Petro Chemical Products, Inc. - Executive Summary |
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1. Corporate Prevention and Emergency Response Approach The Petro Chemical Products, Inc., (Petro Chemical) facility is located at 2910 W. Beaver Street, Jacksonville, Duval County, Florida. The facility has developed and maintained accident prevention programs and is developing an emergency response plan appropriate to the site. Petro Chemical's onsite environmental and safety personnel are responsible for the safety and environmental programs. They also provide training for site employees and procure safety training services when needed. 2. Description of Stationary Source The Petro Chemical facility uses a A-46 Hydrocarbon mixture as a propellant for aerosol containers. The A-46 mixture system contains a total quantity of approximately 36,000 pounds of a mixture of propane, butane, and isobutane (propane mixture), which exceeds the RMP threshold for a flammable mixture of listed chemicals. The propane mixture is stored in one aboveground horizontal storage tank, which is loc ated outside near the southwestern corner of the property boundary. 3. Description of the Worst Case and Alternative Release Scenarios The worst-case release for a flammable mixture assumes that the total quantity of 36,000 lbs was released into a vapor cloud and 10 percent was assumed to detonate in a vapor cloud explosion. Since the OCA Guidance requires the user to choose either rural or urban, urban land use was chosen. The endpoint distance of 0.3 miles for the worst-case release was determined using OCA Guidance Reference Table 13. For the alternative-case scenario analysis, the quantity of 6,800 lbs., a release rate of 680.0 lbs./min., and a duration of 10 minutes were used. As in the worst-case, urban land use was assumed for the alternative-case scenario. Since the calculated release rate for the alternative-case release was less than 1500 lbs./min. and the LFL for propane is 36, the endpoint distance for the alternative-case release was determined using the data prese nted in OCA Guidance Table 28, which gave a distance of 0.10 miles or 528 feet. 4. Prevention Program The Hydrocarbon Propellant process at Petro Chemical satisfies the RMP rule criteria for a Program 3 process. These criteria are that the process has the potential for offsite impacts in the worst-case scenario, is subject to the OSHA Process Safety Management Standard (PSM), and can be classified into one of the nine SIC codes listed in the RMP rule. The Petro Chemical facility has a program in place to comply with the OSHA PSM Standard, 29 CFR 1910.119. The program was developed in 1998 for the A-46 Hydrocarbon Propellant Process. The PSM program includes a preventive maintenance plan which requires all process equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equipment. In developing the PSM Program, Petro Chemical also developed written op erating procedures for the propellant process. These procedures cover all phases of the operation and include information on safety devices. These procedures will be used to train all operators and mechanics who work on the propellant process the ensure consistency of operation and minimize human error. Existing safe work practices such as Confined Space and Hot Work Permit were reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the PSM Program include collection and review of all equipment information, the development of updated Piping & Instrument Diagrams (P&IDs), and the correction of any equipment design deficiencies found. These actions will ensure that the equipment meets all industry standards and accurate equipment information will be available when needed. A Process Hazard Analysis was performed to identify unsafe conditions. Other prevention plan procedures, including, Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation were developed to ensure continued safe operation and prompt correction of deficiencies. The PSM Program receives full support of plant management and involvement of employees at all levels. 5. Accident History The Petro Chemical facility has had no releases that resulted in offsite consequences for hydrocarbon propellant in the past five years. 6. Emergency Response Program The Petro Chemical facility has an Emergency Response Program in place. The program complies with 29 CFR 1910.38. The site also has internal emergency response capability and is developing a program to comply with paragraph (q) of 29 CFR 1910.120. The current plan has been coordinated with the Jacksonville Fire Department. Notification is made locally by dialing 911. |