Car-Freshner Corporation - Executive Summary |
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General Executive Summary for Manufacturing Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Car-Freshner Corporation 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 Warehousing and filling of aerosol products. We have 3 regulated substances present at our facility. These substances include Isobutane [Propane, 2-methyl], Methyl ether [Methane, oxybis-] and Propane. Isobutane [Propane, 2- methyl] is used for an aerosol propellant. Methyl ether [Methane, oxybis-] is used for an aerosol propellant. Propane is used for an aerosol propellant. 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 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 3 flammable substances as a class involves a catastrophic release from A-55. In this scenario 72,000 lb. of Flammable Mixture: Propane and 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 0.33 miles is obtained corresponding to an endpo int of 1 psi overpressure. The alternative release scenario submitted for Program 3 flammable substances involves a release from A-55. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 21,200 lb. of Flammable Mixture of Propane and Isobutane [Propane, 2- methyl] in 10 minutes. The release is controlled by active mitigation measures that include Water cannons. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.14 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, 1998 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our st ationary source. Process Safety Information Car-Freshner Corporation 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 with 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 5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 03/06/2000. Operating Procedures For the purposes of safely conducting activities within our covered processes, Car-Freshner Corporation maintains written operating procedures. These procedures address various modes of operation such as init ial 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 Car-Freshner Corporation 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 3 years and more frequently as needed. Mechanical Integrity Car-Freshner Corporation 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 Car-Freshner Corporation to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 03/06/2000. 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 Car-Freshner Corporation. The most recent review was performed on 03/06/2000. 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 Car-Freshner Corporation 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 03/06/2000. These audits are carried 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 Car-Freshner Corporation 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 Car-Freshner Corporation 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 analyses 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. Car-Freshner Corporation 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 Car-Freshner Corporation 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 Car-Freshner Corporation carries a written emergency response plan to deal with accidental releases of hazardous materials. 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. Clinton 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. Employee suggestions, vendor equipment upgrades, hazard analysis, and process re-engineering are some of the major steps we want to take to improve safety at our facility. The changes generated are continuously being implemented. |