Evans Harvey Corporation, L.L.C. - Executive Summary |
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Executive Summary Evans Harvey Corporation, L.L.C. 2800 Peters Road Harvey, Louisiana 2694 LDEQ Facility ID Number 1. Accidental Release Prevention and Emergency Response Policies We at Evans Harvey are committed to employee, public and environmental safety. This commitment is inherent to our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled The Evans Harvey facility's primary activities are repackaging and warehousing of chemicals. Evans either repackages or warehouses up to 8 regulated substances at our facility. These subst ances are listed below. Evans receives the regulated substances in bulk and packages the products for customer distribution. Drummed products are either warehoused or shipped depending on customer specifications. Inventory is dependent upon customer orders and not all regulated substances are present onsite at a given time. Chemical CAS No. Toxic Substances: Acrylonitrile 107-13-1 Hydrazine 302-01-2 Toluene 2,4 diisocyanate 584-84-9 Toluene 2,6 diisocyanate 91-08-7 Toluene diisocyanate 26471-62-5 Flammable Substances (Liquid Form): Teimethylamine 75-50-3 Dimethylamine 124-40-3 Isopropylamine 75-31-0 Ethylamine 74-04-7 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario Evans is the operator of a stationary source that has more than the threshold quantity of a regulated substance in a process, as determined under 40 CFR 68.115 and therefore is subject to 40 CFR Part 68 - Chemical Accident Prevention Provisions. Evans is a Program 2 level facility because the processes covered under RMP are not subject to the OSHA process safety management standard, 29 CFR 1910.119. To evaluate the worst case and alternative scenarios, Evans used EPA's program RMP*Comp to calculate the off-site consequences. RMP*Comp is based on the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. Scenarios for Toxic Substance s The worst-case release scenario submitted for toxic substances as a class involves a catastrophic release of Hydrazine. The scenario involves the release of 27968 lb. of Hydrazine in a liquid form over 60 minutes. The release is completely contained within a diked area. Evaporation from that pool within the dike occurs over 60 minutes. Calculations take into account the worst case weather conditions (stable, low wind speed) in an urban setting, and are calculated to a toxic endpoint of 0.011 mg/l. One alternative release scenario is submitted for each toxic substance that may be present in Program 2 processes cumulatively. Inventory is dependent upon customer orders and not all regulated substances are present onsite at a given time. The alternative release scenario for Hydrazine involves a release from a transfer hose failure while loading or unloading from a rail car. The scenario involves the release of 1480 lb. of Hydrazine. It is assumed that the release takes place fo r 60 minutes before it is brought under control. Secondary containment at the loading dock is used to confine the size of the toxic liquid pool, from which surface evaporation takes place over 60 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves to control the release. These active mitigation controls are expected to limit the extent of the spill and reduce the amount released by 95%. Calculations are based on the most common weather conditions, in an urban setting and are calculated to a toxic endpoint of 0.011 mg/l. The alternative release scenario for Acrylonitrile involves a vessel release from a leaking drum. The scenario involves the release of 360 lb. of Acrylonitrile. It is assumed that the release takes place for 60 minutes. Passive mitigation controls such as enclosure within the warehouse, drains and sumps ar e taken into account to calculate the scenario. These mitigation controls are expected to limit the extent of the spill and reduce the amount released by 99%. Calculations are based on the most common weather conditions, in an urban setting and are calculated to a toxic endpoint of 0.076 mg/l. The alternative release scenario for Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl] involves a release from a transfer hose failure while loading or unloading from a rail car. The scenario involves the release of 2750 lb. of Toluene 2,4-diisocyanate. It is assumed that the release takes place for 60 minutes. The toxic liquid forms a pool, from which surface evaporation takes place over 60 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves to confine and control the release. Under the most common weather conditions, the maximum distance to the toxic endpoint of 0.007 mg/L of Toluene 2,4-diisocyanate is less than the distance to the nearest public receptor. The alternative release scenario for Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl] involves a release from a transfer hose failure while loading or unloading from a rail car. The scenario involves the release of 2750 lb. of Toluene 2,6-diisocyanate. It is assumed that the release takes place for 60 minutes. The toxic liquid forms a pool, from which surface evaporation takes place over 60 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves to confine and control the release. Calculations are based on the most common weather conditions, in an urban setting and are calculated to a toxic endpoint of 0.007 mg/l, which is less than the distance to the nearest public recept or. The alternative release scenario for Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl] involves a release from a transfer hose failure while loading or unloading from a rail car. The scenario involves the release of 2750 lb. of Toluene diisocyanate. It is assumed that the release takes place for 60 minutes. The toxic liquid forms a pool, from which surface evaporation takes place over 60 minutes. Passive mitigation controls such as drains and sumps are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include automatic shut off valves to confine and control the release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.007 mg/l of Toluene diisocyanate (unspecified isomer) is less than the distance to the nearest public receptor. Scenarios for Flammable Substances The worst case release scenario submitted flammable substances as a class involves a catastrop hic release of Ethylamine from the Warehouse. The scenario involves the release of 529,500 lb. of Ethylamine. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with the entire released quantity participating in a vapor cloud explosion. Under worst case weather conditions (stable, low wind speed), in an urban setting, the endpoint is calculated to 1-psi overpressure. The alternative release scenario submitted for flammable substances involves a release of Isopropylamine from a drum in the warehouse. The release is assumed to result in a pool fire. The scenario involves a 60-minute release of 305 lb. of Isopropylamine. It is assumed that the entire quantity is released as a pool. An ignition source reaches the pool, resulting in a pool fire. Passive mitigation controls such as enclosures and dikes are taken into account to calculate the scenario. The release is also controlled by active mitigation measures that include deluge system(s ) and fire monitors. Under neutral weather conditions, the endpoint is calculated to the distance from a pool fire to a radiant heat level that could cause second degree burns from a 40-second exposure (5 kilowatts/square meter). This maximum distance is less than the distance to the nearest public receptor. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Evans has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The repackaging and warehouse processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Evans is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Evans Harvey maintains a record of safety information that describes the chemical hazards, operating pa rameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The checklist method is used to carry out our process hazard analyses. The studies are undertaken by a team of personnel with experience in engineering and process operations and are revalidated on a regular basis or when there is a change in the process. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Evans maintains written standard operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after maintenance. The information is regularly reviewed and is readily accessible to oper ators involved in the processes. Training Evans has a training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with those processes. New employees receive training and are tested for competency before starting work. Refresher training is provided on a regular basis and more frequently as needed. Mechanical Integrity Evans carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure valves, hoses and piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a timely manner. Compliance Audits Evans will conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits will be carried out at least every 3 years and any corrective actions required as a result of the audits will be undertaken promptly. Incident Investigation Evans promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. 5. Five-year Accident History Evans has had an excellent record of preventing accidental releases over the last 5 years so that no accidental release has occurred during this period. 6. Emergency Response Plan Evans has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergenc y response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident return to wok procedure To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Since the implementation of the various elements of our accidental release prevention program, there have been no developments or findings that indicate the immediate need to improve safety at our facility. We have a continuous improvement policy in place that includes safety issues. 8. Certification Statement The undersigned certifies that to the best of their knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Denise Thorning Title: Environmental Manager Date signed: June 21, 1999 |