Sethness Product Company - Executive Summary |
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Executive Summary It is the policy of the Sethness Products Company to prevent the occurrence of hazardous materials releases by attention to the design and maintenance of systems that handle the hazardous chemicals. Emergency response policies include mitigation when possible within the abilities and training of the plant staff. Should these efforts be insufficient, further intervention would be in active cooperation with community planners and first responders. Sethness Products is an active member of the Clinton County Local Emergency Planning Committee. The Sethness Products Company produces caramel color for the soft drink and other industries by processing corn syrup. Sulfur dioxide and aqueous ammonia are used as reactants with the raw corn syrup to achieve the color desired by the customer. Two sulfur dioxide storage tanks exist that hold up to a combined total of 154,000 pounds of liquid sulfur diox ide under pressure at ambient temperature. Two aqueous ammonia tanks exist that hold up to 136318 pounds of 30% aqueous ammonia at ambient temperature and pressure. Distribution piping containing full strength sulfur dioxide and aqueous ammonia contributes a negligible amount of additional volume. The worst case scenario for a sulfur dioxide release considers the release of one tank of sulfur dioxide (limited to 80% of absolute capacity to prevent overfilling) which is 77075 pounds, over ten minutes. Under worst case weather conditions, the plume would travel more than 25 miles before dissipating to concentrations no longer dangerous to the public. Given the properties of sulfur dioxide it is difficult to imagine the release occurring in ten minutes or less. An alternative scenario considered involving a sulfur dioxide release of gas from a relief valve failure or possibly a seal, considers the loss of 20 pounds/minute. This could affect a circle with radius of 0.58 mile s until dissipating to levels not harmful to humans. The worst case scenario for an aqueous ammonia release considers the release of 74,450 pounds of material (limited to 80% of tank capacity to avoid overfilling) over ten minutes. Under worst case weather conditions, the plume would travel 2.4 miles until dissipating to concentrations no longer harmful to the public. An alternative release scenario for aqueous ammonia considers the release of up to 3 gallons per minute (669 pounds) such as might occur if there is a problem with fittings on the tank truck or pump inlet fitting. This release would impact a circle with radius of 0.06 miles until dissipating to harmless concentrations. The programs in place to prevent releases focus primarily on prevention by design and maintenance. The facility personel work in concert to insure that design and system components are optimized for safe operation. All proposed changes are reviewed by plant engineering staff to insure that s ystem integrity is not compromised. During this review, any activities such as inspection or maintenance are specified and integrated into plant operations. Given the small facility staff, outside experts frequently provide or review designs for changes to the systems. In addition to an aggressive safety program based on Job Safety Analysis, the facility is in compliance with the Process Safety Management (PSM) rules. The plant safety program assures that management, engineering, and operations are informed of the hazards posed by these materials, and the actions required to maintain the systems in safe condition. The safety program has the full support of labor and management. In the unlikely event of a release, facility personnel would assess the seriousness of the problem and take appropriate action. Actions would include evacuation of the facility, notification of emergency first responders, and if required, a call for help to the Quad Cities Hazardous Materials Team. In order to provide rapid response to a problem, Sethness employees have been trained in the early detection of small leaks and catastrophic events that could result in large releases. Employees, upon detection of incidental leak conditions, have training and equipment to make emergency repairs. In the event of catastrophic failure due to a tornado or collision between a vehicle and tank, activation of the community response plan would be the primary response. There have been no releases of Sulfur Dioxide or aqueous ammonia that have had an impact on off-site receptors. The small releases that have occurred are due to maintenance. Minor leaks have been vigorously followed up to prevent reoccurrence. The emergency response plan is designed to assure the safety of employees. Once safety of employees is assured, abatement of the release will be addressed. Preventing hazardous concentration of vapors is the primary goal. This will be accomplished by repairing faulty or d amaged equipment, or the application of bandages. Should the problem have the potential to be beyond the capability or training of facility personnel, further mitigation and response will be coordinated with local first responders and (if necessary) the Quad Cities Hazmat team. As a result of the hazard analysis for PSM, there are plans to improve the security of the sulfur dioxide unloading and storage system that will be implemented by August 1, 1999. Additional plans to formalize and improve documentation of the management of change program and hot work permit system is being Developed for implementation by August 1, 1999. |