Glasgow Spray-Dry - Executive Summary

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Glasgow Spray-Dry is a dairy processing and drying facility located in Glasgow, Barren County, Kentucky.  This facility maintains a 30,000 gallon bulk propane storage system for auxiliary power.  Based on criteria originally specified in Section 112(r) of the Clean Air Act (CAA), the source was classified as "Program II".  Under a proposed rule (Docket No. A-99-18), the applicable threshold for flammable hydrocarbon fuels (including propane) was increased from 10,000 pounds to 67,000 pounds.  Glasgow Spray-Dry maintains greater than this revised threshold and therefore requires the development, implementation, and submittal of a Risk Management Plan (RMP) to the USEPA. 
 
There have been no incidents involving the propane system in the last five years which presented any threat of personnel or property damage on or off the site. 
 
The worst-case scenario for this facility, as specified in the CAA, is a release of approximately 25,500 gallons of propane within 60 seconds followed by a vapo 
r cloud explosion with a 10 percent yield factor.  The radius of influence to 1 psi overpressure is 0.40 miles, based on modeling using RMP*Comp. 
 
The most severe alternative scenario is a release of 25,500 gallons of propane within 60 seconds and plume dispersal by a Stability Class C atmosphere, followed by a vapor cloud fire extending 0.36 miles (641 yards) based on the ALOHA modeling program.  The Class C atmosphere is representative of historical Glasgow (or surrogate) weather conditions. 
 
In both of these scenarios offsite receptors are affected.  There are no administrative controls or mitigation measures in use that could reduce the predicted effects. 
 
A second, alternative scenario is filling of the tank followed by disconnection or rupture of the fill line and failure of the backflow prevention check valve to actuate.  Modeling indicates the tank would empty in 32 minutes.  Based upon Class C atmospheric conditions the flammable vapor cloud is predicted to extend 0.06 miles ( 
111 yards). 
 
Another alternative scenario is the breaking of the fill pipe flush with the tank.  Modeling indicates the entire contents of the tank would empty in 12 minutes.  Based upon Class C atmospheric conditions the flammable vapor cloud is predicted to extend 0.11 miles (195 yards). 
 
Offsite receptors are not affected in either the 0.06 mile or 0.11 mile alternative release scenarios. 
 
Response to incidental releases (those that may be handled without invoking 29 CFR 1910.120) will be managed by Glasgow Spray-Dry maintenance personnel.  The Glasgow Fire Department will be summoned by 911 if an incident requires more advanced techniques or equipment. 
 
Hazard Review of this system is conducted as needed and Glasgow Spray-Dry personnel perform preventive maintenance inspections monthly.  There are currently no known system deficiencies and no planned changes to the current standard operating procedures or safety protocols.
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