HASA Inc - Executive Summary |
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1 EXECUTIVE SUMMARY 1.1 Accident Release Prevention and Emergency Response Policies At HASA, Inc, protecting the environment is a high priority. Accident prevention is the preferred alternative. When a release occurs, we are committed to responding with the maximum of company resources and cooperate with local emergency response agencies. We will provide training and information, as requested, to local emergency response agencies. Corporate and management levels support complete compliance for all safety and environmental laws and are committed to implement a RMP plan and achieve plan goals. We encourage and require employee participation in chemical safety. 1.2 Facility Description and Regulated Substances Handled Hasa, Inc uses chlorine at its Eloy, Arizona facility. The chlorine is received in rail car quantities (180,000 lb.), above the 2,500 lb. regulatory threshold for chlorine. All processes that use the chlorine are classified as regulated process for purposes of the RMP ru le. For Hasa, Inc, only the sodium hypochlorite production process uses chlorine and is therefor regulated for RMP purposes. All other processes at Hasa, Inc do not use or have regulated chemicals above the regulatory thresholds. The sodium hypochlorite (bleach) manufacturing process reacts liquid chlorine with a sodium hydroxide solution to produce the bleach in a continuous flow reactor. The reaction is controlled and monitored under redundant automatic control monitored by an operator. The bleach is then sent to storage tanks. The bleach is packaged as needed or sold in bulk tanker quantities for water treatment. Typical water treatment customers use the sodium hypochlorite to treat swimming pools, potable water disinfection or treated sewerage disinfection. Hasa, Inc also packages other water treatment chemicals and inventories and ships others. 1.3 Worst Case Scenario Essentially, the EPA requires all processes to assume that the maximum quantity of the listed chemical is relea sed in 10 minutes. They do no allow credit for any active controls for mitigation of the release rates (i.e. automatic shutdown controls). For this facility, the worst case release quantity is 180,000 lbs. This value is the maximum quantity contained in a full railcar of chlorine as received from HASA's suppliers. For a 10-minute release period, the yields a release rate of 18,000 lb./minute of chlorine. EPA default conditions were used. Using specific guidance for liquid chlorine is found in the EPA document, Risk Management Program Guidance for Wastewater Treatment Plants, the distance to the toxic endpoint (3-ppm) for a 90-ton railcar of chlorine of 14 miles. Within this distance, HASA has identified numerous pubic receptors, and no environmental receptors. The program, Landview III, estimates the population within the affected area. For this worst case scenario, there are an estimated 4,751 residents within the 14-mile radius. 1.4 Alternate Scenario For this facility, the altern ative scenario is a liquid chlorine leak in process piping. This type of leak would most likely start small. It is estimated the most likely hole size will be equivalent 1/4-inch diameter. This size hole would be quickly detected by the plant operations personnel due to the odor, noise, and yellowish cloud. Also, any leaking valve packing, flange leak, or valve leak would, most likely, not leak at a rate greater than the 1/4-inch hole being modeled. The EPA document, Risk Management Program Guidance for Wastewater Treatment Plants, gives a release rate for liquid chlorine through a 1/4-inch hole to be 150 lb./minute (Exhibit 4-13). HASA has selected to use these weather conditions for the alternate release scenario. They are: Wind Speed 3 meters/sec Stability Class D Temperature 250 C (770 F) Relative Humidity 50% Using specific guidance for liquid chlorine is found in the EPA document, Risk Management Program Guidance for Wastewater Treatment Plants, the distance to the toxic endpo int (3 ppm) for a 150 lb./min leak of liquid chlorine is 0.2 miles. Within this distance, HASA has identified some pubic receptors, and no environmental receptors. The program, Landview III, estimates the population within the affected area. For this alternate case scenario, there is an estimated 1 resident within the 0.2-mile radius. 1.5 Accidental Release Prevention Program Hasa, Inc has prepared a comprehensive accidental release prevention program. The program topics include: 7 Hazard analysis 7 Operator training 7 Mechanical maintenance and inspections 7 Management of change 7 Pre-startup Review 7 Incident investigation 7 Contractor safety 7 Compliance audits 1.6 Five Year Accident History Hasa, Inc has not had any chlorine releases during the previous 5 years. 1.7 Emergency Response Program HASA has prepared an extensive emergency response program. The program includes an emergency response plan, training and coordination with local emergency response agencies and the Pinal County Local Emergency Planning Committee (Pinal LEPC). 1.8 Planned Changes to Improve Safety The process hazard analysis of the regulated process yielded three recommendations for further evaluation and consideration by HASA: 1. Replace the scrubber bubbler with a corrosion resistant material or begin an inspection program to identify bubbler failure. The current bubbler has failed an average of every 5 years. 2. Begin a procedure to check and adjust the scrubber caustic concentration on a routine basis. 3. Extend the scrubber discharge at least eight feet above ground. They will be completed within the required timetables. |