SAL Chemical Company - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies SAL Chemical is committed to continuous improvement in the chemical distribution industry's responsible management of chemicals. As part of that commitment, we make health, safety and environmental considerations a priority in our planning for all existing and new operations, products, processes, and facilities. Description of the Facility and Regulated Substances SAL Chemical's operations include chemical warehousing, repackaging, and distribution. SAL Chemical maintains an inventory of chlorine and hydrofluoric acid (HF) in quantities that exceed the EPA's threshold quantities for regulation under the Risk Management Program (RMP) rule. SAL Chemical stores up to 14 one-ton containers and up to 150 150-pound cylinders of chlorine, for a total of 50,500 pounds, outdoors. The maximum inventory of 70% HF is 10,000 pounds. HF is stored in drums inside a 10,000 square-foot warehouse. The chlorine and HF are not repacka ged; they are stored onsite and shipped to customers in the original containers. The chlorine storage and distribution operation is regulated by OSHA's Process Safety Management (PSM) rule; therefore, it is a Program 3 process. The HF storage and distribution process meets Program 1 requirements. Worst-Case and Alternate Release Scenarios A worst-case release of HF would be 350 pounds, the contents of one 55-gallon drum, released inside a 10,000-square foot building. The release rate to the outside air is 0.21 pounds per minute. The distance to the toxic endpoint of 0.016 mg/L for this release is 0.1 mile, which would not reach a public receptor. The distance to the toxic endpoint was estimated using EPA's RMP*Comp model, and the population data was accessed from the US Census Bureau's internet database. The worst-case release of chlorine at the facility would be a catastrophic release of 2,000 pounds of chlorine from a one-ton container over a 10-minute period. The extent of the release was calculated without taking credit for any mitigating factors, which is in accordance with EPA requirements for calculating the effects of a worst-case release. The distance to the toxic endpoint of 0.0087 mg/L is 1.3 miles, which would potentially impact a residential population of 2,700. EPA's model, RMP*Comp, was used in estimating the distance to the toxic endpoint. The US Census Bureau internet site provided the population estimate. The alternative release scenario for chlorine is a one-ton container leak from a one-half inch diameter hole, resulting in a leak of 620 pounds per minute of liquid chlorine. It is estimated that the leak could continue for 60 minutes before being stopped. Although unlikely to occur, this release scenario is more likely to occur than the worst-case release scenario described above. This release would be mitigated by SAL Chemical's storage and inspection program. The containers are stored away from vehicular traffic, and the cont ainers are inspected daily. The distance to the toxic endpoint for this scenario is 0.4 mile, which would potentially impact a residential population of 30. The release rate was derived from EPA's RMP Guidance for Wastewater Treatment Plants, and the distance to the toxic endpoint was calculated using RMP*Comp. The residential population was estimated from the US Census Bureau's internet site. General Accidental Release Prevention Program and Chemical Specific Prevention Steps SAL Chemical is an active member of the National Association of Chemical Distributors (NACD) and applies the NACD's strict principals for safe distribution of its chemicals. SAL Chemical also uses elements of an OSHA PSM program for chlorine operations. The PSM program contains twelve elements, including a hazard analysis, standard operating procedures, employee training, compliance audits, incident investigation, and management of change. In addition to the PSM program, SAL Chemical's chlorine manufactur er provides training to SAL Chemical employees on safe chlorine management every twelve to eighteen months. Five Year Accident History SAL Chemical has had no accidental releases of HF or chlorine in the past five years that resulted in on-site deaths, injuries, or significant property damage, or in known off-site deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place. Emergency Response Program SAL Chemical maintains a written emergency action plan that describes escape procedures, rescue and medical duties, and information on reporting emergencies. SAL Chemical's emergency action plan is coordinated with the Brooke-Hancock County LEPC and the Weirton Fire Department. Representatives from the Weirton Fire Department visit SAL Chemical annually to review the site layout and to update their emergency plans. Additionally, SAL Chemical's Operations Manager is a member of the Brooke-Hancock County LEPC. Planned Changes to Improve Safety SAL Chemical plans to continue its membership in the NACD and uphold the NACD's principles for safe distribution of chemicals. SAL Chemical will also continue providing training to its employees on the safe handling of regulated substances, and SAL Chemical's chlorine supplier will conduct safety meetings during 1999. SAL Chemical will also implement a new Health and Safety Manual in June 1999. |