Halocarbon Products Corp. - Executive Summary |
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HALOCARBON PRODUCTS CORPORATION Halocarbon Products Corporation's plant is located on about 100 acres in the North Augusta Industrial Park at street address 1100 Dittman Court. Construction of the plant began in 1982 and shipping of product from the state-of-the-art facility began in 1986. The plant employs about 130 highly skilled people from the surrounding communities. Halocarbon Products Corporation manufactures fluorinated specialty chemicals including lubricants used for oxygen and aggressive chemical service, flotation fluids used in gyroscopes, acids for agricultural chemicals, alcohols used in the manufacture of pharmaceuticals and the generic inhalation anesthetics halothane and isoflurane. To produce these products, Halocarbon needs various chemicals on-site. These chemicals do not pose any unusual hazards when handled and stored properly. Our employees are trained in identifying and handling the hazards associated with these chemicals in the event of an emergency, su ch as a fire or spill. Halocarbon has divided the plant into three main processing areas. Area 1 and 2 are on the north side of the building and are for processing flammable materials. Areas 1 and 2 are separated by fire doors. Area 3 is located on the south side of the building and is used to process non-flammables. Area 3 is separated from Areas 1 and 2 by the mechanical equipment area and the centrally located control room. Two chemicals present at Halocarbon Products Corporation fall under the risk management plan: hydrogen fluoride (HF) and chlorine. As described later, the worst case release scenarios for both these chemicals involve their storage containers. A monitoring alarm is in place at the HF storage area to quickly detect leaks. A water curtain around the storage area can be used to suppress HF leaks. In addition, there is an emergency dump tank designed to hold the entire contents of the primary HF storage tank. In the unlikely event of a failure of the primar y tank, the contents will be dumped to the dump tank and the water curtain will be started to reduce the amount of HF released from the site. Both tanks are diked. Chlorine is stored in industry standard ton cylinders. If a leak were to develop in a cylinder, the cylinder kits (both "A" and "B") required to stop the release are at Halocarbon. These kits consist of various tools, plugs and gaskets necessary to stop cylinder leaks. Two emergency ton cylinders are always available and are capable of holding the contents of a chlorine cylinder. In addition, alkaline material is available to construct a "tent" to absorb and neutralize the escaping chlorine gas. Area alarms are in place to warn of a leak for quick response. ACCIDENTAL RELEASE PREVENTION PROGRAM Halocarbon Products Corporation falls under OSHA's Process Safety Management (PSM) standard. Processes are closely scrutinized for all aspects of safety in processing and handling. Whenever a new process is planned or an ex isting process is modified, a team of highly trained professionals and certified operators hold a formal, structured review of the project. Any potential problems identified during the review are investigated. The team must be satisfied with the outcome of these investigations before the project can proceed. To ensure complete employee involvement, comments are requested from plant operators. These comments also must be addressed by the team. Many times a pre-start up safety review is done prior to starting a new or modified process. This review includes a tour of the process by a team of trained employees to be sure the process is installed correctly. The team also must be satisfied that standard operating procedures, training and Material Safety Data Sheets (MSDS) for the process chemicals are complete. Any incidents in a PSM process are reviewed routinely to see if process improvements are needed. Prior to an operator being certified on a PSM process, he must pass a test ab out that process. In order to ensure that operators keep up with process changes, each operator must make a presentation before their peers and managers every year discussing the process, the chemicals handled and how they operate the process. This operator certification program has worked well for Halocarbon in preventing incidents and releases. To minimize the possibility of spilled chemicals getting into the environment, all process areas and truck loading areas are contained. If there is a spill, the contained material can be reused or properly disposed. Outside storage tanks are diked. If a spill occurs, the material collects in the dike. It is then drained or pumped from the dike to a recovery drum. There are no automatic pumps in the dikes for rainwater, reducing the possibility of accidentally pumping spilled material to the environment. Halocarbon uses, stores and ships chemicals in high pressure cylinders. These cylinders are hydrostatically tested on a regular basi s. Halocarbon has the capability to stop leaks from these cylinders and practices response to a leaking cylinder as part of regular training. As part of our emergency response plan, Halocarbon maintains the following equipment: Self-contained breathing apparatus Level A response gear Level B response