SGL Technic, Inc. - Executive Summary |
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Executive Summary 1.1. Accidental Release Prevention and Emergency Response Policies The SGL Carbon Corporation, Arkadelphia Facility, Accidental Release Prevention and Emergency Response policies involve a unified approach that integrates technologies, procedures, management practices, training, coordination with emergency responders, and public awareness. All applicable elements of the U.S. Environmental Protection Agency's (EPA) Risk Management Program (RMP) at 40 cfr 68 and the U.S. Occupational Health and Safety Administration's (OSHA) Process Safety Management Program (PSM) at 29 cfr 1910.119 are adhered to an incorporated, where appropriate, into these policies and this Plan. 1.1.1. Purpose The purpose of these policies, and this Plan specifically, is to establish a system to prevent accidental releases of regulated toxic and flammable substances and to reduce the severity of a release in the unlikely event o ne where to occur. 1.1.2. Management System SGL Carbon Corporation, Arkadelphia Facility has a management system to oversee the implementation and ongoing use of the RMP program elements.. This program, along with other SGL Carbon Corporation policies eliminates and/or reduces hazardous chemical releases at the Arkadelphia Facility. 1.1.3. Organization The Site Manager is responsible for and oversees the local facility management team. The RMP Organization and lines of responsibility are defined in the organizational chart in Appendix A of this Plan. All responsible staff positions related to the RMP and PSM programs are listed. The main duties and responsibilities of these positions related to RMP and PSM are defined in the Emergency Response Plan in Appendix B of this Plan. 1.1.4. Prevention Program Level 3 The SGL Carbon Corporation, Arkadelphia Facility has in place policies, procedures, and systems as part of the Prevention Program. The Prevention Program addresses each of the RMP Program Level 3 elements required by 40 cfr 68.65,et. seq., and corollary elements of the OSHA PSM Program. These required program elements include: 1. process safety information 2. process hazard analysis 3. operating procedures 4. training 5. mechanical integrity 6. management of change 7. pre-startup review 8. compliance audits 9. incident investigation 10. employee participation 11. hot work permit 12. contractors These elements are described in more detail in Section 5of this Plan. The program is tailored to the Arkadelphia Facility and to the emergency response services available to the facility. The Facility is in compliance with the Emergency Response Program requirements. 1.2. The Arkadelphia Facility Site and Regulated Substances Handled The SGL Carbon Corporation Arkadelphia Facility is located at 201 Technology Drive in Clark County, Arkansas. The longitude and latitude of the facility is 93005'39" longitude and 34002'56" latitude. The f acility manufactures bulk graphite gasket material and process rayon fabrics and yarns. These products are used for automotive, aerospace, and other industrial applications. This facility has been situated at this site since May, 1996 and has been engaged in essentially the same operation since that time. 1.2.1. The Arkadelphia Facility Site Description The Arkadelphia Facility is located 7.5 miles southwest of Arkadelphia, Arkansas in the Clark County Industrial Park. The Arkadelphia Facility consists of a 50,000 ft2 production area and an adjoining office complex. Departmental breakdown of the Arkadelphia Facility include Graphite Foil Production, Rayon Fabric Production, Rayon Yarn Production, Calcarbon, Maintenance, Quality Control, Shipping/Receiving, Engineering, Administration and Management. 1.2.2. The Regulated Substance Handled The Arkadelphia Facility is a stationary source as defined by 40 cfr 68.3 and 40 cfr 68.115 and as part of its manufacturing process the facility stores and uses >98% White Fuming Nitric Acid, CAS # 7697372, in a concentration and manner described in 40 cfr 68.115 and above the threshold quantity cited in 40 cfr 68.115 and 40 cfr 68.130. 1.2.3. The Regulated Process The only use for nitric acid at the Arkadelphia Facility is for Graphite Foil Production. Nitric acid is stored in the segregated, locked and restricted nitric acid storage room. The nitric acid is contained in a 6000 gallon aluminum tank, with a sidewall thickness of 5/16". The nitric acid tank is located inside an acid resistant coated secondary containment sump that is capable of holding 2.62 times the tank volume. Nitric acid is supplied to the Graphite Foil Production by ~ 100' of 3/8" PTFE tubing. The total combined volume of the nitric acid delivery line at any one time is ~ 2 gallo ns. 1.3. Offsite Consequences Analysis Two offsite consequences analysis were conducted. They include two nitric acid release scenarios. The first is the EPA prescribed and unlikely "worst case release." The second is the more probable "alternative release scenario." The alternative scenario is defined as "more likely to occur than the worst case scenario." The regulatory "lookup" tables in the "RMP Offsite Consequences Analysis Guidance", as presented in the USEPA supplied software package "RMP*Comp" , were used to determine the distance theoretically traveled by the released gas under specific atmospheric conditions before the concentration of the gas decreases to the "toxic endpoint" specified at 40 cfr 68 Appendix A. This endpoint is described by the American Industrial Hygiene Association (AIHA) as the "maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action." The same endpoint was used in both analyses. The residential population within a circle with a radius corresponding to the toxic endpoint distance was defined to estimate the population potentially affected under each scenario. The population residing in the resulting circle was estimated from the most recent U.S. Department of Commerce, Bureau of the Census data using the Block Group Uniform Density Method as contained in the LandViewbIII Environmental Mapping Software obtained from the Bureau of the Census. Included