Sewell Products, Inc. - Auburndale Plant - Executive Summary |
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1. The primary goal of our Risk Management Program is to prevent or reduce the risk of accidental releases of substances that might expose employees, the public, or the environment to the hazards of toxicity, fire, or explosion. Our policy is to implement the prevention measures outlined in the Process Safety Management and Risk Management Program regulations by focusing on the standards, procedures, and practices which govern individual processes, activities, or equipment. As with any prevention program, one of the most important barriers to an incident is the performance and conduct of our people in integrating program requirements and safe work practices in their daily activities. 2. This facility manufactures private label household products including Bleach, Ammonia, and Fabric Softener. Chlorine, which is used to manufacture Bleach, is the only regulated substance at this facility subject to this Risk Management Program. Tank Cars delivered by rail are connected directly t o the plant's processing system. The maximum stored quantity of Chlorine on site is 360,000 pounds (2 full Tank Cars). 3. The Offsite Consequence Analysis was conducted using EPA's computer model "RMP*Comp." The worse-case release scenario (as structured by the regulation) is the failure of a single Tank Car containing 180,000 pounds of Chlorine with a 10 minute release. The probability of this scenario is extremely low based on the construction standards, safety features and rigorous inspection/testing program that are incorporated into these Tank Cars. The alternate release scenario chosen is a pipe leak equivalent to a flow rate just under the Tank Car's excess flow check valve limit (250 pounds/minute) with a 10 minute release. The release rate in this alternate scenario is considered the most conservative in a class of credible events for the following reasons: Most leaks, should they occur, would be a small fraction of this value and either manually or automatically isolat ed within several minutes. If a large pipe leak did occur, it would more likely result in actuation of the excess flow check valve which would immediately and automatically terminate the release. 4. In addition to having a well trained, knowledgeable, and experienced staff that operate and conduct maintenance on this system, the prevention program at this facility combines a proactive approach toward ensuring mechanical integrity and operational safety with a defense-in-depth philosophy in the system's design features. For example, daily checks are made on the piping systems that transport the Chlorine from the Tank Car to the processing system. Any deficiencies found are immediately corrected. At the end of each day, the Chlorine system is isolated and supply lines drained through a scrubber system to ensure no residual pressure during non-operational periods. The valves on the Chlorine Tank Cars are inspected by the vendor after each return delivery and refurbished every 6 mon ths. From a design standpoint, air operated shutoff valves installed at the Tank Car outlet will automatically shut if a leak is detected by perimeter Chlorine monitors or if the Tank Car is inadvertently moved enough to actuate quick disconnects on the valve's instrument air supply. The processing system also utilizes shutoff valves that automatically close if Chlorine supply pressure becomes too low (responds to possible leak upstream) or if the mixture in the process is out of specification. Expansion chambers isolated by rupture discs are installed to mitigate any unanticipated pressure increase prior to exceeding design pressure of piping components. A Safety relief valve installed on the Tank Car provides additional protection to overpressure events when the system is in service . A plant program document has been developed that outlines the facility's implementation of the regulations associated with chemical safety and risk management. 5. There have been no accidents at this facility involving the Chlorine unloading system. A review of the 5 year history also reveals that any minor incidents involving this system have resulted in less than the reportable quantity. 6. The facility has an emergency response program that includes joint training with the local Fire Department/Hazardous Response Team, special training for employees on site to prepare them for response to an accidental release, and a plan for evacuation of the facility and notification of authorities in the event of an emergency. 7. Based on the most recent Process Hazard Analysis, no major improvements are planned. Some minor improvements are planned that include the addition of an audible alarm connected to the actuation of the perimeter Chlorine monitors, and more rigorous checks on the scrubber system. |