Process Safety Management

SECTION 1Purpose, Scope and Responsibilities

1.1 Purpose

This document is the written Process Safety Management (PSM) program for the Thunderbolt Solvent System at Perry's Awesomeness Factory (Building B). It sets out how Perry Industries meets each element of 29 CFR 1910.119 for this process, who is responsible, and where the supporting records are kept. Sections 3 through 17 follow the order of the standard, paragraphs (c) through (p).

1.2 Scope

The covered process is the Thunderbolt Solvent System. It stores, transfers and refluxes Thunderbolt, and blends the recovered Thunderbolt into Awesomeness (isopropyl alcohol, 99.5% minimum, CAS 67-63-0). Section 2 sets out the coverage determination and the process boundary. The process includes:

• T-1, 12,000-gallon vertical carbon steel atmospheric storage tank in the flammable tank farm dike (60 ft x 50 ft x 4 ft, drain valve DV-1), with its unloading connection at the flammable/oil unloading pad;
• XV-101, T-1 outlet automatic valve, and P-101, T-1 to R-101 transfer pump, with the connecting piping;
• R-101, 2,500-gallon jacketed reflux kettle (normal charge 2,000 gallons), with its steam supply valve TV-101 and relief valve PSV-101;
• E-101 overhead condenser and V-102 500-gallon recovery receiver, with the vent header and flame arrester;
• the V-102 draw-off line and pump P-102 to the Awesomeness line, and Awesomeness blend tanks BT-1, BT-2 and BT-3 (1,500 gallons each, normal batch 1,200 gallons, blended at ambient temperature, product about 10 wt% isopropyl alcohol), with their outlet piping to the packaging filler;
• Safety systems: LEL detectors LD-1 to LD-3, ESD-101 emergency shutdown, level, temperature, pressure and flow instruments and their alarms and interlocks.

T-3 (white mineral oil) shares the flammable tank farm dike but is not a highly hazardous chemical; it is treated as an adjacent hazard in the PHA. T-2 (Polyjuice Base, 25% aqueous ammonia) is in a separate ammonia storage area and is not part of this PSM process; see Section 2.4. Ammonia solutions are listed in Appendix A of 1910.119 only above 44% ammonia by weight. T-2 is covered separately under the EPA Risk Management Program (document RMP-PJB-001).

1.3 Responsibilities

SECTION 2Applicability Determination

2.1 Coverage basis - 1910.119(a)(1)(ii)

Paragraph (a)(1)(ii) applies the standard to "a process which involves a Category 1 flammable gas (as defined in 1910.1200(c)) or a flammable liquid with a flashpoint below 100 °F (37.8 °C) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more," with two exceptions. Isopropyl alcohol is not listed in Appendix A, so coverage rests on (a)(1)(ii).

• Thunderbolt flash point: 53 °F (12 °C), closed cup. This is below 100 °F.
• Thunderbolt specific gravity: 0.785 at 20 °C, which is 6.55 lb per gallon.
• Awesomeness in BT-1 to BT-3: about 10 wt% isopropyl alcohol; flash point 97 °F (36 °C), Pensky-Martens closed cup (ASTM D93), Perry QC lab, March 2026 (Awesomeness SDS AWE-42). Because the flash point is below 100 °F, the whole weight of the mixture in the blend tanks is counted as flammable liquid, not only its IPA content. Density 1.05 g/mL (8.76 lb/gal) at 20 °C.

Quantity in the process

Table 2-1. Flammable liquid inventory in the process. 10,000 lb of Thunderbolt is reached at about 1,527 gallons (10,000 / 6.55).

R-101 alone holds 13,100 pounds, which is above 10,000 pounds. The process is covered on R-101's inventory by itself, without counting T-1.

2.2 The atmospheric storage exception - 1910.119(a)(1)(ii)(B)

Paragraph (a)(1)(ii)(B) excepts "flammable liquids with a flashpoint below 100 °F (37.8 °C) stored in atmospheric tanks or transferred which are kept below their normal boiling point without benefit of chilling or refrigeration." The exception does not apply to this process. R-101 holds 13,100 lb of Thunderbolt at its normal boiling point of 181 °F (83 °C), the boiling point at 14.7 psia as defined in paragraph (b), and R-101 is a process vessel, not storage. OSHA has stated that the exception reaches only storage and associated transfer (letter to Rep. Richard E. Neal, February 22, 1995).

