FP International, Commerce - Executive Summary |
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FP International, Commerce Facility 1) Accidental release prevention and emergency response policies. In this facility we use isopentane and isobutane which is considered flammable by the EPA.The same properties that make isopentane and isobutane valuable as blowing agents in our manufacturing process also makes it necessary to observe certain safety precautions when handling them. These precautions are in place to prevent unnecessary human exposure, to reduce the threat to our personal health as well as our co-workers and to prevent the threat to members of the nearby community. It is our policy to adhere to all applicable federal and state rules and regulations. Safety depends upon the manner in which we handle isopentane and isobutane. This combined with the safety devices inherent in the design, the safe handling procedures that we use and the training of our employees help insure the safety of our employees and our community. Our emergency response program is meant to comply with the Emergency Planning Community Right to Know Law (Hazardous Materials Release Plans and Inventory Act). FP International's response plan includes procedures for notification of the local fire authority and notification of any potentialy affected neighbors. 2) The staionary source and regulated substance handled. A) At our Commerce Facility FP International collects and recycles post consumer and industrial polystyrene for use in the manufacturing of our product. During the manufacturing process, blowing agents (a 50% - 50% mixture of isopentane and isobutane) are injected into a polystyrene melt as it is extruded. One above ground 5,000 gallon storage tank is used to store the blowing agent mixture. B) The regulated substance is isopentane and isobutane. C) The maximum amount stored at this facility is 21,000 pounds. 3) The worst case scenario(s) and the alternate release scenario(s), including administrative controls and mitigation measures to limit the distance for each reporte d scenario. RMP Comp used for modeling. A) Worst Case Scenario: Failure of the above ground storage tank would release 21,000 pound of isopentane and isobutane. Company policy limits the maximum filling capacity to 85% at 60 degrees F. It is assumed that the entire contents are released as vapor which finds an ignition source and results in a vapor cloud explosion. The distance to the endpoint of 1 psi for the worst case scenario is .2 miles. B) Alternate Scenario: A pull away causing faiilure of a 25 foot length of 2 square inch hose. The manualy operated emergency shut off valve will stop the flow. the contents of the hose is lost. Although it is unlikely if the vapor reaches an ignition source, it would result in a vapor cloud fire. The estimated distance to the lower flammablity limit is < .1 mile. This release has the potential of extending beyond the facility boundary. 4) The general accidential release prevention program and specific prevention steps. This manufacturing facilit y complies with EPA's Accidential Prevention Rule and all applicable State Codes and Regulations. This facility was designed in accordance with NFPA-58. As part of our corporate Injury and Illness Prevention Plan all employees receive training covering the following aspects of health and safety; safety philosophy, general safety rules, reporting safety hazards, emergency procedures and hazardous communications. In addition to initial training, further training is given if any employee is exposed to a hazard previously unrecognized, or if an employee is reassigned to a job which exposes them to new hazards. Our Corporate Hazardous Communications Plan, which is located in our safety manual contains, safe work practices, the use and care of personal protective equipment, and emergency procedures in case of spills or releases. Emergency and first-aid procedures are also covered. 5) Five year accident history. There have been no releases of isopentane/isobutane during this time period. 6) The emergency response plan. This facility's emergency response plan is located in our safety manual and is based on NPGA's LP-Gas Handbook. 7) Planned changes to improve safety. Monthly safety inspections are conducted at this facility and safety deficiencies are corrected as they occur. At this time no major upgrades to this facility are planned. |