C-CARE, LLC - Executive Summary

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Section 1: Accidental Release Prevention and Emergency Response Policies 
 
The C-CARE, LLC facility is designed, constructed, and operated to provide a safe and healthful work environment for our employees, protect our neighbors and the citizens of the local community, and protect our environment.  We strive for continuous improvement through the use of good engineering practices, the development of new technologies, internal auditing programs, an employee suggestion program, and external auditing by state and local regulatory agencies and emergency response organizations.    
 
 
Section 2: Stationary Source and Regulated Substances Handled 
 
C-CARE, LLC is a contract manufacturer of personal care products.  The principle products manufactured include hair color, hair color developers, styling products, shampoos, conditioners, and perm products.  The NAICS code for these products is 32562, Toilet Preparation Manufacturing. 
 
This facility currently utilizes one covered process in which a li 
quified petroleum gas mixture composed of approximately 50% propane and 50% isobutane is charged into aerosol cans for the purpose of expelling  hair color products.   The LP gas is brought in by tanker trailer and transferred through an unloading station to a 4,000 gallon above ground storage tank.  The maximum quantity on site at any one time is 3,400 gallons or approximately 15,500 pounds.  The LP gas is transferred through piping to a filling machine located within a gas house which is attached to the rear of the manufacturing building.  Cans of hair color enter the gas house on a conveyor, are charged with the LP gas in the filling machine, and exit the gas house on the conveyor.  The filling machine is capable of charging approximately 27 cans per minute, the largest of which receive 8 grams of LP gas.  
 
 
Section 3: The Worst-Case Release Scenarios and the Alternative Release Scenarios 
 
3A. Worst-Case Release Scenario 
 
The worst-case release scenario for this process involves a v 
apor cloud explosion that could potentially occur if the storage vessel were full and the entire 3,400 gallons were to be released at one time.  The estimated distance to an overpressure of 1 psi is 0.2 miles, based on the EPA's RMP*Comp model. 
 
There are four public receptors and a portion of a residential community located within 0.2 miles.  Two of the public receptors are industrial park type occupancies and the other two are office buildings.  The area directly behind the storage vessel is wooded and this area could potentially become involved in a fire scenario in the event of an explosion at the storage vessel.  A residential community is located on the opposite side of that wooded area and there are approximately 90 homes within the 0.2 mile range in which we would expect an overpressure of 1 psi.  Based on an average of 4.7 persons per household in Anne Arundel County, there are approximately 430 residents in those homes.  Some of those homes border the wooded area and could be 
at risk if the wooded area were involved in a fire scenario. 
 
There are no passive mitigation systems in place.  There is a pressure relief valve on the vessel and active mitigation systems in the form of excess flow valves where lines enter the vessel to prevent the discharge of product in the event of piping or valve failure. 
 
3B. Alternative Release Scenario. 
 
The most probable alternative release that would occur at this facility would involve the rupture or disconnection of a hose during the transfer of LP gas from a transport to the storage vessel.  The product released could potentially find an ignition source and result in a vapor cloud fire.   Active mitigation systems that are in place to prevent or minimize a release of product include emergency shut off valves on the transport, an excess flow valve on the transport, and a backflow check valve in the transfer line from the unloading station to the storage vessel.  With these active mitigation systems in place, the estimated 
quantity that would be released in the event of hose rupture or disconnection would be approximately 10 gallons or 45 pounds.  The lower flammability limit for propane is 36.0 milligrams per liter and the distance to reach that endpoint would be less than 0.1 miles based on the EPAs OCA guidance reference tables.  There are no public receptors within that distance, however, the wooded area behind the facility could potentially become involved in a vapor cloud fire scenario and place the residential homes on the opposite side at risk. 
 
 
Section 4: Accidental Release Prevention Program. 
 
The aerosol charging process is subject to the requirements of OSHAs Process Safety Management standard.  A process hazard analysis has been conducted to identify and control potentially catastrophic events that could result from the release of LP gas at our facility. 
 
The PHA documented that the necessary safety and active mitigation systems are in place.  The equipment and safety systems for this proc 
ess were designed and installed in accordance with NFPA 58: Standard for the Storage and Handling of Liquified Petroleum Gases, NFPA 30B: Code for the Manufacture and Storage of Aerosol Products,  29 CFR 1910.110: Storage and handling of liquified petroleum gases, and other good engineering practices.  Several groups were consulted during the design and construction phases, such as  Factory Mutual Insurance Company, the Anne Arundel County Fire Marshall, and the supplier of the LP gas. 
 