The process is covered on the R-101 inventory alone, without counting T-1 or the blend tanks.

2.3 Process boundary

Paragraph (b) defines process to include "any group of vessels which are interconnected." T-1 is piped to R-101 through XV-101 and P-101, and V-102 is piped through P-102 to blend tanks BT-1, BT-2 and BT-3. T-1, the transfer piping, the draw-off line and the blend tanks are part of the covered process, and every element of this program applies to them. The blend tanks hold a flammable liquid (flash point 97 °F) in blending service, not storage. The boundary ends at the packaging filler.

Finished Awesomeness in closed containers is outside the process. Once filled and closed, the containers are not connected to any process vessel; OSHA has stated that container storage of flammable liquids of this kind falls under the (a)(1)(ii)(B) exception (letter to Joe Virsack, July 9, 1999). The PHA facility siting node addresses the finished goods area next to the blend tanks.

2.4 Process boundary determination - T-2 Polyjuice Base

T-2 (Polyjuice Base, 25% aqueous ammonia) is a separate process and is not part of the Thunderbolt Solvent System. Ammonia solutions are listed in Appendix A only above 44% ammonia by weight, and aqueous ammonia is not a flammable liquid. Separate vessels are one process when they are located so that a release at one could involve the other (paragraph (b) definition of process); EPA applies the same test to co-located vessels under 40 CFR Part 68, treating two vessels as one process when a single event, such as a fire or explosion, could involve both or interfere with mitigation (EPA RMP guidance, applicability of program levels for co-located vessels).

T-2 is in its own ammonia dike (40 ft x 40 ft x 3.5 ft, drain valve DV-2) about 170 ft from the flammable tank farm dike, across the Building B access road, with no shared piping, its own unloading pad (20 ft x 30 ft) and its own spill kit SK-10, safety shower SS-4 and water-fog monitor WM-1 (drawing PI-B-101). A release or fire at one area does not involve the other. The determination is reviewed at each PHA revalidation and through MOC for any change that reduces the separation.

2.5 Other provisions

• (a)(1)(ii)(A), hydrocarbon fuels used solely as fuel: does not apply. Thunderbolt is a raw material.
• (a)(2): Building B is not a retail facility, an oil or gas well operation, or a normally unoccupied remote facility. The control room is staffed whenever production runs.
• Appendix A: no listed toxic or reactive chemical is present in the process at or above its threshold quantity.

Figure 2-1. Building B facility diagram, drawing PI-B-101 (drawn at 1 in = 80 ft; reduced here, use the graphic scale). Flammable tank farm (T-1, T-3) at top; ammonia storage area (T-2) below, about 170 ft south across the access road.

SECTION 3Employee Participation - 1910.119(c)

This section is the written plan of action required by 1910.119(c)(1).

3.1 Consultation - 1910.119(c)(2)

Perry Industries consults with employees and their representatives on the conduct and development of PHAs and on the development of the other PSM elements. This is done as follows:

• At least one Thunderbolt Solvent System operator serves on every PHA team, revalidation and MOC hazard review. Operators from both shifts are invited to the PHA sessions for the nodes they run.
• The Building B Safety Committee (hourly and salaried members from both shifts) reviews draft operating procedures, safe work practices and training materials before they are issued. Committee minutes record comments and how each was resolved.
• Operators review and initial each operating procedure at the annual certification (Section 6.4).
• Employees may raise a process safety concern to their supervisor, the PSM Coordinator, the EHS Manager or the Safety Committee. Concerns are logged and answered in writing.
• Incident investigation teams include an employee knowledgeable in the process (Section 14).

3.2 Access to information - 1910.119(c)(3)

Employees and their representatives have access to the PHAs and to all other information developed under this program. This includes process safety information, operating procedures, MOC records, PSSR records, incident investigation reports, mechanical integrity records and compliance audit reports.

• Copies are kept in the Building B control room and the PSM Coordinator's office and can be read at any time.
• Requests for copies go to the PSM Coordinator or to Wendy Weaver, Director of Human Resources. Copies are provided within 7 working days.
• Trade secret information is handled under Section 17.

3.3 Informing employees of this plan

This plan is covered in initial operator training and in refresher training. A notice telling employees where the PSM program and PHA can be read is posted on the Building B safety board.