Meritor Heavy Vehicle Systems, LLC - Executive Summary

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1.  The accidental release prevention and emergency response policies at your facility: 
 
The Meritor Heavy Vehicle Systems, LLC (Meritor) facility located in Oshkosh, Wisconsin complies with NFPA-58 requirements for LP-Gas storage, and it is our policy to adhere to all applicable federal, state, and local laws.  If an emergency accidental release were to occur involving our propane storage system, it is our policy to immediately notify the Oshkosh Fire Department, who would respond to the emergency. 
 
2.  A description of your facility and the regulated substances handled: 
 
The Meritor facility manufactures heavy vehicle components for the automotive industry.  We use propane as a backup fuel for plant heating only.  The propane storage process consists of three 30,000-gallon propane tanks, two pumps, one propane vaporizer, and associated piping, valves, and other miscellaneous equipment. 
 
3.  The worst-case release scenario: 
 
The worst-case release scenario for the Meritor facility con 
siders the potential failure of one 30,000-gallon storage tank filled to 88% of it's holding capacity (administrative controls limit each storage tank to 88% of capacity at 600F), resulting in a vapor cloud explosion.  Utilizing a computer-based version of the methodology presented in USEPA's "RMP Offsite Consequence Analysis Guidance", USEPA, May 24, 1996 (RMP*Comp), the distance to the flammable endpoint (1 psi overpressure) was determined to be 0.4 miles.  The public receptors affected under this worst-case release scenario include:  day care centers; schools; sports arenas; the Fox River; private residences; and, commercial, office, and/or industrial facilities.  The residential population within this 0.4-mile radius is approximately 3,812 persons, which was estimated using an Environmental Data Resources - Offsite Receptor Report. 
 
4.  The alternative release scenario: 
 
The alternative release scenario for the Meritor facility considers the potential release of propane through the 
fill pipe (i.e., caused by a rupture of the connection between the propane unloading station piping and the propane delivery tanker truck), resulting in a vapor cloud explosion.  The release rate of propane from the 2" diameter fill pipe with an initial operating flow rate of 200 gallons per minute was determined, using RMP*Comp, to be 7,120 pounds per minute.  It was assumed that the release occurred for a duration of 0.3 minutes.  Therefore, the alternative release scenario modeled a release of a total of 2,136 pounds of propane.  Utilizing RMP*Comp, the distance to the flammable endpoint was determined to be 0.06 miles.  The only affected public receptor under this alternative release scenario is the Fox River.  There is no residential population within this 0.06-mile radius. 
 
5.  The general accidental release prevention program and chemical-specific prevention steps: 
 
The Meritor facility complies with USEPA's accident prevention rule and all applicable federal, state and local c 
odes and regulations.  The propane system is designed, installed, and maintained in accordance with NFPA-58 and state law at the Meritor facility in Oshkosh, Wisconsin. 
 
6.  Five-year accident history: 
 
The Meritor facility has never had an accident involving its propane storage process.  This accident history includes no events resulting in deaths, injuries, property or environmental damage, evacuations, or shelterings in place. 
 
7.  The emergency response program: 
 
In the event of an emergency accidental release involving our propane storage system, it is Meritor's policy to immediately notify the Oshkosh Fire Department, who would respond to the emergency. Meritor has communicated this policy with the Oshkosh Fire Department. 
 
8.  Planned changes to improve safety:          NONE
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