The storage vessel is constructed of carbon steel and the piping and fittings are schedule 80.  The transfer system is equipped with process controls such as emergency isolation valves, excess flow valves, backflow check valves, pressure relief devices, and vents.  There is a back-up generator to provide auxilliary power in case of power failure. 
 
The aerosol filling room is equipped with state of the art equipment and safety systems.  There are gas detection devices to detect the build-up of LP gas and 
the room has a ventilation system that provides 1 complete air change per minute.  If a gas monitor detects 20% of the lower explosive limit, the ventilation rate will automatically increase to 2 air changes per minute and audible and visual alarms are triggered to alert employees.  If a gas monitor detects 40% of the lower explosive limit, the process equipment automatically shuts down, air actuated valves close and prevent additional LP gas from entering the building, and audible and visual alarms alert employees.  These alarms are monitoried by an outside agency 24 hours per day, 7 days per week.  The gas house is protected by a state of the art explosion suppression system which which utilizes infrared detection and water as the suppression agent. 
 
Operational procedures have been developed to control the activities of employees working on or in close proximity to this process.  The procedures detail start-up, normal operations, shut down operations, temporary shut downs, emergenc 
y operations and special operations such as hot work. 
 
A preventive maintenance program has been implemented to regularly inspect and test the process equipment and safety systems.  That program will ensure that the mechanical integrity of the process equipment is maintained and ensure that the safety systems are functioning properly.  The storage vessel and piping are leak tested bi-annually with a soap solution.  The components are inspected during the bi-annual test and painted as necessary to prevent corrosion.  The emergency stop buttons and the automatic emergency shut off valves are tested quarterly to ensure their proper function.  The pressure relief valve on the storage vessel is inspected quarterly to ensure that it does not leak continuously or lift prematurely.  The gas house safety systems are tested, repaired and maintained quarterly to ensure that all of the components are in proper operating condition and the system is functioning as designed.   
 
 
Section 5: Five Year  
Accident History 
 
This facility and the aerosol filling operation are 5 years old.  There have not been any accidental releases from this process. 
 
 
Section 6: Emergency Response Program 
 
The Environmental, Health & Safety Manager is the facility Emergency Response Coordinator.  The Emergency Response Coordinator is responsible for assessing each emergency and determining the appropriate response action.  Internally, we have 3 emergency response teams: an evacuation and building protection team, a spill response team and a first aid team.  Each team has been trained to perform their specific job functions in the event of an emergency.  The local external agencies that may be called upon in the event of an emergency at our facility include the Anne Arundel County Fire, Police, Health and Public Works Departments, and the Maryland Department of the Environment.  For medical emergencies, we will use a local medical center or the Hospital.  The Emergency Coordinator will identify and conta 
ct the internal and external resources necessary to handle a particular type of emergency. 
 
A Tier II Report is submitted each year to the Maryland Department of the Environment, the Anne Arundel County Fire Department Headquarters and the Anne Arundel County Fire Station that would respond to an emergency at our facility.  The most recent report was submitted August 16, 2000.  Members of the Anne Arundel County Fire Department that would respond to an emergency were provided with a tour of our facility so they could become familiar with our processes, chemical hazards, fire and explosion hazards, and the fire detection and suppression systems that are in place.   
 
In the event of a chemical release that cannot be handled internally, arrangements have been made with a local Hazmat contractor who will be called upon to handle the release.  The LP gas will evaporate immediately at -25 degrees Fahrenheit, thus any product released would quickly evaporate to a gaseous form and present a fi 
re and explosion hazard. 
 
Our facility is fully protected by an automatic sprinkler system.  There is a fire pump on site to ensure adequate pressure in the event of a discharge from the sprinkler system and the fire pump is inspected, tested and maintained on a weekly basis.  Fire detection systems within the facility include smoke detectors, heat detectors, and flow detectors in the sprinker system.  Each type of detector will trigger audible and visual alarms within our facility, and send a signal to the outside monitoring agency.  These systems are inspected, tested, and maintained in accrordance with our preventive maintenance program. 
 
 
Section 7: Planned Changes 
 
A new process technology have been developed and is currently being evaluated that would elimate the use of LP gas in the process.
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