TCL India is evaluating a project to set up a Fine Chemicals Manufacturing Facility from shale gas feedstock in West Virginia. The project is entitled ‘Pluto’. The facility will be storing and handling n-butane in excess of 10,000 lbs. in above ground bullets, and hence will be subject to OSHA PSM (29 CFR 1910.119 et seq.) and EPA RMP (40 CFR 68.150 et seq.).
Scope of WorK
Step 1: Impact Assessment
a. Facility Siting Study (FSS) – Consequence based study
b. Risk Management Program Worst Case Scenario Offsite Consequence Modeling
c. Prepare PSM, RMP & CFATS Applicability Assessment (needed for Step 2)
Step 2: Meet with Authority Having Jurisdiction to discuss safety study requirements
Step 3: Quantitative Risk Assessment (QRA), if required
Step 4: Dispersion modeling of LPG vents and PSV discharges (LPG Bullet PSV discharges will be modelled to assess distances to reach a flammable concentration at and below the Lower Flammable Limit (LFL), if required. Note: it is assumed that the design of the bullets will follow NFPA 58 Liquefied Petroleum Gas Code requirements and thus adherence to code standards may eliminate the need for dispersion modeling.
Step 5: Submittal of RMPlan, development of PSM program elements and Submittal of CFATS Top Screen (task not included in this proposal)