gear Level C response gear Air line respirators Emergency A kit for cylinder repair Emergency B kit for cylinder repair Stretchers for rescue Back board for rescue Automatic external defibrillator Fuel oil absorbent Absorbent "pigs" Shovels Brooms Alert meters for hazardous atmospheres First aid kits Neutralizing chemicals for chemical spills Acid-resistant gear Radios for communication Oxygen cylinders and masks Salvage drums Portable emergency dump tanks All of our tanks, vessels, and piping containing extremely hazardous chemicals are on a preventative maintenance program. The program is maintained with a computerized tracking system that generates reports to plant management that insure that items get done as scheduled. The plant and the tank farms are monitored by a leak detection system. If the system detects a leak, an alarm sounds in the control room. All operators are trained in steps to take in responding to a leak alarm, including annual response drills for a stimulated leak. CONTINGENCY PLAN AND EMERGENCY PROCEDURES This plan involves the following steps: 1. Evacuation A. Evacuation of employees B. Evacuation of outside personnel as necessary 2. Implementation of Incident Command System A. Set-up command B. Notify offsite commanders/responders C. Notify offsite agencies for assistance as needed 3. Response A. Employees B. Outside agencies Halocarbon will use the Incident Command System for any incident requiring evacuation. This system is based on the principle that at all times of plant operation there will be at least one person, either on-site or on-call, who will be responsible for directing and coordinating all site emergency response activities. This person is the Incident Commander and will have the authority to allocate all resources necessary to control an incident. Additionally, there will be one person responsible for all outside communications. This person is called the Emergency Coordinator. In the case of an emergency at the facility, the primary Incident Commander and Emergency Coordinator, or their alternates, shall be contacted immediately. Each Incident Commander and Emergency Coordinator must be familiar with this plan, the operations and activities at the facility, the location and characteristics of the hazardous substances handled, the location of critical facili ty records, the facility layout and location of all emergency response and spill clean up equipment. The designated Incident Commander and Emergency Coordinator and alternates are: The primary Incident Commander is the Plant Manager. The secondary Incident Commander is the Production Manager. If an incident occurs at a time when these people are not present, then the Shift Supervisor will take on the duties of the Incident Commander until he is relieved of this duty. The primary Emergency Coordinator is the Director of Environment, Health and Safety. The secondary Emergency Coordinator is the Coordinator of Environment, Health and Safety. Operators take on the duties of the Emergency Coordinator until the primary or secondary Emergency Coordinator is available. The primary duty of the Incident Commander (IC) is to direct all site emergency response activities beginning with evacuation and proceeding through to clean up and restart. The IC has the authority and responsibility to manage and direct all response operations. The duties include: Determine objectives Assign responsibility Manage resources Plan and direct operations Establish internal communications Establish outside communications via the Emergency Coordinator The Incident Commander will take measures to ensure that fire, explosions or continued releases do not occur, recur or spread to other hazardous substance/wastes at the facility utilizing the Incident Command System as needed. These measures include, but are not limited to, designating the following: Operation Officer - manage response to incident Safety Officer - responsible for all safety activities and hazard identification Recorder - record all activities and decisions made in a chronological order Liaison Officer - act as a liaison between the Emergency Coordinator and government and priority or ganizations Decon Officer - coordinate decontamination procedures NOTE: Some employees may handle more than one of the above listed functions. The primary responsibilities of the Emergency Coordinator are as follows: 1. Ensure all employees are accounted for and present. 2. Arrange for Emergency Services for any injured employees. 3. Receive incoming calls 4. Identify and assess the characteristics, source, amount, and extent of released materials. 5. Assess possible hazards to human health or the environment that may result from the release, fire, or explosion. 6. Coordinate all outside communications including North Augusta Public Safety, Aiken County Emergency Response, South Carolina DHEC, and EPA. 7. Advise/respond to radio, TV, and public service announcements. 8. Communicate recommended evacuation distances to North Augusta Public Safety and Aiken county Emergency Response for off site releases that threaten human health and/or the environment. 