EMPAK, Incorporated - Executive Summary |
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GENERAL DESCRIPTION OF FACILITY EMPAK, Incorporated, Deer Park has two basic operations: a commercial hazardous waste management facility and a railcar cleaning facility. The EMPAK Disposal Facility is a commercial treatment, storage, and disposal facility, which utilizes biological waste treatment, physical-chemical treatment, dewatering, filtration, solidification, fixation and deepwell disposal processes. As a hazardous waste management facility, EMPAK eliminates or minimizes the hazardous characteristics and the amount of hazardous substances from streams that might otherwise have contributed to harming the health of the community or contaminating the environment. The EMPAK Railcar Cleaning Facility is a service operation, which purges, cleans, and sandblasts railcars. In providing the railcar cleaning service for surrounding industries, EMPAK provides a safe means for cleaning railcars. All wastes generated from the railcar cleaning processes are sent through the EMPAK Disposal Facility for safe and environmentally sound disposal. After reviewing and analyzing the wide variety of chemicals received at EMPAK, only the Railcar Cleaning Facility falls under the requirements of 40CFR68 or the Risk Management Plan regulations. Therefore, the majority of the Executive Summary will deal with the Railcar Cleaning Facility. PROCESS DESCRIPTION FOR RAILCAR CLEANING FACILITY The cleaning process for a railcar begins with Customer Service Department. After Customer Service Department discusses the railcar and the contents of the railcar with the Railcar Manager, the contents of that railcar are then determined to meet the safety and regulatory criteria of the facility. The railcar's content will be checked against or added to a Primary / Secondary Approved Chemical List. The Primary / Secondary Approved Chemical List signifies that the treatment of the chemical, cleaning procedures, disposal requirements and safety provisions for a particular chemi cal have been established or are in the process of being developed. No chemical is accepted for cleaning until this process has been completed. After a chemical has been added to the Primary / Secondary Approved Chemical List, the Process Control and Inquiry (PC&I) form is completed to address and develop written procedures for cleaning the railcar, disposing of the waste, and providing adequate personal protective equipment. The PC&I informs the operator of the necessary controls, such as the thermal oxidizer, the caustic scrubber, or the flare, for vapor emissions and for personal protection. The PC&I is reviewed by technical superintendent, corporate environmental, the Safety and Health Coordinator, the Railcar Manager and the Disposal Manager. Each PC&I is chemical specific. Thus allowing EMPAK to provide the best means for protecting the health and safety of our employees, guarding against any impact to our community and eliminating any contamination to our environment. Whe n the PC&I has been completed and approved, the railcar is allowed on the facility site for cleaning. All railcars are weighed before acceptance for railcar cleaning. At the small chance of a full railcar arriving at the site, the customer and Union Pacific are notified to remove the railcar immediately. If the railcar contains a product heel, EMPAK notifies the customer to determine the return of the product heel. The product heel becomes a waste at the time the customer declines the return of the heel. EMPAK then becomes the generator of that waste. More often than not the heel is returned as product. During the cleaning process, the PC&I, the Work Order and the Material Safety Data Sheet or General Waste Profile remain with railcar. This allows all information to be readily available to the operator. If the railcar contains a manifested waste, the railcar is cleaned in the RCRA Permitted Part B pad. All washwaters from this area are sent to EMPAK's Wastewater Treat ment Facility or to the Deepwell Injection Treatment Facility for proper disposal. In compliance with 40CFR ' 264.175 and 40 CFR '264.193, this area has secondary containment. The secondary containment provides passive mitigation in the event of a spill. In the event of a spill, operations are ceased and the area is immediately washed down. The washwaters are then routed either to the Wastewater Treatment Facility or the Deepwell Injection Treatment Facility for proper disposal. LISTING OF REGULATED SUBSTANCES HANDLED After evaluating the Approved Chemicals Listing against the Regulated Substances listed for flammable chemicals, EMPAK determined that the Quantity Stored does not meet RMP Threshold Levels. Therefore, no Worst Case Scenarios or Alternative Release Scenarios were developed. After evaluating the Approved Chemicals Listing against the Regulated Substances listed for flammable chemicals, EMPAK determined that the chemicals listed below did meet the RMP threshold l evel. For further information, please refer to Table 1. TABLE 1: DETERMINATION OF RMP COMPLIANCE FOR TOXIC