along with the population estimates are estimates of the number of institutional features and specified environmental receptors falling within the two circles. Details of the Offsite Consequences Analyses effort and results are described in Section 3 of this Plan. 1.3.1. Worst Case Release Scenario The worst case release scenario at the SGL Carbon Corpora tion, Arkadelphia Facility involves the failure of a 6000 gallon >98% White Fuming Nitric Acid storage vessel, the largest single storage vessel on site. The scenario followed the conditions prescribed by EPA at 40 cfr 68.22 and 40 cfr 68.25. EPA set this condition to facilitate the performance of the offsite consequences analyses in such a manner to provide an estimate of the maximum possible area that might be affected in the unlikely event of catastrophic conditions. The conditions were selected in order to provide very conservative results, i.e. large distance to endpoint, and may be unrealistic. The Offsite Consequences Analysis yielded a distance to the endpoint of 0.3 miles. The analysis of the demographic data representing a circle around the facility with a radius equal to the endpoint distance yielded a population estimated at 3 including three manufacturing facilities, but no institutional facilities or environmental receptors. A detailed discussion of the analysis of t his scenario is contained in Section 3.4 of this Plan. 1.3.2. Alternative Case Release Scenario The alternative release scenario involved a faulty hose used to transfer received shipments of nitric acid from a delivery vehicle to the nitric acid storage tank. The annual average temperature was provided by NOAA data from Hot Springs, AR. Other meteorological conditions assumed were those as contained in the "RMP Offsite Consequence Analysis Guidance" This serves to describe a more plausible failure of containment occurring during more likely atmospheric conditions. The Offsite Consequence Analysis yielded a distance to the endpoint of 0.2 miles. The analysis of the demographic data representing a circle around the facility with a radius equal to the endpoint distance yielded a population estimated at 1 including one manufacturing facility and no institutional facilities or environmental receptors. A detailed discussion of the analysis of this scenario is contained in Section 3.5 of this Plan. 1.4. Accidental Release Prevention Program Based upon the offsite consequences analysis and the requirement a PSM Program under the OSHA regulations at 29 cfr 1910.119, The SGL Carbon Corporation, Arkadelphia Facility's Accidental release Prevention Program is based upon the Level 3 Program requirements of 40 cfr 68. 1.4.1. General facility Wide Release Prevention The facility has an emergency response plan, which has been coordinated with the Arkadelphia Fire Department. The Arkadelphia Fire Department is a member of the Local Emergency Planning Committee (LEPC). This emergency response plan includes an emergency response decision tree and a notification plan. Internal emergency response drills are conducted quarterly by the facility. The Arkadelphia Fire Department has a standing invitation to participate in these drills. Emergency operations and response procedures are evaluated as part of these drills. Besides the specific emergency response program elements, other essential elements of the prevention program are incorporated into the operating culture of the facility and include: 1. involvement by senior management in every aspect of the Graphite Foil process 2. continuous on-going training of operators and other staff critical to the process 3. preventive maintenance and mechanical integrity programs to assure continued safe operation of the process 4. up to date process and safety equipment that meets or exceeds industry and regulatory standards 5. management of change procedures to assure that all processor equipment modifications are thoroughly reviewed with safety as the foremost concern 6. auditing and inspection programs to assure continuing safe operation 1.4.2. Chemical Specific Release Prevention For the prevention of a release of nitric acid from the Graphite Foil Process, the prevention steps include, but are not limited to, the following: 1.4.2.1. Facility Design The Arkadelphia Facility was designed to minimize pos sible contact between personnel and nitric acid. The storage area for nitric acid is isolated in a normally locked acid storage room. The storage room is surrounded by a 4' concrete retaining wall that is designed to contain 2.62 times the tank volume. Additionally, the floor of the acid storage room and the concrete retaining wall are covered with an acid resistant coating to prevent seepage. 1.4.2.2. Equipment Design All equipment associated with the nitric acid process is constructed of industry accepted materials of construction for contact with nitric acid, (PTFE, stainless steel, anodized aluminum, titanium). In every location possible, secondary containment is also included to minimize the risk of human contact with nitric acid. 1.4.2.3. Personnel All personnel associated with the Graphite Foil process receive initial and ongoing training in the safe operation of the process and related equipment with particular emphasis on the hazardous properties of nitric acid. All per sonnel that are assigned to the Graphite Foil process undergo Haz-Mat training that is specifically tailored to the nitric acid process. 1.5. Five Year Accident History The SGL Carbon Corporation, Arkadelphia Facility has had two accidental release that resulted in an injury onsite, but not in deaths or significant property damages on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage in the past five years. 1.6. Planned Changes to Improve Safety On April 2, 1999, SGL Carbon Corporation, Arkadelphia Facility preformed a Process Hazard Analysis for the nitric acid system at the Arkadelphia Facility. ECCI, Inc. assisted in the PHA, and proposed action items are included in Appendix D. As part of the internal health and safety program at the Arkadelphia facility, a weekly inspection of the entire facility is preformed by a multi-departmental safety committee. |