Oxarc, Inc. - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Oxarc, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass manufacturing, repackaging, storage, and sales of gases. We have 4 regulated substances present at our facility. These substances are Ammonia (anhydrous), Acetylene [Ethyne], Sulfur dioxide (anhydrous) and Chlorine. All of these substances are for resale and are not used within our facility. . The maximum inventory of Ammonia (anhydrous) at our facility is 36420.00 lb. while Acetylene [Ethyne], Sulfur dioxide (anhydrous) and Chlorine are present at our facility in quantities of 19225.00 lb., 17000.00 lb. and 11250.00 lb. respectively. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from the Sulfur Dioxide bulk storange tank. In this scenario 17000 lb. of Sulfur dioxide (anhydrous) is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation tak es place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been calculated at 100%. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 12 miles is obtained corresponding to a toxic endpoint of 0.0078 mg/L. The alternative release scenario for Chlorine involves a release from a 150 pound chlorine cylinder. The scenario involves the release of 150 lb. of Chlorine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by an "A" style containment kit which can limitl the quantity released. Under neutral weather conditions the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.31miles. The alternative release scenario for Sulfur dioxide (anhydrous) involves a release from a 150 lb. Sulfur Dioxide cylinder. The scenario involves the release of 150 lbs. offSulfur Dioxide . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by the application of an "A" style containment kit. These active mitigation systems can limit the quantity released. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 0.31 miles. The alternative release scenario for Ammonia (anhydrous) involves a release from the Ammonia bulk storage tank. The scenario involves the release of 2000 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.31 miles. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Acetylene manufacturing. In this scenario 19225 lb. of Acetylene [Ethyne] is released. The release quantity has been calculated as the maximum quantity on hand. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.22 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Acetylene manufacturing. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 2310 lb. of Acetylene [Ethyne] in minutes. Passive mitigation controls such as deluge system(s) are taken into account to calculate the scenario. The re lease is also controlled by active mitigation measure that is a water de luge system. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.07 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Oxarc, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The studies are undertaken by a team of qualified personnel with expertise in process operations and are constantly evaluated. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Oxarc, Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Oxarc, Inc. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least yearly and more frequently as needed. Mechanical Integr ity Oxarc, Inc. carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Oxarc, Inc. The se reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Oxarc, Inc.will conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Oxarc, Inc. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Oxarc, Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Oxarc, Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Oxarc, Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, only one accidental release has occurred during this period. There has been only one accidental release of a regulated substance from our facility within the last 5 years. This release took place on 08/14/1996 and involved 2000 lb. of Ammonia (anhydrous). Due to this accident, 103 people offsite received medical treatment. Onsite, there were no deaths or injuries. 6. Emergency Response Plan Oxarc, Inc. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Franklin County LEPC is the Local Emergency Planning Committee (LEPC ) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. A new receiving prodcedure for hazardous proudcts and additional internal fencing to prevent release during the possible theft orf Ammonia are some of the major steps we have taken to improve safety at our facility. We are looking at replacing the bulk Sulfur Dioxide storage tank and updating the fill system. This change is expected to implemented by October 1, 1999. |