Rust-Oleum Corporation - Executive Summary |
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1.0 SOURCE AND PROCESS DESCRIPTION 1.1 SOURCE The Rust-Oleum Corporation (Rust-Oleum) off-site warehouse located in Pleasant Prairie, Wisconsin, is subject to the United States Environmental Protection Agencys (USEPAs) Risk Management Program (RMP) for Accidental Chemical Release regulation (40 CFR 68) because it contains a mixture of propane (Chemical Abstract System [CAS] number 74-98-6) and n-butane (CAS number 106-97-8) exceeding 10,000 pounds. The mixture is used as a propellant for aerosol paint cans. Finished goods are transferred to the warehouse for interim storage. Mixtures of propellant, flammable liquids, and paint solids are stored in 12- or 18-ounce cans. Approximately 1,000,000 pounds of propellant may be stored in the well-protected warehouse at any one time. Propellant is a flammable and potentially explosive gas. The propellant is not inherently toxic. 2.0 POTENTIAL RELEASE SCENARIO 2.1 WORST-CASE SCENARIO Consistent with the RMP rule requirements, a worst-case release from the largest single container was analyzed to assess the maximum distance to the flammable endpoint. The release scenarios analyzed and the endpoints evaluated are based on the guidance contained in the USEPAs Risk Management Program Guidance for Propane Storage Facilities (the Propane Guidance), dated March 4, 1999, and the USEPAs Offsite Consequence Analysis Guidance (OCAG), dated April 1999. The worst-case scenario assumes that failure of the largest single container, an 18-ounce aerosol can, results in a release of propellant and flammable liquid vapor. The released material is assumed to form a vapor cloud which comes into contact with an ignition source and detonates. The endpoint for this release is defined as an overpressure of 1 pound per square inch caused by the explosion and is considered the threshold for potential serious injuries to people as a result of property damage caused by an explosion. Based on the contents of an 1 8-ounce aerosol can, the distance to the endpoint for a worst-case release is 38 feet (0.007 miles), which is contained within the building. No public receptors are located within the endpoint distance. 3.0 ACCIDENT HISTORY There have been no accidental releases of propellant at the Rust-Oleum Pleasant Prairie warehouse in the last 5 years that have resulted in death, injury, or significant property damage on site; or off-site death, injury, property damage, evacuation , sheltering in place, or environmental damage. 4.0 PREVENTION PROGRAM Although a formal, documented prevention program is not required by the RMP rule for Program 1 processes, a number of design and operational controls are in place to decrease the severity or prevent the occurrence of a fire or explosion. The most significant controls are described below: The warehouse is designed as an aerosol warehouse in accordance with the National Fire Protection Association (NFPA) Manufacture and Storage of Aer osol Products code (NFPA 30B). Aerosol storage is limited to two pallets high within the warehouse. All electrical equipment meets the requirements of the National Electric Code (NFPA 70). The warehouse is fully sprinklered using an early suppression fast response system. 5.0 EMERGENCY RESPONSE PROGRAM The Rust-Oleum, Pleasant Prairie facility has implemented a detailed written Emergency Action Plan (EAP). The EAP is intended to address all emergencies at the facility, including incidents related to a release of propellant. The EAP includes awareness and response training for plant employees, coordination with the local fire department, and evacuation of personnel in the facility. The EAP identifies specific individuals and their responsibilities, and identifies procedures for emergency medical care. Additionally, the Rust-Oleum manufacturing facility, located less than one city block from the off-site warehouse, has a trained and well-equipped hazardous material response team that would also respond to a hazardous material situation at the warehouse. Please note that the USEPAs RMP*Submit software, version 1.0.7, does not allow entry of such a small release amount and endpoint distance. The release amount in the data elements sections of RMP*Submit is, therefore, reported as 1 pound and the endpoint distance as 0.01 miles. |