Chase Products Co. - Executive Summary |
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Chase Products Co. 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, including forklift training. Chase Products Co. maintains a material safety data sheet (MSDS) listing in the warehouse for use by facility employees. Annual fire safety inspections are performed by the La Grange Park Fire Company. In addition, Chase Products Co. coordinates emergency response measures with the La Grange Park Fire Company. Chase Products Co. also utilizes Verlan Fire Insurance Company to perform annual inspections of the warehouse facility. Chase Products Co. 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). The aerosol cans are stored within Chase Products Co.'s finished goods warehouse. The warehouse is used only for finished product storage. No manufacturing or processing is conducted at the warehouse. The maximum number of finished aerosol products stored within the warehouse at any one time is 3,182,000 16-ounce cans. The average net weight of these finished aerosol products is 12.25 oz/can and the average amount of propellant in each can is 20%. The total amount of propellant stored within the warehouse is 487,200 lbs. Solvent-based aerosol paint products, meeting an NFPA-4 rating, comprise approximately 34% of the total inventory. The remaining 66% of the inventory is comprised of water-based aerosol products that do not meet the NFPA-4 flammability rating. Chase Products Co.'s finished goods warehouse is not subject to OSHA PSM standards; however, the warehouse operations fall under Program 2 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 a ll the aerosol propellant contained within the warehouse, based upon a catastrophic natural gas explosion. However, as outlined in Chapter 1 of the USEPA's Consequence Guidance Manual, only the solvent-based products meeting the NFPA-4 criteria for flammability are to be considered in the threshold quantity determination. As a result, out of the 487,200 lbs of total propellant, 34% or 165,600 lbs are considered in the worst-case scenario. Although CPC utilizes administrative and active mitigation systems (i.e., Early Suppression Fast Response (ESFR) fire sprinkler system) 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 0.4 miles, and a residential population of 2,450 would potentially be impacted. The flammable endpoint distance was calculated usi ng 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 meeting the NFPA 4 rating consists of a vapor cloud release and subsequent explosion resulting from the release of 230 lbs of A80 propellant (60% propane/40% n-butane) which is primarily used in the spray paint aerosol cans. Although unlikely to occur, this release scenario is more likely to occur than the worst-case release scenario described above. Twelve 16-ounce (12.25 oz net) cans are stored in one case and there are 126 cases per pallet. The pallets are stacked four high within the warehouse. This scenario assumes that the top pallet accidentally falls to the concrete floor compromising the integrity of the cans. Chapter 10 of the USEPA's Consequence Guidance Document states in Section 10.4 under "Vapor Cloud Explosion" that the worst case modeling may be used to calculate the alternative release scenario to determine the distance to an overpressure of 1 PSI. The estimated distance to 1.0 psi overpressure is 0.05 miles or 264 ft, and there would be no residential population impacted by the explosion. Passive mitigation measures including the warehouse structure, fire walls, blast walls, and active mitigation ESFR sprinkler system should effectively control the magnitude of the explosion, reducing the potential for additional fires and/or explosions within the warehouse. 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. Chase Products Co. 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. Chase Products Co. 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 Chase Products Co. conducts tabletop and hands-on emergency response drills annually. In addition, 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. |