9. Notify South Carolina DHEC and the National Response center giving information as follows: A. Name and telephone number B. Name and address of facility C. Time and type of incident D. Name and quantity of material involved E. Extent of injuries F. Possible hazards to human health or environment G. Actions proposed or taken to clean-up, contain, limit exposure, and/or remove substance 10. After the incident is over the emergency coordinator will ensure the following: A. Clean-up efforts are completed and waste/contaminated material is stored or disposed of properly. B. Make sure all emergency equipment is cleaned and ready for future use. C. Notify authorities of clean-up efforts D. Recorder has all pertinent information pertaining to the incident E. File a written incident overview to all affected agencies and management. FIVE YEAR ACCIDENT HISTORY The only release of an RMP chemical over the past 5 years involved chlorine. One Friday afternoon, a small metal container in the Research Building was charged with 22 pounds of chlorine. The container had an electric heating element used to heat the chlorine to generate enough vapor pressure to drive the chemical into a research reactor. The power switch for the heater was shut off for the weekend. On Monday morning, the container was found to be empty. An investigation showed the release was due to a faulty heater power switch - the switch contacts were fused together and power was actually applied to the heating element all weekend. As a result, chlorine pressure would build up to the container's pressure relief valve rating. The pre ssure relief valve then opened, reducing the pressure, closed, then opened again. This cycle continued through the weekend, emptying the container. While it was not required for Halocarbon Products to report this release, a report was filed to avoid future questions. WORST CASE SCENARIO Our worst case scenario for hydrogen fluoride (HF) involves a total failure of the primary storage tank. The entire contents of the tank spills and vaporizes within 10 minutes. We are required to assume that there is a very mild breeze, all mitigating devices we have installed (diking, water curtain and emergency dump tank) fail and, at the time of the tank failure, it is 90% full. Further, we must assume that no operators respond to the tank failure and no alarms or leak detectors are activated. In summary, this scenario is required to assume that nothing is done or can be done about the tank failure. The worst case scenario for chlorine is the complete failure of a 2,000 pound container. The assumptions here again are no operator involvement, no alarms warning of the leak, no attempt to mitigate the situation and a complete loss of chlorine in 10 minutes. As in the HF case, the atmospheric conditions are very stable with little wind. ALTERNATE CASE SCENARIO The alternate case scenario for hydrogen fluoride (HF) involves two bolts rusting on a tank flange, allowing a small gap between the flange faces. At first, the HF will leak out undetected, then the alarm will notify the operators of the problem. Automatic valves will be activated to: 1) start draining the HF to the emergency dump tank and 2) start the water curtain. The acid water generated by the water curtain will be collected in the tank dike and will be neutralized prior to disposal. The water curtain will absorb the hydrofluoric acid, reducing the release to the air by 90%. The alternate scenario for chlorine involves the transfer line from the cylinder rupturing. The chlorine vapor will set off one of t he area alarms causing a response from the operators. Operators will respond using protective gear and shut a valve on the cylinder. The total response time is estimated to be 10 minutes. TRAINING Halocarbon Products Corporation has an aggressive training and safety program. The operators demonstrate their ability to handle emergencies via our emergency drills. At least once per year, management arrives at the plant unexpected at an off hour, activates an alarm, hands the responders a scenario and records the response of that shift. This is done for each of the four shifts. The drill is video taped and then reviewed and critiqued by each shift during our regular safety meetings. Lessons learned are made part of the safety meeting. Each operations shift must attend 24 hours of safety meetings per year. These meetings include discussions and hands-on training on subjects such as: Chlorine cylinder A and B kits Repairing a leaking cylinder Level A gear drill Self contained breathing apparatus training Fire extinguisher training Confined space rescue Alarms Evacuations Notification methods Decontamination procedures In addition, the operators are taught to report all injuries and incidents including releases. Each report is investigated to determine the cause so as to prevent the same incident happening again. These reports are kept in a file and the more serious incidents are discussed with the employees during safety meetings. During the past 5 years, Halocarbon has had an excellent record of not releasing chemicals to the environment. This is attributed to the intensive training the operators receive during the year. This training is continuously up-dated and increased to make Halocarbon the best partner the community can have. To further this goal, Halocarbon will be establishing a Community Advisory Panel (CAP) as well as continuing to work under t he Chemical Manufactures Association's Community Awareness and Emergency Response (CAER) program. |