Sivento, Inc. - Executive Summary |
|
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Sivento, Inc. has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. Sivento, Inc. has a nine-point policy guiding the accidental release prevention program. These are: 1) Use applicable design safety codes and standards as the basis for design, construction, operation, and maintenance in our facilities. 2) Evaluate facilities, equipment and processes for safety and health concerns. 3) Use multiple safeguards to provide layers of protection in the design, construction and operation of facilities to prevent a single fail ure escalating into a catastrophic event. 4) Document the safety and health evaluation. 5) Inspect and evaluate process equipment against the design specifications. 6) Maintain current and complete documentation of the process and equipment throughout the lifetime of the process. 7) Develop a Management of Change procedure to control minor changes to process technology, operation and maintenance that may affect the safety of the process. 8) Review all changes to process equipment, procedures and practices to ensure the continued safety of employees and facilities. 9) Develop inspection and maintenance programs that ensure the continued integrity of facilities. Sivento, Inc. has a nine-point policy guiding the emergency response program. These are: 1) Determine what potential emergency situations could occur, i.e., employee injury, fire, explosion, flood, cold weather, loss of electrical power, gas/chemical release, etc. 2) Develop written procedures for potential emergencies outlini ng personnel responsibilities, emergency information and equipment. 3) Assign personnel to the emergency positions or tasks specified in the written procedures. 4) Provide appropriate emergency response equipment and ensure that it is periodically inspected. 5) Train emergency personnel to respond to emergencies in accordance with the written procedures. 6) Periodically conduct simulated emergency drills. 7) Review emergency procedures with all employees at least annually. 8) Review emergency procedures whenever there are significant changes in personnel, operations, or plant layout; or at least annually and update as necessary. 9) Document emergency procedure reviews and updates, including the date of the review. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTAN CES Sivento, Inc. Mobile Plant is located in the Theodore Industrial Park in Theodore, Alabama on a 1,000 acre site shared with Creanova, Inc. This facility employs 30 personnel. Seven production areas produce 12 products in a continuous production schedule, operating 24 hours per day, 7 days a week. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: dimethyldichlorosilane, hydrogen chloride, methyltrichlorosilane, acetylene, trichlorosilane, ethylenediamine, hydrogen sulfide, trimethylchlorosilane and ethyl ether. RELEASE SCENARIOS The worst-case scenario (WCS) associated with substances in Program 3 processes at the site is a catastrophic failure of one storage tank containing 190,000 pounds of hydrogen chloride over a 10-minute period forming a vapor cloud. Administrative procedures and equipment interlocks prevent the chlorine storage tank fr om containing over this amount. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this scenario. According to EPA's look-up tables, the release would reach offsite endpoints such as public and environmental receptors. The WCS associated with a release of flammable substances in Program 3 processes at the site is a catastrophic failure of one tank trailer containing 10,000 pounds of acetylene over a 10-minute period forming a vapor cloud which subsequently explodes. Administrative procedures and equipment interlocks prevent the acetylene tank trailer from containing over this amount. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this scenario. According to EPA's look-up tables, the 1 psi overpressure boundary from the explosion would not re ach offsite and would not reach any public or environmental receptors. The ARS for dimethyldichlorosilane is from a hole in a transfer hose while transferring dimethyldichlorosilane from a tank trailer to a stationary trailer. The hole could release of 720 pounds of gas over a 3 minute period. The 3-minute release duration is the approximate time necessary to detect the leak, close the emergency shut-off valve and deluge the vapors with fire water to control the vapor release. No other mitigation measures were taken into account in evaluating this scenario. This release has the potential to reach offsite but the only public or environmental receptors reached above the toxic endpoint defined by EPA would be the adjacent industrial plant. The ARS for hydrogen chloride is from a failure in the flex hose on the hydrogen chloride weigh tank. The hose could release 4,000 pounds over a 10-minute period. The 10-minute release duration is the approximate time necessary for the tank to empt y. No other mitigation measures were taken into account in evaluating this scenario. This release has the potential to reach offsite and reach public or environmental receptors above the endpoint defined by EPA. The ARS for hydrogen sulfide is from a failure in the piping from the storage tank trailer to the process weigh tank. The hole could release 530 pounds over a 2 minute period. The 2-minute release duration is the approximate time until the excess flow valve on the storage tank trailer stops the flow. No other mitigation measures were taken into account in evaluating this scenario. This release has the potential to reach offsite but the only public or environmental receptors reached above the toxic endpoint defined by EPA would be the adjacent industrial plant. The ARS for ethylenediamine is from a leak in the discharge of a storage tank. The hole could release 6,8000 pounds over a 30 minute period. The 30-minute release duration is the approximate time necessary to detect the leak and shutdown the storage tank pump. No other mitigation measures were taken into account in evaluating this scenario. This release does not have the potential to reach offsite above the endpoint defined by EPA. The ARS for methyltrichlorosilane is from a hole in the unloading hose during the transfer from a tank trailer to a storage railroad car. The hole could release 6,000 pounds over a 20-minute period. The 20-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release has the potential to reach offsite and reach public or environmental receptors above the endpoint defined by EPA. The ARS for trimethylchlorosilane is from a hole in the unloading hose during the transfer from a tank trailer to a storage tank. The hole could release 590 pounds over a 3-minute period. The 3-minute release duration is the approxim ate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release does not have the potential to reach offsite above the endpoint defined by EPA. The ARS for acetylene is from a hole in the transfer line from the tank trailer to the process. The hole could release 600 pounds over a 5-minute period forming a vapor cloud which subsequently explodes. The 5-minute release duration is the approximate time necessary to detect the leak, depressurize the line and thus stop the release. No other mitigation measures were taken into account in evaluating this scenario. This release does not have the potential to reach offsite above the endpoint defined by EPA. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The prevention program used by the facility is consistent with the Occupational, Safety and Health Administration's Process Safety Management Standard. The standard includes management systems elements involving safety information, hazard evaluations, operating procedures, employee training, contractor programs, mechanical integrity, pre-start up safety reviews, incident investigations, safe work practices and emergency response. There are a number of chemical specific prevention steps used at the facility including release detection equipment, release containment, and release control equipment. FIVE-YEAR ACCIDENT HISTORY Sivento, Inc. has an excellent record of accident prevention over the past 5 years. We have no incidents in the last five years that meet the RMP reporting requirements. EMERGENCY RESPONSE PROGRAM INFORMATION Sivento, Inc. maintains a written emergency response program. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper f irst-aid, medical treatment, evacuation plans, and notification of local emergency response. The overall emergency response program for Sivento, Inc. is coordinated with the Mobile Fire Department and the Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. Sivento, Inc. has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, Sivento, Inc. conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. PLANNED CHANGES TO IMPROVE SAFETY Sivento, Inc. resolves all findings from process hazards analysis, some of which result in modifications to the process. The following types of changes are planned: increase process controls & modify procedures. |