HVC Inc. - Executive Summary
General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities |
1. Accidental Release Prevention and Emergency Response Policies
We at HVC Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass Chemical distribution.. We have 2 regulated substances present at our facility. These substances include Chlorine and Sulfur dioxide (anhydrous). Both substances are stored on-site until shipment to our customers, typically water and wastewater treatment plants.
3. The Worst Case Release Scenario(s) and
the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To evaluate the worst case scenarios, we have used Chlorine Institutes pamphlet 162 and Safer. For alternative release scenario analyses we have employed the EPA's OCA Guidance Reference Tables or Equations and Chlorine Institute's pamphlet 162. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Chlorine container storage. In this scenario 2000 lb. of Chlorine is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. Passive mitigation systems such as enclosure(s) are also taken into account to calculate the scenario. These mitigation systems have the effect of reducing the rate of rel
ease. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 6.7 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.
The alternative release scenario for Chlorine involves a release from Chlorine container storage. The scenario involves the release of 150 lb. of . Chlorine liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 3.2 minutes. Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario, having the effect of reducing the rate of release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 1.1 miles.
The alternative release scenario for Sulfur dioxide (anhydrous) involves a release from Sulfur dioxide storage. The scenario involves the release of 150 lb. of . Sulfur dioxide liquid is assumed to be released to form a 1 cm deep pool from whic
h evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario, having the effect of reducing the rate of release to the atmosphere. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 0.43 miles.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
HVC Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analy
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What If. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every three years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 08/06/1998.
For the purposes of safely conducting activities within our covered processes, HVC Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
c. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every two years and more frequently as needed.
HVC Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at HVC Inc. to manage changes in process chemicals, technology, equ
ipment and procedures. The most recent review/revision of maintenance procedures was performed on 11/17/1998. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at HVC Inc.. The most recent review was performed on 05/04/1997. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
HVC Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 05/14/1999. These audits are carried out at least every 3 years and any cor
rective actions required as a result of the audits are undertaken in a safe and prompt manner.
HVC Inc. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
HVC Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduc
t specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. HVC Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-year Accident History
HVC Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period.
6. Emergency Response Plan
HVC Inc. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well
as post-incident decontamination of affected areas.
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
Anderson County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.
7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Improved training of all employees and minimization of inventory are some of the major steps we took to improve safety at our facility.