SCC Chemical Corporation - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
SCC Chemical Corporation has an emergency action plan in effect. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. This Plan was designed to meet the following objectives:
1.) To save lives.
2.) To minimize and avoid injuries.
3.) To protect the environment.
4.) To minimize property damage.
SCC Chemical Corporation maintains a safety committee whose members are the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, chlorine health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations.
STATIONARY SOURCE AND REGULATED SUBSTANCE
Startup of the chlorine system occurred in 1981. The process is located at 1920 Riverview Drive in San Bernardino, California. The chlorine transfer process for SCC Chemical consists of chlorine one-ton containers which are the storage vessels. Chlorine liquid is dispensed from the one ton container through a filling manifold to a 20 pound cylinder. The 20 pound cylinders are then used off-site to treat swimming pools. The transfer system is equipped with a caustic scrubber tank to neutralize any chlorine residual in the piping once the transfer process is complete, thereby preventing the chlorine gas from escaping to the atmosphere.
The maximum quantity of chlorine on site is six one ton containers or 12,000 pounds of chlorine.
HAZARD ASSESSMENT SUMMARY
Worst Case Release Result Summary
The worst case release for this facility was that of the maximum quantity of chlorine that can be stored in the largest vessel in 10 minutes. The largest vessel at this facility is a one t
on chlorine container which holds a maximum of 2,000 pounds of chlorine. This vessel is stored outside, therefore, no passive mitigation measures were used. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed and F stability. The facility is located in an urban setting. The reference table, Exhibit 4-4, from EPA's RMP Guidance for Wastewater Treatment Plants was used to find the potential downwind distance to 3 ppm as a result of this worst case release scenario. The release reaches off-site and may affect population receptors. No environmental receptors were affected by this potential release scenario.
Alternative Release Result Summary
The alternative release was that of a 1/4 inch diameter leak from a pipeline containing liquid chlorine. Based on the pressure in the tank, the release rate was calculated to be 50 pounds/minute. Since there is no accident history at this facility, this release scenario was based on the possibility of a leak i
n the pipeline or a flange seal leak (note that the one-ton line is 1/4 inch) that continues until the tank is empty. The meteorological conditions used were 3 meters/second wind speed, and D stability. The facility is located in an urban setting. The reference table, Exhibit 4-12, from EPA's RMP Guidance for Wastewater Treatment Plants was used to find the potential downwind distance to 3 ppm for the alternative release scenario. This release reaches off-site and may affect population receptors. No environmental receptors were affected by this potential release scenario.
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
SCC Chemical has a Process Safety Management program in place to manage the handling of chlorine. In addition, common industry standards, policies, and procedures are utilized to ensure safe practices are being performed. This includes common practices outlined by the Chlorine Institute and the National Association of Gas Chlorinator
In addition, the chlorine repackaging process is only operational one hour per day, four days per week. While the transfer process is not in operation, all chlorine tank valves are closed. Only two facility personnel are trained to operate the transfer process.
Finally, the chlorine containers are surrounded by an R-2 Fire Wall.
FIVE YEAR ACCIDENT HISTORY
There have been no reported releases of chlorine at this facility over the last five years since June 1994.
EMERGENCY RESPONSE PROGRAM
SCC Chemical has a Hazardous Materials Business Plan in effect at the facility and on file with the San Bernardino County Fire Department. The facility works closely with the local fire department and All Pure Chemical, the chlorine supplier. The facility plans to contact 9-1-1 in the event of an emergency. In addition, All Pure Chemical is available to respond to a release of chlorine.
The facility has three full time employees on site. The President is designated as the Emergency Coor
dinator in the event of an emergency. In the event of a release of chlorine, the personnel will evacuate out the front of the building, opposite of the hazard, contact 9-1-1 and their neighbors in the building.
PLANNED CHANGES TO IMPROVE SAFETY
The Hazard Analysis, Hazard Assessment, and External Events Analysis studies provided the mitigation measures outlined below to improve safety at SCC Chemical facility. The recommendations are scheduled to be implemented on or before December 1999.
Process Hazard Analysis Recommendations
R01: Review the operating procedures to ensure that they are an accurate representation. Review the operating procedures annually and certify that they are accurate. Use the operating procedures to train new employees.
R02: Certify the two trained fill operators using the Senior Operator form included in the Training section of the PSM/RMP manual.
R03: Add "warning" to the operating procedures to alert operators that they need to be prepared to stop th
e transfer process sooner when the ambient temperature is in excess of 100 F.
R04: Add warning to operating procedures that Vent Valve should be closed during transfer process.
R05: Post the Fire Department diamonds.
R06: Relocate the escape mask closer to the filling area (either outside or just inside the garage roll-up door).
R07: Relocate the B-kit closer to the filling area (either outside or just inside the garage roll-up door).
R08: Consider adding flow direction arrows and line contents labels in the event the facility hires new operators who are not familiar with the design/operation of this system.
R09: Conduct an informal inspection of the one ton containers that are delivered. This should include the general condition, currency of hydrostatic test, and valve protective housing.
R10: Include a copy of the Superior Valve Company specification sheet in the Process Safety Information Section of the PSM/RMP Manual.
R11: Review the secondary containment requirements fo
r the spare caustic tank.
R12: Post an evacuation map along with the emergency telephone numbers.
R13: Consider having a second escape mask located in the office area.
R14: Have employees sign a certification that they have reviewed and understand the emergency response plan / business plan.
External Events/Seismic Recommendations
S01: The one ton containers should be resting on a non-flammable support. Typically, individual "cradles" are used for each container. This support should be properly anchored to the ground. Each container should be secured using two nylon "Kevlok" straps which use a "come-along" buckle to ensure that the strap is tight (520-881-2130). Typically, these straps are rated at 5000 pounds. Two chains can be used to secure each container, but they must be kept tight around the container.
S02: The Compressed Gas Association Recommended Practice PS-6 allows for nesting of vertical cylinders such as the 20 pound cylinders. The nesting should be 3-4 cylinder
s deep and no more than 10 cylinders long. A nylon "Kevlok" strap with a "come-along" buckle should be sued around the center of the nested cylinders.