Trinity Manufacturing, Inc. - Executive Summary |
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Accidental release prevention and emergency response policies: This facility uses chlorine to manufacture a pesticide product. Chlorine is considered hazardous by EPA; therefore, certain safety precautions are observed when handling chlorine to prevent unnecessary human exposure, to reduce the threat to the health of the employees at this facility, and to reduce the threat to nearby members of the community. It is this facility's policy to adhere to all applicable federal, state, and local laws and regulations. This facility is in compliance with the OSHA PSM rule and has an OSHA emergency response plan, a NC state pesticide storage contingency plan, and a hazardous materials management plan. These plans outline who should be contacted and what steps should be taken in the event of an emergency. If an emergency were to occur, it is this facility's policy to alert the following outside agencies: Hamlet Police and Fire Department, the NC Highway Patrol, and Richmond County Medic al Services. The stationary source and regulated substances handled: This facility is a chemical manufacturer of agricultural and textile chemicals. Chlorine is an ingredient used in the manufacture of these products. Chlorine is brought onsite in railcars. Only one of the railcars onsite is hooked up to the process at any one time. The chlorine supply system consists of the railcars onsite and associated piping, valves, and detection equipment. There are safety shutoff valves at the railcar discharge and also midway to the process in the event of a problem. There are two chlorine "C" kits available for handling railcar emergencies, one at each railcar station. All piping has been labeled to minimize misidentification. The worst case release scenario and the alternate release scenario including administrative controls and mitigation measures to limit the distances for each reported scenario: The worst case release scenario is failure of one of the railcars resulting in a toxic gas release of chlorine gas during an assumed 10 minute gas release. This facility is located in a relatively remote area; however, the amount of chlorine released under the worst case weather conditions could disperse to have offsite impacts before reaching the toxic endpoint of 0.0087 mg/l. There are a number of alternative release scenarios that could occur such as a leak at the railcar while unloading, valve leak, or pipe break. These scenarios give a more realistic accounting of a chlorine leak at this facility. Chlorine has strong, distinct odor; therefore, a leak should be detected soon after beginning. Since detection should occur soon after a leak begins, offsite impacts should be minimal if any at all occur. The general accidental release prevention program and the specific prevention steps: This manufacturing facility complies with EPA's accident prevention rule, OSHA's PSM rule and all applicable federal, state, and local laws. The emergency response plan w hich was developed and implemented deals with the safety of the employees in the event of an accident and minimizing the release of any chemical onsite, including chlorine. Each employee receives hands on training in the use of personal proctective equipment and communications equipment. Each employee is to receive training in all of the aspects of the emergency plan and program, and drills are to be performed at least once a year. Training is available to the outside agencies that would be responding to emergencies. This facility provides the outside agencies familiarization of the facility. The agencies that would be contacted for an emergency are the Hamlet Police and Fire Department, the NC Highway Patrol, and the Richmond County Emergency Medical Services. There are safety shutoff valves at the railcar and also midway to the process in the event of a problem. There are two chlorine "C" kits available for handling railcar emergencies. All chlorine piping has been labeled to minimize misidentification. Five year accident history: There has never been an accident involving chlorine that caused death, injury, property or environmental damage, or evacuations at this facility in the past five years. The emergency response program: In the event of an emergency involving chlorine, it is this facility's policy to notify the following outside agencies: Hamlet Police and Fire Department, the NC Highway Patrol, and the Richmond County Emergency Medical Services. Planned changes to improve safety: This facility is constantly looking for ways to improve safety for both the employees and members of the surrounding area. Additional leak detectors are planned to be installed in the near future. |