FEDERAL-MOGUL BLACKSBURG - Executive Summary |
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Federal-Mogul Blacksburg is a facility that manufacturs powertrain journal bearings. Casting, machining, and electroplating operations all take place within the plant. The facility is permitted to process 360,000 gallons of wastewater per day, most of which is generated by electroplating operations. Chlorine and sulfur dioxide are used at the facility in the cyanide destruct and chrome reduction processes, respectively. Accidental release prevention / Emergency response policies: Federal-Mogul Blacksburg takes great care in preventing accidental releases. The facility is subject to OSHA 29 CFR 1910.119 Process Safety Management, EPA Part 68 Risk Management Plan, and it's own Consolidated Emergency Response Plan (BB-SFENV-30-4). In addition to the consolidated emergency response plan, Process Safety and Risk Management compliance manuals have been completed. These three manuals summarize the accidental release prevention techniques in place as well as emergency response policies a t Federal-Mogul Blacksburg. Stationary Source: Federal-Mogul Blacksburg Regulated Substances: Chlorine and Sulfur Dioxide Worst-case Release Scenario: One worst-case scenario, estimated to create the greatest area within the radius of the toxic endpoint, is defined for the release of a one ton chlorine container over ten minutes. This scenario uses chlorine instead of sulfur dioxide because the radius of exposure of chlorine encompasses that of sulfur dioxide. The passive mitigation of the chlorine system consists solely of the fact that the ton containers are enclosed in a separate building from the plant. The greatest distance to the toxic endpoint is 0.9 miles. This value was calculated for chlorine using RMP*Comp Version 1.06. Alternative Release Scenarios: Four alternative scenarios were reviewed, two for chlorine gas and two for sulfur dioxide gas. These scenarios are more likely to occur than the worst-case scenario. The alternative scenarios were chosen for possible piping and cylinder releases. The first alternative scenario is a release from the piping directly attached to a ton container of chlorine. Using RMP*Comp Version 1.06, the radius of toxicity is calculated to be 0.1 miles. The second alternative scenario is a release from the piping directly attached to a ton container of sulfur dioxide. Using RMP*Comp Version 1.06, the radius of toxicity found is 0.1 miles. The third alternative scenario is a release from the process piping of the flowing chlorine. Using RMP*Comp Version 1.06, the radius of toxicity is 0.1 miles. The fourth alternative scenario is a release from the process piping of the flowing sulfur dioxide. Using RMP*Comp Version 1.06, the radius of toxicity is 0.1 miles. Accidental Release Prevention Program: Federal-Mogul Blacksburg is in compliance with OSHA's Process Safety Management (29 CFR 1910.119) and EPA's Risk Management Plan (40 CFR Part 68) regulations and has had no significant release during its 25+ year existence. On-s ite emergency coordinators and trained hazardous material responders regularly meet and practice to maintain their skills. In addition, response agreements are maintained with a variety of outside responders to handle any emergency that is beyond the capabilities of the on-site emergency teams. Various safeguards are present on both the chlorine and sulfur dioxide systems. These include alarms to detect any leakage of these gases or malfunction of the systems. All malfunctions are relayed to our employees via alarms located throughout the building. Either system can be shut down quickly should a problem occur to minimize any potential release. Five-year Accident History: On December 28, 1998, a pump malfunctioned causing the system to discharge excess chlorine into the cyanide treatment tank. The waste water operator quickly shut the system off, but was exposed, via inhalation, to residual chlorine venting from the tank. The employee was sent to the hospital for assessment an d was released to go home shortly thereafter and to return to work the following day. A minimal amount of chlorine was released from the cyanide destruct system. On February 20, 1995 two employees were injured slightly due to a chlorine release. One inhaled chlorine, and the other suffered a minor burn. The incident occurred because one employee was not familiar with the current chlorine system. A minimal amount of chlorine was released, estimated to be no greater than one pound. Emergency Response Plan: The Consolidated Emergency Response Plan (BB-SFENV-30-4) contains all the information regarding emergency response at Federal-Mogul Blacksburg. The CERP addresses security, a description of the plant and its operations, material handling procedures, emergency personnel responsibilities and training, outside responders, emergency response procedures, emergency and pollution prevention systems, and documentation of response operations. These topics are discussed at length. In som e cases, a more detailed discussion is contained in the Process Safety Management Manual (maintained as per 29 CFR 1910.119). Planned Changes: There are no planned changes to the safety systems of either the chlorine or sulfur dioxide systems beyond routine maintenance and replacement. Both of these systems are proven safe and effective. Future changes to either system will be implemented as warranted to maintain a high standard of safety. |