SUBSTANCES REGULATED SUBSTANCE CAS No. THRESHOLD QUANTITY QUANTITY STORED (pounds) (pounds) Acrolein 107-02-8 5,000 7,006 Bromine 7726-95-6 10,000 25,906 1,1-Dimethylhydrazine 57-14-7 15,000 17,493 Dimethyl Dichlorosilane 75-78-5 5,000 7,097 Furan 110-00-9 5,000 7,805 Hydrofluoric Acid (Anhydrous ) 7664-39-3 1,000 1,000 Methyl Chloroformate 79-22-1 5,000 10,188 Phosphorus oxychloride 10025-87-3 5,000 13,994 Oleum (30% concentration) 8014-95-7 10,000 16,244 Titanium tetrachloride 7550-45-0 2,500 14,411 Toluene 2,4-diisocyanate 584-84-9 10,000 10,163 DESCRIPTION OF THE WORST CASE SCENARIO Since EMPAK is in the business of providing a cleaning service for railcars, EMPAK has determined an excessive heel is 1000 gallons for liquid or 1000 pounds for solids and gases. EMPAK analyzed a total release of all chemicals that may be in on site due to railcar cleaning services under weather conditions consisting of F Stability with 1.5 mile per hours, ambient temperatures of 77oF, and 50% humidity. After analyzing the Worst Case Scenario, it was dete rmined that Furan will cause the largest offsite impact. According to the Offsite Consequence Analysis Guidance published by the EPA, a total release of 1,000 gallons of Furan will affect a 24 mile radius area. Within this area, there are hospitals, schools, residential areas, industrial facilities and parks and recreational facilities. Approximately 1,750,000 people will be exposed to a release of 1000 gallons of Furan with no mitigation measures or emergency response programs initiated. Since EMPAK has an Accident Prevention Program and an Emergency Response Program in place, EMPAK feels confident that the probability of this event is very low. DESCRIPTION OF THE ALTERNATIVE RELEASE SCENARIO After reviewing internal reports, EMPAK has estimated a more probable heel as being 100 gallons for a liquid heel or 100 pounds for a solid heel. EMPAK has determined the most likely release scenario for 11 chemicals. Due to the nature of removing heels, EMPAK has determined the most lik ely release scenario to be a leaking transfer hose. This release will be occurring in the beginning stages of a deteriorating hose. Therefore, the greatest offsite impact of the Alternative Release Scenarios will affect an area with a 3.5-mile radius. Within this area, hospitals, schools, residents, industry, and parks and recreational facilities may be impacted. Approximately 19,000 people will be affected by a release of 524 pounds of Furan. An accidental release of 465 pounds of Acrolein may also have the potential of impacting a 1.9-mile radius area. Within this area, this release may have the potential to affect commercial, office or industrial areas. In most of our Alternate Release Scenarios, the release will have no offsite impact and will not affect our surrounding community. Again, EMPAK is confident that the actual impact will not be as significant as the calculated impact due to our Accident Prevention Program and Emergency Response Program. FIVE-YEAR ACCIDENT HIS TORY In the last five years, EMPAK has had total 1 accidental releases with: 2 releases involving spills of hazardous waste occurring in 1999, 1 release involving a release of chlorine occurring in 1998, 0 releases occurring in 1997, 1 releases occurring in 1996 involving a fire, and 2 releases involving spills of hazardous waste occurring in 1995. All events were responded to and contained within a timely manner. No offsite impact resulted from these accidental release events. Detailed information is available in the RMP Submit Report. GENERAL ACCIDENT RELEASE PREVENTION PROGRAM Since EMPAK is a railcar cleaning facility, all railcars are weighed before the cleaning process begins. Those weights of railcars that indicate a weight greater than a product heel weight are immediately returned to the customer. This practice greatly reduces the probability of a large quantity release occurring within the facility. Ot her means of preventing accidental releases includes employee training. In the railcar cleaning facility an operator receives three months of on-the-job training as an apprentice. Before the operator can be allowed to work on his own, his performance record is reviewed by his co-workers, his supervisor, the Railcar Cleaning Superintendent, and the Railcar Cleaning Manager. The operator also has a 24-hour Hazwoper Training Class, so that he is able to respond to emergency situations appropriately. When the operator's performance record has been reviewed and approved, the operator is then allowed to work on his own. During the course of the following year, the Railcar Cleaning operator receives an 8-hour refresher training, which includes Lock Out/Tag Out, Hot Work Permit, RCRA, Confined Space Entry, Fall Protection and Personal Protective Equipment. In the event an operator fails to properly follow procedures and policies, he will receive a one-on-one counciling session. If this fails, the operator ultimately faces termination. Along with employee training, the Process Control and Inquiry (PC&I) was developed to inform the operator of hazards and methods to safety