Follmer Development Inc. - Executive Summary

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General Executive Summary for Manufacturing Facilities 
 
1.    Accidental Release Prevention and Emergency Response Policies 
 
We at Follmer Development Inc. are strongly committed to employee, public and environmental  
safety.  This commitment is demonstrated by our comprehensive accidental release prevention  
program that covers areas such as design, installation, operating procedures, maintenance, and  
employee training associated with the processes at our facility.  It is our policy to implement  
appropriate controls to prevent possible releases of regulated substances. 
 
 
2.    The Stationary Source and the Regulated Substances Handled 
 
Our facility's primary activities encompass this facilities primary activity is the filling of aerosol  
products.  We have 2 regulated substances present at our facility.  These substances include  
Isobutane  [Propane, 2-methyl] and Propane.  Isobutane  [Propane, 2-methyl] is used for a  
propellant for aerosol products.  Propane is used for a propellant for 
aerosol products. 
 
The maximum inventory of Isobutane  [Propane, 2-methyl] that is expected to be present in this  
facility based on process/operational  requirements 10747.80 lb. while Propane is expected to be  
present at our facility in a maximum quantity of 7972.20 lb.. 
 
3.    The Worst Case Release Scenario(s) and the Alternative Release  
Scenario(s), including administrative controls and mitigation measures to  
limit the distances for each reported scenario 
 
To perform the required offsite consequence analysis for our facility, we have used the EPA's  
OCA Guidance Reference Tables or Equations.  The following paragraphs provide details of the  
chosen scenarios. 
 
The worst case release scenario submitted for Program 2 and 3 flammable substances as a class  
involves a catastrophic release from A70/A55.  In this scenario, 18000 lb. of Flammable  
Mixture: Propane, Isobutane  [Propane, 2-methyl] is released. It is assumed that the entire  
quantity is released as a vapor, which finds an  
ignition source, with 10 percent of the released  
quantity participating in a vapor cloud explosion.  Under worst case weather conditions, the  
calculated distance of 0.21 miles is obtained corresponding to an endpoint of 1 psi overpressure. 
 
One alternative release scenario submitted for Program 2 and 3 flammable substances involves a  
release from A70/A55.  The release is assumed to result in a Vapor Cloud Explosion.  The  
scenario involves the release of 18000 lb. of Flammable Mixture: Propane, Isobutane  [Propane,  
2-methyl] in 10 minutes.  Under neutral weather conditions, the maximum distance to the  
flammable endpoint of 1 psi overpressure is 0.13 miles. 
 
Another alternative release scenario submitted for Program 2 and 3 flammable substances  
involves a release from Warehouse.  The release is assumed to result in a Vapor Cloud  
Explosion.  The scenario involves the release of 720 lb. of Flammable Mixture: Propane,  
Isobutane  [Propane, 2-methyl] in 10 minutes. The release is als 
o controlled by active mitigation  
measures that include sprinkler system(s).  Under neutral weather conditions, the maximum  
distance to the flammable endpoint of 1 psi overpressure is 0.04 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 elements of the release prevention program that is in place at our stationary  
source. 
 
Process Safety Information 
 
Follmer Development Inc. maintains a detailed record of safety information that describes the  
chemical hazards, operating parameters and equipment designs associated with all processes. 
 
Process Hazard Analysis 
 
Our facility conducts comprehensive studies to ensure that hazards associated w 
ith our processes  
are identified and controlled efficiently.  The methodology used to carry out these analyses is  
HAZOP.  The studies are undertaken by a team of qualified personnel with expertise in  
engineering and process operations and are revalidated at a regular interval of five years.  Any  
findings related to the hazard analysis are addressed in a timely manner.  The most recent  
PHA/update was performed on 03/18/1999. 
 
Operating Procedures 
 
For the purposes of safely conducting activities within our covered processes, Follmer  
Development Inc. 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 in the processes. 
 
Training 
 
Follmer Development Inc. has a comprehensive training program in place  
to ensure that  
employees who are operating processes are competent in the operating procedures associated  
with these processes.  Refresher training is provided at least every three years and more  
frequently as needed. 
 
Mechanical Integrity 
 
Follmer Development Inc. carries out highly documented maintenance checks on process  
equipment to ensure proper operations.  Process equipment examined by these checks includes  
among others; pressure vessels, storage tanks, piping systems, relief and vent systems,  
emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by  
qualified personnel with previous training in maintenance practices.  Furthermore, these  
personnel are offered specialized training as needed.  Any equipment deficiencies identified by  
the maintenance checks are corrected in a safe and timely manner. 
 
Management of Change 
 
Written procedures are in place at Follmer Development Inc. to manage changes in process  
chemicals, technology, equipme 
nt and procedures.  The most recent review/revision of  
maintenance procedures was performed on 05/27/1999.  Process operators, maintenance  
personnel or any other employee whose job tasks are affected by a modification in process  
conditions are promptly made aware of and offered training to deal with the modification. 
 
Pre-startup Reviews 
 
Pre-start up safety reviews related to new processes and to modifications in established processes  
are conducted as a regular practice at Follmer Development Inc..  The most recent review was  
performed on 05/27/1999.  These reviews are conducted to confirm that construction, equipment,  
operating and maintenance procedures are suitable for safe startup prior to placing equipment  
into operation. 
 
Compliance Audits 
 
Follmer Development Inc. conducts audits on a regular basis to determine whether the provisions  
set out under the RMP rule are being implemented.  The most recent compliance audit was  
conducted on 05/27/1999.  These audits are carrie 
d 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 
 
Follmer Development Inc. promptly investigates any incident that has resulted in, or could  
reasonably result in a catastrophic release of a regulated substance.  These investigations are  
undertaken to identify the situation leading to the incident as well as any corrective actions to  
prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
 
Employee Participation 
 
Follmer Development Inc. truly believes that process safety management and accident  
prevention is a team effort.  Company employees are strongly encouraged to express their views  
concerning accident prevention issues and to recommend improvements.  In addition, our  
employees have access to all information created as part of the facility's implementation of the  
RMP rule, including information resulting from process hazard analyse 
s in particular. 
 
Contractors 
 
On occasion, our company hires contractors to conduct specialized maintenance and construction  
activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the  
contractor is carried out.  Follmer Development Inc. has a strict policy of informing the  
contractors of known potential hazards related the contractor's work and the processes.   
Contractors are also informed of all the procedures for emergency response should an accidental  
release of a regulated substance occur. 
 
 
5.    Five-year Accident History 
 
Follmer Development Inc. 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 
 
Follmer Development Inc. carries a written emergency response plan to deal with accidental  
releases of hazardous materials.  The plan includes all aspects of emergency respon 
se including  
adequate first aid and medical treatment, evacuations, notification of local emergency response  
agencies and the public, as well as post-incident decontamination of affected areas. 
 
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. 
 
Ventura County is the Local Emergency Planning Committee (LEPC) with which our emergency  
plan has been coordinated and verified. 
 
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.  Employee suggestions, vendor  
equipment updates, process re-engineering, and hazard analyses are some of the major steps we  
want to take to improve safety at our facility.  These changes are continuously being  
implemented.
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