Alloys Cleaning, Inc. - Executive Summary |
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FACILITY DESCRIPTION Alloys Cleaning, Inc. owns and operates a metals cleaning facility at 1957 E. 64th St., Los Angeles, CA. Various metal products are cleaned in acid baths to remove any oxides on the surface and rinsed in batches according to customer orders. The facility is located in an industrial area south of Gage Avenue and west of Alameda Street, in the Huntington Park area. The following AHM is handled at this facility in the maximum amount shown below. Hydrofluoric Acid (70%) 6,000 lb (12 55-gal drums) Concentrated hydrofluoric acid (70%) is delivered to the facility in 55-gal drums, approximately 12 drums every two weeks. Acid is pumped from the drum to the acid baths using a portable pump and flexible hose when needed. All drums and baths are located inside a containment area. All acid systems including acid baths are operated at room temperature. Any acid fumes produced in the baths are drawn into a fume s crubber located nearby and scrubbed with dilute caustic solution. CHEMICAL SAFETY APPROACH AND POLICY Alloys Cleaning, Inc. is committed to conducting its operations in a manner that is safe both to its workers and to its neighbors. In order to meet that commitment, the company maintains a number of programs to minimize the hazards presented by the materials noted above. These programs include release prevention programs, emergency response programs, worker training programs, employee right-to-know programs, and public right-to-know programs. This document, in part, satisfies the public right-to-know program. OFF-SITE CONSEQUENCE ANALYSIS Using software provided by the EPA called RMP*Comp and following the OCA Guidance document, an Off-site consequence analysis was completed for this facility. The reader will note that the only AHM of concern here is 70% hydrofluoric acid. The largest container of this material is a 55-gallon drum and this is the basis used for the worst case scenario. For the alternative scenario, a hole in such a container that was blocked by emergency responders prior to fully emptying the drum was postulated. This material is always handled within a secondary containment system, but this area is much larger that a mere 55 gallon spill and would not limit pool surface area. Below are the RMP*Comp result prints for the two scenarioss. WORST CASE SCENARIO RMP*Comp Ver. 1.06 Results of Consequence Analysis Chemical: Hydrofluoric acid 70% CAS #: 7664-39-3 Category: Toxic Liquid Scenario: Worst-case Quantity Released: 55 gallons Liquid Temperature: 70 F Mitigation Measures: Diked area: 3000 square feet Dike height: 0.33 feet Release Rate to Outside Air: 3.43 pounds per minute Topography: Urban surroundings (many obstacles in the immediate area) Toxic Endpoint: 0.016 mg/L; basis: ERPG-2 Estimated Distance to Toxic Endpoint: 0.3 miles (0.5 kilometers) --------Assumptions About This Scenario--------- Wind Speed: 1.5 meters/second (3.4 miles/hour) Stability Class: F Air Temperature: 77 degrees F (25 degrees C) ------------------------------------------------ ALTERNATIVE SCENARIO RMP*Comp Ver. 1.06 Results of Consequence Analysis Chemical: Hydrofluoric acid 70% CAS #: 7664-39-3 Category: Toxic Liquid Scenario: Alternative Quantity Released: 400 pounds Release Duration: 10 minutes Release Rate: 40 pounds per min Liquid Temperature: 70 F Mitigation Measures: Diked area: 3000 square feet Dike height: 0.33 feet Release Rate to Outside Air: 3.74 pounds per minute Topography: Urban surroundings (many obstacles in the immediate area) Toxic Endpoint: 0.016 mg/L; basis: ERPG-2 Estimated Distance to Toxic Endpoint: 0.2 miles (0.3 kilometers) --------Assumptions About This Scenario--------- Wind Speed: 3 meters/second (6.7 miles/hour) Stability Class: D Air Temperature: 77 degrees F (25 degrees C) ------------------------------------------------ RELEASE PREVENTION This material is always handled and moved in a manual fashion. This means that there is always someone present when the potential for a release of this material exists. Therefore, the release prevention program for this material is primarily in the training and procedures supplied to the affected employees. Below is a brief description of the elements of the training system: 1. The personnel training program will ensure that the facility complies with all elements of hazardous materials and waste laws and regulations. 2. The training program will be directed by a person experienced in hazardous materials and waste management procedures, including contingency plan implementation. 3. Employees will receive instruction on hazardous materials, safe operating procedures, and waste management practices which relate to their duties at the facility. 4. The training program will be designed to ensure that employees will be able to respond effectively to emergencies at the facility. 5. Training will include instruction in emergency procedu res, and the use of emergency equipment and emergency systems. 6. There will be procedures for using, inspecting, repairing and replacing emergency and monitoring equipment at the facility. 7. The training program will include: 1) instruction on the use of shutoff systems and communication or alarm systems; 2) response methods for fires or explosions: 3) response methods for releases to storm drains, sewers or surface waters; 4) procedures for operations shutdown; 5) procedures for the proper handling, storing, labeling and disposing of hazardous materials and wastes. 8. All employees will be required to complete their hazardous materials and waste training before they begin duties involving these materials. 