manage these hazards. Chemical specific instructions are listed on the PC&I for the cleaning of a specific railcar. Before the railcar is brought on site for cleaning, the PC&I must be developed. The Technical Superintend initiates the PC&I by providing chemical and physical information for the chemical to be removed. To protect the employees from any unnecessary exposures, the Safety and Health Coordinator determines the proper personal protective equipment needed. To minimize accidental releases to the environment and to eliminate any offsite impacts, the Corporate Environmental Specialist determines appropriate emissions controls. The Disposal Manager establishes the correct disposal methods for the waste streams. Next, the Railcar Manager develops special cleaning instructions for the r ailcar. After each section is completed and approved, the PC&I is then reviewed by operations. At this point, any questions or concerns are addressed before the cleaning process begins. In conclusion, the PC&I is a valuable tool at EMPAK in reducing and eliminating any accidental releases. To further mitigate any accidental releases, EMPAK has invested in the following air pollution control devices including a thermal oxidizer which has a destruction efficiency of 99.9%, a flare, which has a destruction efficiency of 98% and a caustic scrubber which has a destruction efficiency of 95%. Other means of controlling emissions include our Wastewater Treatment System for biological treatment and metals removal. Our Wastewater Treatment System has destruction efficiency of 95%. When wastewater cannot be biologically treated, the Deepwell Injection System is used. To ensure properly functioning equipment, a quarterly preventive maintenance schedule was developed. Each quarter all eq uipment is inspected for leaks, corrosion, and cracks. All moving parts are inspected for any signs of wear. If problems are found, the equipment is taken out of service, repaired, and returned to service. Also, as part of Accident Prevention Program, the operator must inspect the railcar cleaning facility daily. During the daily "walk-around" compliance inspection, the operator notes and reports any questionable areas that might have the potential to impact the safety and health of co-workers, the community, and the environment. EMPAK has also developed an employee participation program, Safety Awareness Team (SAT). The members of SAT include Disposal and Railcar operators, Maintenance employees, Administrative personnel and Laboratory Technicians. SAT involves the employee in the decision-making process by allowing employees to develop safety procedures, to inform management of the need for improved personal protective equipment and to alert others of potentially hazardous situations. The employee's input is greatly appreciated and respected by EMPAK management. DESCRIPTION OF EMERGENCY RESPONSE PROGRAM In coordination with PAKTANK, our sister company, EMPAK has developed a joint Emergency Response Program to serve both sites. The Emergency Response Program includes Fire/Explosion Response Procedures, Spill/Air Release Response Procedures, Natural Disaster Response Procedures and Bomb Threat Response Procedures. Each procedures listed above contains contact information for the company management, outside emergency assistance organizations, community information services, and governmental agencies. An Emergency Alarm system is outlined in the Emergency Response Program to alert employees, contractors, and visitors to the appropriate actions to take during an emergency situation. This includes sheltering in place and evacuation of the plant site. Responsibilities are also assigned in the emergency procedures for properly trained personnel. Each member of the Emergency Response Team is trained annually in Fire Fighting Techniques, 8-hour Hazwoper after receiving the initial 24-hour Hazwoper, and hazardous waste management techniques as listed in RCRA. DISCUSSION OF SAFETY CHANGES TO BE IMPLEMENTED Since EMPAK deals with a large variety of chemical that pose potential hazards, EMPAK continuously strives to develop procedures and practices to protect and preserve the safety and health of our employees, our community, and our environment. To achieve the above ends, EMPAK is working on short-range goals of increasing the number of emergencies drills held each year at the facility. Although the Disposal Facility does not fall under the Risk Management Plan regulation, EMPAK plans to develop Process Hazard Analysis on the equipment to determine hazards that will reduced or eliminated. As a long-range goal, EMPAK will develop a Management of Change program for both the Railcar Cleaning Facility and the Disposal Facility. Be cause we all work to improve our quality of life for ourselves, our families and our neighbors, it is EMPAK's intentions to operate a business which emphasizes the protection of safety and health of our employees, the prevention of unnecessary exposures to our community and the preservation of our environment. By doing so, EMPAK feels it has an earned a place in the community. |