Bondo/Mar-Hyde Corporation - Executive Summary |
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General Executive Summary for Propane/Isobutane Storage, Bondo/Mar-Hyde Corporation 1. Accidental Release Prevention and Emergency Response Policies The primary function of Bondo/Mar-Hyde Corporation to manufacture bulk and aerosol paint and specialty coatings for the automotive aftermarket. By virtue of the flammable effects associated with Propane and Isobutane, it is necessary to observe certain safety precautions in handling these products to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as the health of our co-workers, and to reduce the threat to nearby members of the community. We are strongly committed to employee, public and environmental safety. Safety at our facility depends upon the manner in which we handle Liquefied Petroleum Gasses as well as on the various safety devices incorporated into the design of our equipment. Furthermore, comprehensive training received by our employees adds to the inherent safety of our distribu tion facility. Our emergency response program is based upon the provisions contained in Title 40 Code of Federal Regulations, Part 265. In addition to the presence of appropriate controls to prevent possible releases of propane, if a release does occur, we are completely coordinated with Union Township Fire Department, and Environmental Enterprizes, Inc. which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled The primary purpose of this facility is to repackage and distribute propane to both retail and wholesale customers for use as a fuel. Propane and Isobutane arrive at our facility via transport truck only and is stored in two (2) storage tanks. This facility has equipment for transports. Access to this site is restricted to authorized facility employees, authorized management personnel and authorized contractors. The regulated substances handled at this facil ity are propane and isobutane. The maximum amount of propane and isobutane that can be stored at this plant are 66528.00 lb propane and 77616.00 pounds isobutane. 3. The Worst Case Release Scenario and the Alternative Release Scenario, Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario We have calculated worst case release scenarios based on the NPGA-EPA approved TNO-Multi energy method. For alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for propane involves a catastrophic release from Propellant Storage resulting in a Boiling Liquid Expanding Vapor Explosion or BLEVE. The scenario involves the release of 77616 lb. of propane. It is assumed that the entire quantity is released as a vapor that finds an igni tion source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather, the maximum distance of 0.30 miles was obtained corresponding to a flammable endpoint of 1 psi overpressure. An alternative release scenario involves a release from Propellant Storage resulting in a vapor cloud ignition. In this scenario 69 lb. of propane is released in 10 minutes. The release is also controlled by active mitigation measures that include excess flow valves, positive shutoff valves, back flow check valves, and an emergency shutoff valve with mechanical, thermal, and remote capability. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 for 40 seconds is 0.36 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 E PA. This facility was designed and constructed in accordance with NFPA-58 Standard and other applicable codes in effect at the time of installation. The following sections briefly describe the release prevention program that is in place at our stationary source. Safety Information Bondo/Mar-Hyde Corporation maintains a detailed record of written safety information, which describes the chemical hazards, operating parameters and equipment designs associated with all aspects of our distribution facility. Hazard Review A checklist methodology is used to carry out hazard reviews at our facility. The reviews focus on operating procedures, equipment functions and handling practices to identify possible hazards. The studies are undertaken by a team of qualified personnel with extensive knowledge of facility operations and are revalidated annually. Any findings related to the hazard reviews are addressed in a safe and timely manner. Operating Procedures For the purposes of safely cond ucting activities within our covered processes, Bondo/Mar-Hyde Corporation 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 with the processes. Training Bondo/Mar-Hyde Corporation has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Maintenance Bondo/Mar-Hyde Corporation carries out highly documented maintenance checks on process equipment to ensure proper functioning. Maintenance activities are carried out by an outside source supplying qualified personnel with previous training in these practices. Furthermore, personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Compliance Audits Bondo/Mar-Hyde Corporation conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three (3) years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Bondo/Mar-Hyde Corporation promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of propane. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from recurring. All reports are retained for a minimum of 5 years. 5. Five-year Accident History Bondo/Mar-Hyde Corporation has had an excellent record of preventing accidental releases over the last five (5) years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Bondo/Mar-Hyde Corporation carries a written emergency response plan to deal with accidental releases of propane. The plan includes all aspects of emergency response 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. Butler County LEPC 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. Increase training, and increased maintenance and inspection are some of the major steps we want to take to improve safety at our facility. These changes shall be implemented by November, 1999. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. We fully realize this action is not required at this time, however, in the interest of community awareness, Bondo Mar-Hyde Corporation wishes the community to know the steps we are taking to enhance community safety. Name: Charles Keener Signature: Title: Safety/Environmental Date signed: |