Sierra Chemical Co., Sparks - Executive Summary |
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The Accidental Release Prevention and Emergency Response Policies at the Facility: Sierra Chemical Co. relies on the Occupational Safety and Health Administration (OSHA) 29 CFR 1910.119 Process Safety Management Standard and the OSHA 29 CFR 1910.120 Hazardous Waste Operations and Emergency Response Standard to establish policies in its efforts and commitment to prevent accidental releases of highly hazardous materials through prevention and emergency reponse. Additionally, this new regulation, 40 CFR Part 68 Chemical Accident Prevention Program, Risk Management Plan, will further enhance Sierra Chemical Co. commitment to risk management. Facility and Regulated Substances Handled: Sierra Chemical Co., Sparks Facility, consists of three operations involving highly hazardous materials. The first operation is a chlorine transfer and sodium hypochlorite manufacturing (bleach) process. Chlorine is received at the facility via 90 ton railcars. There is typically one railcar and a numbe r of filled small packagings on site for a total of 202,150 pounds. It is repackaged into 17 ton tank trucks, 1 ton containers, and 150 pound cylinders. Additionally, the facility manufactures sodium hypochlorite (bleach) utilizing chlorine as a reactant. The second operation is a sulfur dioxide transfer and sodium bisulfite manufacturing process. Sulfur dioxide is received at the facility via 90 ton railcars. There is typically one railcar and a number of filled small packagings on site for a total of 196,400 pounds. It is repackaged into 17 ton tank trucks, 1 ton containers, and 150 pound cylinders. Additionally, the facility manufactures sodium bisulfite utilizing sulfur dioxide as a reactant. The third operation is a anhydrous ammonia container handling and storage process. Anhydrous ammonia containers, 1730 pound skid tanks and 150 pound cylinders, are received at the facility and stored pending delivery to consumers. Typical inventory of anhydrous ammonia is 16,990 pound s. The Worst-Case Release Scenario and the Alternate Release Scenarios: Because sulfur dioxide and chlorine are received at the facility via 90 ton railcars, complying with Department of Transportation regulations, the worst-case scenario for the facility would be the release of the contents of 1 railcar. This scenario was chosen based on the requirements contained in 40 CFR Part 68. However, in contrast to the required worst-case release scenario, Sierra Chemial Co. chose the failure of a 1 inch flexible transfer line for the alternate release scenario for both products. This scenario was chosen because with the exception of the railcar and the flexible transfer line, all other process components handling chlorine and sulfur dioxide are located inside an enclosure equipped with a fume scrubber. Furthermore, through actuated valves located on both the railcar and the process side of the flexible transfer line and detectors located at the railcars interlocked with the actuated val ves, it was estimated that the flow of chlorine or sulfur dioxide could be stopped within 1 minute. Modelling for all scenarios was completed utilizing RMP*Comp, Version 1.06, as provided by EPA. Modelling for the worst-case release scenario demostrated potential off-site impacts to residential, schools, hospitals, county and city parks, national forest, and industrial facilities. In contrast, modelling for the alternate release scenarios demostrated potential off-site impacts to adjacent industrial facilities only. For the anhydrous ammonia container storage and handling, the alternate release scenario was chosen as a leaking valve on a 1730 pound skid tank that took response personnel 180 minutes to mitigate. Modelling for this alternate release scenario demonstrated potential off-site impacts to adjacent industrial facilities only. The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps: Sierra Chemical Co. achieves accidental release prevent ion through the following programs. OSHA Process Safety Management Guidelines (Sierra Chemical Co. Document HS180.10), Accident Prevention Program (Sierra Chemical Co. Document HS105), and the Sierra Chemical Co. Workplace Audit and Compliance Audit programs. The Five-Year Accident History: Sierra Chemical Co., Sparks Facility, has had one accident as defined in 40 CFR Part 68. The accident took place on November 11, 1996 and resulted in the injury of one plant employee and a release of chlorine estimated at 1.12 pounds. The Emergency Response Program: Sierra Chemical Co., Sparks Facility, has a written emergency response plan (Sierra Chemical Co. Document HS150.20) prepared pursuant to 29 CFR 1910.120(q). Applicable plant personnel receive annual training including drills. Additionally, a copy of the emergency response plan has been furnished to the Local Emergency Planning Committee. Planned Changes to Improve Safety: Sierra Chemical Co. strives to mprove safety by imple mentation of the OSHA Process Safety Management Standard (including compliance audits every three years and process hazards analysis revalidation every five years) and an employee safety committee. |