9. Additional training will be provided to personnel when new materials or procedures are introduced and at yearly refresher sessions. 10. The owner and/or operator will maintain the following records and documents at the facility: a. Job title and name of each employ ee holding a position related to hazardous materials/waste management. b. Written job descriptions for each position related to hazardous materials and waste management. c. Written description (including dates and hours) of training given to each person managing hazardous materials/wastes at the facility. d. Records that show that each employee holding a position related to hazardous material/waste management has the required training and refresher courses. FIVE-YEAR ACCIDENT HISTORY No accidents involving the material of interest for this document have occurred in the last five (5) years. EMERGENCY RESPONSE PROGRAM This section covers the procedures to be followed in the event of an emergency. However, before discussing the procedures, a very important point must be made. Should an emergency situation occur, "DO NOT PANIC"; a clear head is very important in handling any emergency. The operator(s) on duty should assess the situation, decide on the course t o follow and then carry out the plans in an orderly, controlled manner. The information presented in the following section is designed to aid the operator in answering emergencies; however, it should be remembered that the operator(s) is the only one who can assess the situation as it occurs. Therefore, should the operator feel that a change in procedure is justified due to the events as they happen, he should make the changes required. SAFETY All personnel should be familiar with the Material Safety Data Sheets for the subject materials. Hydrofluoric acid is nonflammable, but has a lower boiling point (1510F) and is highly reactive. Both liquid and vapors of hydrofluoric acid can cause severe burns which may not be immediately painful or visible. Hydrofluoric acid will penetrate skin and attack underlying tissues and bone. Solutions as dilute as 2% or lower may cause burns. Large burns may also cause hypocalcemia and other systemic effects which may be fatal. Personal protect ive equipment should be used to protect a worker whenever contact with acid could be encountered. The minimum protection suggested for operating and maintenance personnel includes: chemical safety goggles, hard hat, safety shoes, long-sleeved shirt and trousers of wool, DACRON\ polyester, or ORLON\ acrylic fiber. A rubber apron and rubber gloves with gauntlets long enough to cover the forearm provide additional protection when there is a possibility of body contact. A face shield in combination with chemical splash goggles can also be worn for additional protection. This safety equipment is located near the chemical storage area. In emergencies or in performing work where there is possibility of considerable exposure, a full rubber suit with hood should be worn. Air should be supplied to the hood until absence of fumes in the work area has been established. Standby respiratory equipment should be easily accessible in all areas where the subject materials are handled (unloading stations, storage areas, etc.). Emergency eyewash/safety showers are located and operational at the acid area. Water is supplied to the showers using a 2-inch line (minimum pressure 30 psig) through a quick-opening valve which stays open. HANDLING AND CLEANUP OF LEAKS OR SPILLS Company manuals include a spill clean-up procedure. NOTIFICATION In the event of a significant spill outside of the design containment area, the Operator or his designated representative shall make the notifications listed in the table below. EARTHQUAKE In the event of an earthquake, there is nothing the operator can do while the quake is happening, save protect himself from injury. However, once the quake has subsided there are certain procedures which should be followed. These consist of checking the systems for acid leaks or mechanical damages. Agency Notifications AGENCY PHONE NUMBER Los Angeles County Fire Department 911 Hazardous Materials Emergency Response Coordinator (213) 890-4317 State Office of Emergency 1-800-852-7550 Services Warning Center The two agencies listed above have to be notified of any release requiring Fire Department assistance or of any threatened release posing a significant hazard to human health or safety or the environment. Environmental Protection Agency 415-744-2000 Region IX, San Francisco Per Section 304 of Title III of the Superfund Amendment and Reauthorization Act, this agency has to be notified if any loss during a 24-hour period exceeds the "reportable quantity" for hydrofluoric acid of 100 lb (10 gal). When making a notification, the following information shall be given: -Identify the name and location of the plant Alloys Cleaning, Inc. 1957 E. 64th S treet Los Angeles, CA 90001 -Hazardous material involved and estimated quantity -Location and area coverage of spill or leak -Preliminary assessment of potential hazards -Corrective measures being applied -Provide additional information as requested PLANNED CHANGES TO IMPROVE SAFETY This RMP is prepared based on an RMPP prepared for a local agency a few years ago. All planned actions have been completed that were named in that underlying and original document. It should be noted; however, that the manufacturing processes that utilize hydrofluoric acid are undergoing a major retooling, involving the construction of an entirely new facility that will radically affect safety for the better. The expected completion is set for fall of 1999. This RMP will have to be updated and revised at that time. |