Degussa-H|ls Corporation - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies At the Degussa-H|ls Corporation South Plainfield site, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of release prevention programs and emergency response programs to help ensure the safety of our employees and the public as well as the protection of the environment. This document provides a brief overview of the risk management activities that we have designed into and implemented including: * a description of our facility and the use of substances regulated by the Environmental Protection Agency's Risk Management Program rule; * a summary of results from our assessment of the potential off-site consequences from an accidental chemical release; * an overview of our accidental release prevention programs; * a five-year accident history for accidental releases of chemicals regulated the Environmental Protection Agency's Risk Management Prog ram rule; * an overview of our emergency response program; * an overview of planned activities to improve the prevention program at the facility; * the certification that the Environmental Protection Agency's Risk Management Program rule requires us to provide; and * the detailed information about our risk management program. The South Plainfield facility is a producer of precious metal products such as silver solder, pastes, and powders used in the electronics industry. Formaldehyde solution is used at the facility in the precipitation of metallic silver from precious metal solutions. These operations are conducted in small batch reactors. Formaldehyde solution, 37%, is stored at the facility in a 6000 gallon storage tank and distributed to the user equipment in the plant through a piping network. Formaldehyde solution is delivered by tank truck by several different firms. Deliveries are scheduled when the storage tank level drops below a predetermined level. Worst Ca se Release and Alternative Scenarios The primary hazard for storage and handling of formaldehyde solution at this facility is loss of containment resulting in a toxic release. The "worst case" scenario involves the complete failure of the storage tank with the rapid release of the entire tank contents followed by evaporation. The storage tank is inside a dike with ten foot high walls to limit the surface area of the liquid pool thereby reducing the evaporation rate. The release was modeled using the equations found in Appendix D, Section D.2.1 of the Off-site Consequence Analysis Guidance. The "Worst Case" meteorological conditions followed the conditions established in the rule. The duration of the release was selected as one hour, a temperature of 3110K [1000F] and urban topography were used. The distance to the formaldehyde endpoint is 0.06 miles [317 feet] according to Table 4, Off-site Consequence Analysis Guidance. An alternative release scenario may be the failure of the hose connecting the delivery tank trailer to the unloading transfer pipeline. This scenario was selected as a more credible failure incident. The driver unloads the tank trailer under the surveillance of Degussa-H|ls security personnel. The release rate of 450 lb./min for three minutes was selected. The driver must stay with his vehicle during the unloading operation. The trailer is parked inside the "well" of a nearby loading dock. Spilled liquid would be trapped inside the "well". The following conditions were used; wind speed 3.0 m/s, Class D stability, and urban topography. A release rate for evaporation was calculated from equation 18, Chapter 8, Section 8.2.3, Off-site Consequence Analysis Guidance. A 10 minute duration for the release gave a 0.06 mile (317 feet) distance to the toxic endpoint. The actual distance may be less the selected value was the lowest value in the Table. Accidental Release Prevention Program The prevention program used at the facility is the Occupational Safety and Health Administrations Process Safety Management standard. The standard covers management system elements involving safety information, hazard evaluations, operating procedures, employee training, contractor controls, mechanical integrity, pre-startup reviews, incident investigations, safe work practices, and emergency response. There are a number of specific measures in place to reduce the likelihood of a release of formaldehyde solution or it's impact. The tank liquid level is monitored by two level gauges. The two gauges must read within 100 gallons of each other. Additional material is not ordered until the tank level is at 1500 gallons. This will allow the total contents of the delivery tank trailer to be safely unloaded into the storage tank. The storage tank has an installed high level monitor and alarm that alerts the driver if the tank level is too high. The driver and Degussa-H|ls security personnel are on hand throughout the unloadi ng operation and are able to shut down the operation in the event of a leak before a large release has occurred. The pipe line and storage tank are constructed of welded stainless steel. This material is compatible with and resistant to corrosion from formaldehyde solution. Five-year Accident History There have not been any releases of formaldehyde solution at this facility. Emergency Response Program Emergencies at the facility are handled according to the "Emergency Plan" and details the actions required to respond to plant emergencies such as chemical spills, medical emergencies, fire, gas leaks, bomb threats, explosions and natural disasters. Decisions regarding the evacuation of personnel and the notification of outside agencies are made by the Emergency Response Management Team chairperson or Vice Chairperson. If the emergency plan is activated during the second or third shift the Shift Manager will make the notification. On Saturday the Saturday Manager -in-Charge will make the notification is necessary. The Hazardous Entry and Abatement Team will respond to chemical spills. Team members have been trained in response and mitigation techniques. Team members participate in annual training and drills. Their first response is to stop the release and contain the spread of material. The formaldehyde storage tank is contained inside a dike with walls that are ten feet high. The tank is further sheltered on three sides by the production building. The entire contents of the storage tank will be contained inside the dike. During unloading the tank trailer is parked inside the "well" of the nearby loading dock. Spills occurring during unloading will be contained inside the "well". Planned Improvement to the Prevention Program The prevention program at the facility is the facility is the Process Safety Management System required by the Occupational Safety and Health Administration Standard 1910.119. The Mechanical Integrit y element at the facility is currently undergoing revisions. The remaining elements will be reviewed for possible updating and improvement later this year following the annual facility maintenance shutdown in the summer. Please note: Sect.2.6 and Sect.3.6 should read 0.04 #/min.and 0.1035#/min.. RMP*SUBMIT would not accept these and per EPA Hotline 0.2#/min. was entered. |