Sentry Industries, Inc. - Executive Summary |
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RISK MANAGEMENT EXECUTIVE SUMMARY It is Sentry Industries, Inc. policy to protect our employees, our community, and the environment, through our policies, procedures and actions from chemical releases. Sentry Industries maintains the facility in accordance with all local, state, and federal requirements. We are active members in the Chlorine Institute and follow their recommendations on the safe handling of chlorine. Sentry Industries is involved in and has a representative on the Local Emergency Planning Committee (LEPC) District 11. Sentry Industries Risk Management Plan encompasses the following written procedures: 1. Standard Operating Procedures 2. Preventative Maintenance Procedures 3. Accident Investigation Procedures 4. Operator Training Programs 5. Chemical Accident Prevention Plan 6. Site Emergency Response Program 7. Safety Manual Sentry Industries is located in the Seaboard Industrial Center on the eastern border of Hialeah Florida. Sentry Industries was founded in 1984 to better sever the pool industry. Sentry Industries manufactures and distributes swimming pool supplies to wholesalers and service companies throughout South Florida. Along with other goods and services, Sentry Industries manufactures sodium hypochlorite (bleach). Sodium Hypochlorite is used to sanitize private and public swimming pools and in drinking water and wastewater treatment. In the manufacturing process, elementary chlorine is used, which is a regulated substance under EPA's Risk Management Plan rule. Our maximum inventory of chlorine would be one 90-ton railcar in use and one railcar on standby. The Environmental Protection Agency has defined a worst case scenario as the release of the largest quantity of a listed chemical from a vessel or process line failure that results in the greatest distance t o the listed chemical's endpoint concentration. Possible causes of the worst case release or the probability that such a release might occur, are not considered. The worst case release scenario that Sentry Industries selected was a complete failure of the railcar and the release of 90 tons of chlorine in a 10-minute time frame. This release could potentially effect the community up to 14 miles. An alternative (most likely) release scenario would be up to a 10 pound release from a gasket, valve or flange leak and could effect the community up to .1 miles. This alternate scenario is based on the only two leaks experienced within the last five years. Sentry Industries has taken the following steps to ensure our safe handling of chlorine in the community: 7 All manufacturing processes are Y2K compliant. 7 Only purchase chlorine in railcars from suppliers that conform to all Federal safety requirements for railcars and follow the Chlorine Institute recommendation for railcar loading a nd maintenance. 7 System was designed per industry codes. 7 Have procedures in place for the safe movement of railcars in and out of our secure railcar siding. 7 Equipment checks and preventative maintenance program in place. 7 Only trained personnel are allowed to receive, connect and disconnect chlorine railcars. 7 Written Standard Operating Procedures for operators to follow. 7 State of the art valve closure system to close the valves on the railcar and the piping system in case of railcar movement, detection of chlorine released to the atmosphere, safety equipment failure, power failure and manual shut down. 7 Redundant safety systems. 7 Chlorine gas monitor system that will warn plant personnel and shut the railcar car valves if it detects as little as 1 ppm chlorine released to the atmosphere. 7 Annual auditing of procedures and operations. 7 A chlorine scrubber system to pull a vacuum on hoses and piping systems. 7 Comply with OSHA Process Safety Management rule and EPA's Risk Management Plan. 7 Work with all state and local agencies to improve not only our safety, but also the industries safety commitment overall. In the past five years we have had two accidental release of chlorine. 7 Approximately 2 pounds of chlorine was released on 8/16/95 from a hose connection that leaked from a faulty connection when the railcar was opened. No one on site or off site was injured. A business directly behind our facility evacuated 4 to 6 persons from an outside work area as a precautionary measure. This incident was investigated and a scrubber system and automatic valve closure system was installed as a result. 7 Between 2 and 4 pounds of chlorine was released on 4-29-99 from a flange under a safety expansion chamber. All safety systems worked, the railcar was shut down and a vacuum was pulled on the piping system. From the area effected and the physical conditions observed, the amount of the release was approximately 2 to 4 pounds but could not be determin ed exactly. This release was reported as a release between 2 and 10 pounds. As of this writing this release was still under investigation. Preliminary corrective actions have been to inspect all flanges in the piping system, inspect all gaskets and flanges in inventory, and send the flange, gasket, and disc holder to the vender/manufacture for inspection. Employees at Unique Originals, (approximately 20) were effected by this release and were moved to the far side of their building for about 30 to 45 minuets. No damage or injuries were reported at our facility or in the surrounding facilities. The Hialeah Fire Department responded and inspected the area of the release, but the responders did not have to take any action. Sentry Industries, has an emergency response plan that has been coordinated with the community plan. We have and will continue to work with the local fire department though training and drills to improve our response to any problem that may arise. Sentry Indus tries, also has Aqua Ammonia Solution (29.4%) and Hydrochloric Acid stored on site. The Aqua Ammonia is not covered in this plan because inventory controls do not allow 18,000 pounds to be on site at any one time. The Hydrochloric Acid is not covered in this plan because the concentration is less then 37% (35%). |