Gerett Products - Executive Summary |
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Gerett Products, a division of Western Industries, has instituted an "Accidental Release Prevention" policy that utilizes an integrated procedural, technological, and managerial plan. That plan incorporates the following points: i. Full incorporation of Process Safety Management principles for the handling and storage of regulated materials; ii. Utilization of well-trained, experienced personnel; iii. Utilization of safe, well maintained facilities; iv. Ongoing management interest, involvement, oversight and process support. Gerett Product's "Emergency Action Plan" has been compiled. Gerett Products manufactures small 16.4 oz. flammable-gas filled, steel canisters. The canisters are normally utilized as propane gas-operated camping cookstoves and heaters. Bulk delivery of the gas occurs by commercial truck. The gas is transferred to bulk storage prior to the manufacturing bottle filling process. Packaged bulk storage (after bottling, before shipping) occurs within on-site storage. Typ ically the total amount of gas on-site is between 110,000 to 500,000 pounds. The Offsite Consequence Analysis consideration of both a "Worst Case" release and an "Alternative" release scenario for the regulated material. The "Worst Case" release scenario has been defined by the EPA as "the owner or operator shall assume that the maximum quantity of product, from the largest storage vessel, is released in its "normal" state over a 10 minute period. In the case of liquified gases, the "normal" state would be primarily a vapor state. The "Alternative" release scenario has been defined as "the case more likely to occur than a "Worst Case" scenario. The "Worst Case" scenario would entail the rupture of a Storage Tank suddenly releasing approximately 110,000 pounds of Propane gas. The release will be assumed to occur over 10 minutes. Using a Vapor Cloud explosion model, OCA Section 5.1, the Endpoint distance, the distance required to reach the specified 1 PSI overpressure limit, may be found by either utilizing the EPA OCA reference Tables or direct calculation employing Equation C-1. The estimated endpoint distance using the RMP Guidance for Propane Storage Facilities Table 3 is 0.40 miles. The "Alternative Case" scenario would be the rupture or breakage of an unloading hose or transfer pipeline releasing less than 100 pounds of Propane gas. The tank system and piping, utilizing excess flow, spring-loaded emergency shutoff, check and globe valves would limit any gas release to the contents of the unloading hose or transfer pipelines. Again any release would be limited to a maximum 10 minute duration. Using OCA Table 21, the resulting estimated Vapor Cloud detonation endpoint distance is <0.06 miles. The Gerett Products accidental release prevention program is based on the following parameters:1) Full compliance with the OSHA mandated PSM rule; 2) Use of clear, appropriate and accurate operating procedures; 3) Use of well trained and conscientious operators; 4) Use of wel l maintained and properly equipped facilities; 5) Ongoing Hazard Reviews of equipment and/or processes; 6) Full management involvement and oversight. Gerett Products has experienced no accidental releases of regulated material at any time in the past five years. Gerett Products has developed an Emergency Action Plan that details appropriate responses to potential emergencies at the facility. |