DPC INDUSTRIES, INC - Executive Summary |
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Executive Summary 1. Accidental Release Prevention and Emergency Response Policies DPC Industries, Inc (DPC) is strongly committed to employee, public and environmental safety This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility It is our policy to comply with all applicable federal, state, and local regulations as well as implement appropriate controls to prevent possible releases of regulated substances Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release Our emergency response program includes procedures for notification of the local fire department; notification of any potentially affected neighbors; and notification of local, state and federal agencies Safety is an essential part of our operations, the safety devices built-in to the design of this facility, the safe handling procedures that we use, and the extensive training of our personnel 2. The Stationary Source and the Regulated Substances Handled DPC is a 52-year-old company whose primary activities encompass distributing and repackaging inorganic chemicals and compressed gases as well as manufacturing water treatment products For example, chlorine is used to produce sodium hypochlorite commonly know as household bleach We are headquartered in Houston, Texas and operate more than 20 plants across the United States We have these regulated substances at our facility: Chlorine, and Sulfur Dioxide (anhydrous) DPC transfers and/or stores these materials in 150-lb cylinders, and ton containers for use by our customers The maximum inventories of these substances at this facility are: Chlorine - 1,200,000 lbs Sulfur dioxide (anhydrous) - 750,000 lbs 3. The Worst Case Release Scenario(s) and the Alternative Rel ease Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used EPA's RMP Guidance for Wastewater Treatment Plants Reference Tables or Equations The following paragraphs provide details of the chosen scenarios Executive Summary The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from Sulfur Dioxide repackaging The scenario involves releasing the entire contents of a railcar in a gaseous form over 10 minutes This release would reach the toxic endpoint (0.0078 mg/l or 3 ppm) and public receptors One alternative release scenario has been submitted for each toxic substance present in Program 3 processes The alternative release scenario for Chlorine is the failure of a 1/2" hose on the filling station in the repackaging process This would release material in a gaseous form ov er 15 minutes It is assumed to be controlled by active mitigation measures that include emergency shutdown systems This release would reach the toxic endpoint (0.0087 mg/l or 3 ppm) and public receptors The alternative release scenario for Sulfur dioxide (anhydrous) is the failure of a 1/2" hose on the filling station in the repackaging process This would release material in a gaseous form over 15 minutes It is assumed to be controlled by active mitigation measures that include emergency shutdown systems This release would reach the toxic endpoint (0.0078 mg/l or 3 ppm) and public receptors 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119 Our facility is also subject to EPCRA Section 302 noti fication requirements The following sections briefly describe the elements of the release prevention program that is in place at our stationary source Process Safety Information DPC maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently The methodology used to carry out these analyses is the What if/Checklist (combined) The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated every 5 years as required or as necessary Any findings related to the hazard analysis are addressed in a timely manner Executive Summary Operating Procedures For the purposes of safely conducting activities within our covered processes, DPC maintains written operating procedures These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, and normal shutdown The information is regularly reviewed and is readily accessible to operators involved in the processes Training DPC has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes Refresher training is provided at least every 3 years and more frequently as needed Mechanical Integrity DPC carries out highly documented maintenance checks on process equipment to ensure proper operations Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps Qualified personnel carry out maintenance operations with previous training in maintenance practices Furthermore, thes e personnel are offered specialized training as needed Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner Management of Change Written procedures are in place at DPC to manage changes in process chemicals, technology, equipment and procedure Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at DPC These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior |