified at the site. The worst-case scenario includes the accidental release of all the aerosol propellant contained within the three USTs and the railcar. The release and subsequent vapor cloud explosion of 379,400 pounds of the propellant mixture is caused by a propellant tanker accidentally backing into the aboveground propellant piping system in the area of the USTs and railcar. The shearing of valves and pipes results in an initial release of propellant from the USTs, which explosively ignites and consequently ruptures and ignites the propellant stored within the railcar. Altho ugh CPC utilizes numerous administrative and active mitigation systems to minimize the consequences of such a release, no credit was taken for any mitigating factors in calculating the extent of the release. This is in accordance with EPA requirements in calculating the effects of a worst-case release. The estimated distance to 1.0 psi overpressure is 0.6 miles, and a residential population of 3,540 would potentially be impacted. The flammable endpoint distance was calculated using USEPA's RMP.COMP program. The population figure was obtained using the US Census Bureau MABLE/GEOCORE V2.5 Geographic Correspondence Engine. The alternative release scenario for the aerosol propellant consists of a vapor cloud leak created by the failure of packing material located around a control system valve stem located over the UST containing 84,400 lbs of 100% isobutane at 65 degrees Fahrenheit and 102 psia. Although unlikely to occur, this release scenario is more likely to occur than the worst -case release scenario described above. The packing failure would release isobutane at a rate of 400 lbs/hr over a period of 12 hours. The leak scenario is based upon the reasonable assumption that a valve packing failure would create an orifice area equal to 0.049 square inches. Calculating the estimated release rate using equation 7-1, provided in Chapter Seven of the USEPA's RMP Guidance on Offsite Consequence Analysis, approximately 4,800 lbs of isobutane are released over 12 hours. The estimated quantity of isobutane flashed into vapor is 2,200 lbs and is calculated utilizing equation 10-2 of the RMP Offsite Consequence Guide. The estimated distance to 1.0 psi overpressure is 0.067 miles or 353 ft, and a residential population of approximately 100 would potentially be impacted. The flammable endpoint distance was calculated using USEPA's RMP.COMP program. The population figure was obtained using the US Census Bureau MABLE/GEOCORE V2.5 Geographic Correspondence Engine. T he process at the facility that is regulated by the RMP is also regulated by OSHA's PSM standard. CPC's PSM program includes detailed process safety information. CPC conducts process hazards analyses to identify hazards and ensure that adequate controls are in place to manage the hazards. Operations at the facility are conducted according to standard operating procedures, and employees are trained on the procedures. CPC ensures mechanical integrity of its propellant storage system by conducting routine daily inspections and promptly correcting identified deficiencies. CPC's flammable substance release prevention programs include temperature sensors and pressure gauges located along the piping network to the USTs containing the flammable propellants. In addition, flammable gas release detection sensors are located in the union pump area adjacent to the UST system. The sensors will activate an alarm light inside the operations building when the gas concentration reaches 20% of the lower explosive limit (LEL) in the union pump area. At 40% of the LEL, an audio alarm sounds and complete pump shutdown is initiated. The flammable gas detection sensors are currently not located in the area of the USTs and railcar. CPC had no accidental releases of flammable gases in the past five years that resulted in onsite or offsite injuries or deaths, onsite property damage, or offsite environmental damage. CPC maintains a written emergency response contingency plan that satisfies the requirements for contingency planning and/or notification procedures under the Illinois Toxic Substances Disclosure to Employees Act, OSHA Hazard Communication Rule, and Illinois Chemical Safety Act. The plan's purpose is to establish emergency and notification procedures to be followed in the event of chemical, environmental, or other emergencies. Personnel are trained as emergency coordinators and responders, and CPC conducts tabletop and hands-on emergency response drills annually. In ad dition, the plan is reviewed at least annually and is amended as necessary. Some of the response actions are coordinated with the Broadview Fire Department and the La Grange Park Fire Department. Planned changes to improve safety at the facility include continued training of employees on the emergency response contingency plan. |