Phibro-Tech, Inc. - Executive Summary |
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Executive Summary Introduction: Phibro-Tech, Inc. is committed to the safety and well being of its employees, neighboring community, and the environment. Additionally, Phibro-Tech, Inc. is an active member of the Chlorine Institute. Phibro-Tech recycles waste that results from electroplating and etching. Chlorine and anhydrous ammonia are utilized as additives to the recycled material that is sent to our customers. Recycling the waste into a useable product prevents these materials from being disposed of as a waste. Phibro-Tech's policy is to implement reasonable measures to prevent a release of the regulated substances from occurring, provide early detection of a release via fixed point monitoring systems, and to have in place a contingency plan to respond safely and promptly to such a release. Regulated Substances: The Risk Management Plan has been prepared to address the handling of the regulated substances located at 10 Industry Avenue, Joliet, Illinois 60435. Specif ically, the regulated substances processed at the facility include anhydrous ammonia and chlorine. The following are the maximum quantities of the regulated substances stored on-site: Substance Quantity Storage Vessel Chlorine: 180,000 pounds Railcar CAS # 7782-50-5 Anhydrous Ammonia: 100,092 pounds Above Ground Storage Tank CAS # 7664-41-7 Chlorine and anhydrous ammonia are used as additives to turn waste into a useable product. Specifically, for the manufacturing of specialty etchants that are utilized in the circuit board industry. Executive Summary Page 2 Facility Description and Operations Phibro-Tech, Inc. has been an inorganic chemical processing plant since 1972, predating the Resource Conservation and Recovery Act (RCRA). Manufacturing operations involve the reclamation and refining of metal salts and the reconstitution of etchant solutions. When RCRA was enacted, some of the materials which the facility utilized as raw materials in its man ufacturing operations became classified as hazardous wastes; those operations processing hazardous wastes became classified as exempt- recycling operations. Other materials accepted for recycling have remained classified as solid wastes rather that hazardous wastes. In addition, virgin chemicals are purchased as raw materials for manufacturing operations. The facility has received a RCRA Part B permit in 1993 for operations which include the storage and treatment of hazardous wastes generated from, but not limited to various etching and electroplating processes. The operating process is currently exempt from RCRA. Phibro-Tech's manufacturing and hazardous waste operations are physically and functionally separate entities located on the same site as shown on the Site Plot Plan. The facility is located on a 1.6 acre parcel (T35N, R10E, Sec. 4, NE1/4) in the City of Joliet, Will County Illinois, within the old Joliet Industrial District. The facility is located approximately 1,000 feet east of IL Route 53 (Broadway Street). Land used immediately north, west and south are industrial. The facility is bordered on the east by the Elgin, Joliet, and Eastern (EJ&E) Railroad right-of-way and the DesPlaines River. Worst Case Scenarios: The United States Environmental Protection Agency (USEPA) has defined the Worst Case Scenario as a the hypothetical rupture and full release of all contents of the facilities largest storage vessel in a ten minute time period, assuming all safeguards have failed, during extremely stable weather conditions. Chlorine: The worst case scenario would involve the release of the contents of a ninety ton chlorine railcar that results from the structural integrity of the railcar becoming compromised. The release rate would be 306.2 lbs/s and the distance to the toxic endpoint would be 8.43 miles. Executive Summary Page 3 Administrative Controls: All operators undergo extensive training in accordance with the Process Safety Ma nagement standard (29CFR1910.119). In addition, chlorination takes place on days in which management personnel are present. The emergency response team has received detailed training on the use of a type C kit (Railcar Emergency Response Kit). All chlorine is shipped and stored in a railcar that is certified in accordance with the United States Department of Transportation (USDOT) regulations. The railcar is inspected upon receipt, prior to shipment and on a daily basis while on location. Any discrepancies are immediately reported to the chlorine distributor for evaluation. All chlorine system piping and storage vessels are inspected on a monthly basis by qualified maintenance personnel and any discrepancies (i.e. damaged piping, etc...) are repaired. Mitigation Measures: Phibro-Tech also has a chlorine fixed point monitoring system that is linked to the process and will shut it down via a pneumatic closure device connected to the chlorine railcar. The fixed point monitoring s ystem is linked to the process and will shut down the chlorine car and evacuate the chlorine lines, via the scrubbing unit, at .5 parts per million chlorine. The pneumatic closure device is equipped with a back up air system that will operate in the event of a pressure or power loss. The chlorine railcar is equipped with a safety valve that will stop the release of chlorine in the event of the valve becoming damaged. An emergency Type C kit has been acquired to repair damaged valves and contain releases resulting from valve damage. Alternative Case Scenarios: The USEPA has also specified in the Risk Management Rule that each facility define a specific Alternate or Realistic Scenario that could have off site impact, based on plant operations. The Realistic Scenario are to be modeled using the actual active and passive mitigation systems that are in place if they are capable of withstanding the event of a triggered release. Anhydrous Ammonia: The alternative case scenario would be the release of anhydrous ammonia via a leak in a process line. The release rate would be 23 lbs/s and the distance to the toxic endpoint would be .44 miles. Administrative Controls: Procedures have been developed