Piedmont Laboratories - Executive Summary

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EXECUTIVE SUMMARY 
 
1. Accidental release prevention and emergency response policies 
 
Piedmont Labaratories is committed to both the safety of our employees and that of the surrounding public, including both human health and the environment.  Safety is ensured through careful prevention measures and emergency planning.  The intent of our Prevention Program is the minimization of all risks that could possible lead to an accidental release.  The program focuses primarily on the mechanical integrity of the process equipment and the training of its operators. 
 
2. The stationary source and regulated substances handled 
 
o Piedmont Laboratories is a manufacturing plant that uses hydrocarbon propellants to pressurize aersol cans.  
o This plant uses a mixture of several regulated substances.  These substances are composed of a combination of propane, isobutane, N-butane, 1-1 diflororthane and isopentane.  For simplicity the worst case analysis and alternate release scenario were based on the maj 
or component of the mixture with the highest heat of combustion.  In the case of the propellants, propane and its properties were used in the analysis. 
o The maximun quanity of these regulated mixtures at this facility is 362,000 pounds. 
 
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 
 
o Worst-Case Scenario- Failure of the storage tank when filled to the greatest amount allowed would release 362,000 pounds of propane.  Company policy limits the maximum filling capacity of this tank to 85%.  It is assumed that the entire contents are released as vapor which finds an ignition source, 10% of the release quanity is assumed to participate in the resulting explosion.  The distance to the endpoint of 1psi for the worst-case scenario is 0.58 miles 
o Alternative Scenario- A pull-away rupture causing failure of a 25 foot length of 4 inch diameter transfer hose.Exc 
ess flow valves function to stop the flow.  The conents of the hoses are released and travel to the lower flammability limit.  The distance to this endpoint is less the 320 feet, but has the possibility of extending beyond the facility boundary. 
 
4.  The general accidental release prevention program and the specific prevention steps 
 
Piedmont Laboratories believes that the best way to prevent an accidental release is by being proactive in its approach to safety.  The facility maintains information about the proper use of its equipment and the possible hazards.  By following set operating procedures and maintenance routines, the process equipment within the facility will continue to operate in opimum condition.  In addition the release prevention program is constantly being improved by sustained employee training and regular compliance audits. 
 
5. Five-year accident history 
 
Piedmont Laboratories has not experienced any accidents within the last five years that either led to the release 
of hazardous chemicals or had the potential to lead to such a release. 
 
6. The emergency response program 
 
A well planned emergency response program can make a tremendous difference in the potential off site impacts of an accidental release.  Swift, efficient actions can minimize the damage to both human population and natural surroundings.  To this end, Piedmont Laboratories, has coordinated emergancy response efforts with appropriate local agencies and has instructed employees on the proper actions to take in the event of an accidental release. 
 
7. Planned changes to improve safety 
 
A proactive maintenance program will be implemented to ensure continued integrity process equipment.
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