Fabricolor Manufacturing Corporation - Executive Summary |
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Executive Summary of Risk Management Plan Fabricolor Manufacturing Corporation 24 1/2 Van Houten Street Paterson, NJ 07505 Fabricolor Manufacturing Corporation manufactures organic dyes and pigments in the historic textile and dye manufacturing district of Paterson, NJ. One process produces pigments using 20% oleum (a mixture containing 20% by weight of the more volatile chemical sulfur trioxide in non-volatile sulfuric acid) as a reactant for sulfonation. The OSHA Process Safety Management (PSM) standard does not regulate 20% oleum, but Fabricolor is classified as a major facility under the New Jersey Spill Act regulations, and has developed and implemented a Discharge Prevention, Containment and Countermeasures (DPCC) and a Discharge Cleanup and Removal (DCR) Plan which applies to 20% oleum and other chemicals handled at the facility. The DPCC/DCR Plan was developed and implemented in 1994, and is reviewed, revised and resubmitted to the Bureau of Discharge Prevention (BDP) of t he New Jersey Department of Environmental Protection (NJDEP) every three years; this was done in 1997. The BDP conducts a site inspection and review of records required by the DPCC/DCR Plan each year. DPCC/DCR Plan elements which are also applicable to the RMP include the following: standard operating procedures; preventive maintenance/ mechanical integrity; operator training; recordkeeping; assessment of and protection planning for environmentally sensitive areas; and an emergency response plan which includes employee training and drills. Additional elements required by the RMP have been developed and implemented. In preparation for the RMP, Fabricolor contracted Process Safety Engineering, Inc., in 1998 to perform a HAZOP hazard analysis and safety review of the handling of 20% oleum at its facility. Recommendations from this have all been addressed by management. Risk reduction measures include the following: --Use of 20% oleum, a mixture which is inherently safer than more c oncentrated grades of oleum (e.g., 65% oleum); this was confirmed in a report to Fabricolor by Process Safety Engineering, Inc., which focused both on accident history (no injuries or offsite consequences for mixtures below 35% oleum have been reported) and on inherent properties of oleum mixtures (the vapor release rate for 30% oleum, an even stronger grade than that used by Fabricolor, is 35 times less than that for 65% oleum). --No 20% oleum storage tank is used; rather, the oleum needed is brought by tank truck, then unloaded immediately and directly into a reactor, and used within 24 hours. The fact that no 20% oleum inventory will be on site at the turn of the millenium leads us to project that there will be no Y2K concerns. --A dike is used to limit the spread area of a potential spill while unloading a tank truck of 20% oleum. --Production of pigments using 20% oleum takes place in a completely enclosed building, which would limit the release rate to the a ir of any spill. --A 75 psi rupture disk protecting the sulfonation reactor has been replaced with a 40 psi rupture disk, as recommended in the hazard analysis conducted by Process Safety Engineering, Inc. The worst-case release (WCR) and alternative release scenario (ARS) were developed in conjunction with Roy F. Weston, Inc. For both cases, the EPA Offsite Consequence Analysis (OCA) Guidance Tables and Equations were used to estimate the potential distances affected downwind by an airborne plume of sulfuric acid mist from the 20% sulfur trioxide in the oleum. The WCR involves the release of 20,000 lbs. of 20% oleum from the sulfonation reactor; the rate of emission to the environment would be limited by the building enclosure, resulting in an endpoint distance of 0.19 mile. One school (P. S. 2) is within this distance, as well as a city park/recreation area across the street from the plant. The ARS involves the release of 4700 lbs. of 20% oleum over a ten minute period from a 1/2 inch hole in the unloading hose from the tank truck; the rate of emission to the environment would be limited by the 150 square foot area of the unloading dike, resulting in an endpoint distance of 0.06 mile. The school and park are not within this distance. This information has been presented to the Director of the Paterson Office of Emergency Management (OEM). In addition to the those already mentioned, accidental release prevention and chemical-specific prevention measures include provision for manual venting of the sulfonation reactor to a scrubber, and an interlock to shut off the feed of the chemical being sulfonated if the reaction temperature exceeds a set point. Preventive maintenance includes weekly inspections of the 20% oleum unloading line between the tank truck and the reactor, as well as annual inspection and testing of the sulfonation reactor. There have been no accidental releases involving 20% oleum during the past five years. Fabricolor's emergency respons e program has been updated to conform to the EPA Integrated Contingency Plan ("One Plan") Guidance and presented to local emergency responders (OEM, Police and Fire Departments, Sheriff's Department Hazardous Materials Team, Passaic County Department of Health), as well as to local hospital emergency personnel. Additional community input in preparation for an emergency response drill is being planned. |