and implemented to assure that the equipment is operated in accordance with the existing process specifications. All operators undergo extensive training in accordance with the process safety management standard. Furthermore, the tank and associated piping are inspected on a monthly basis by qualified maintenance personnel and any discrepancies (i.e. damaged piping, etc...) are repaired. The storage vessel has been certified by an engineer and is maintained in accordance with 29CFR1910.119. Additionally, the anhydrous ammonia tank is inspected daily. Mitigation Measures: A fixed point ammonia monitoring system with 10 sensors has been installed to detect a release. The system is designed to have a light actuate when ammonia levels reach 25 parts per million a nd an alarm sound when ammonia levels reach 50 parts per million. Safety valves are also located within the discharge lines of the anhydrous ammonia tank. The valves will be closed in the event of a high pressure release. Executive Summary Page 4 General Accidental Release Prevention Program: Phibro-Tech, Joliet is subject to 29CFR1910.119, which is the Process Safety Management Standard. Specifically, for the chemicals chlorine and anhydrous ammonia. Phibro-Tech has complied with all of the requirements of the Process Safety Management standard. Routine checks of the facility are conducted several times daily to ensure against unauthorized access, and to inspect chemical and hazardous waste storage and processing areas for a potential release. Releases are easy to detect at Phibro Tech Incorporated. Any anhydrous ammonia or chlorine release will emit an odor and will be detected via fixed point monitoring systems. Employees are trained annually to recognize hazards through the Hazard Communication Standard and Contingency plan training programs. When facility operations are suspended due to holidays, weekends (when the plant is not on seven day operation), etc., a professional security agency provides staff to monitor the facility in a manner similar to that conducted by on-site personnel. Six security punch clock stations are located around the facility to document inspection patrols. In this manner the facility is monitored 24 hours per day, 7 days per week. If any problems occur or any release or chemical odor is detected, the security guard is instructed to contact Phibro-Tech Incorporated management and alert them to the situation. Equipment Maintenance Phibro-Tech, Joliet has equipment maintenance schedules that assist in preventing the pre-mature failure of equipment. This process includes the monthly inspection of associated tanks, lines and pumps. In addition, inspections of the chlorine and anhydrous ammonia storage vessels are conducted dail y. Training All training programs have been developed and are compliant with existing regulations set forth by the Occupational Health and Safety Administration, Department of Transportation and the Environmental Protection Agency. All employees receive twenty four hours of hazardous waste operations training upon initial hire. In addition, all employees receive eight hour annual hazardous waste operations training and contingency plan training. Also, all contractors undergo a safety orientation that covers the Phibro-Tech, Inc., Joliet contingency plan. Furthermore, all employees receive extensive on the job training that is process specific. All employees are required to demonstrate the required skills on a daily basis to verify training was comprehended. In the event the employee does not demonstrate competence, the employee is retrained. Monitoring Equipment Phibro-Tech, Inc., Joliet has fixed point monitoring systems for chlorine and ammonia. Specifically, sensors for ammonia and sensors for chlorine are strategically located throughout the facility. The sensors are strategically located around key process areas in and out of the facility. The ammonia sensing unit is programmed to have a light actuate at 25 parts per million of ammonia and an alarm sound at 50 parts per million ammonia. The chlorine unit will shut down the system at .5 parts per million of chlorine. All sensors are calibrated monthly and serviced as needed, at least annually. In addition, direct reading portable instrumentation is available for the detection of anhydrous ammonia and chlorine. Executive Summary Page 5 Five year release history: On June 10, 1997 at 10:00 a.m., an employee was exposed to anhydrous ammonia vapors from a process line. The employee was immediately sent to the local emergency room and was treated for chemical inhalation. The employee was removed from work for one day, but suffered no chronic adverse health effects. There was not any other injurie s, deaths or significant property damage on-site. Additionally, there was not any significant property damage, deaths, injuries, evacuations, sheltering in place or environmental damage off-site that occurred as a result of the release. A faulty flow indicator caused to release of the anhydrous ammonia gas. The valve was immediately shut off and the flow of anhydrous ammonia vapors was discontinued. The duration of the release was less than thirty seconds and the total amount of anhydrous ammonia released is estimated at less than one half of a pound (less than .06 gallons). The flow indicator was replaced and as a result of a regular inspection schedule, has not malfunctioned since. Emergency Response Phibro-Tech has a comprehensive emergency response program that includes the installation of detection and shutdown systems to halt and/or mitigate a release. In the unlikely event that a release cannot be controlled completely via one of the control methods, Phibro-Tech has an Emergency Response Team trained and equipped to respond safely to a release in accordance with an Emergency Response Plan. Specifically, all members of the Emergency Response Team undergo twenty four hours of initial training and eight hours annually as well as partaking in quarterly drills. Planned changes to improve safety All equipment will be maintained in accordance with manufacturer's recommendations. In addition, all training programs will be improved when possible. |