Puritan Products, Inc. - Executive Summary |
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Puritan Products, Inc. is a wholesale distributor of industrial chemicals. The facility is located at 2290 Avenue A in Bethlehem, PA. Regulated substances handled at the facility include hydrochloric acid (37%) and ammonium hydroxide (29%). Hydrochloric acid is delivered by tank wagon to either a 5,000 gallon tank at the facility or to drums. Ammonium hydroxide is delivered by tank wagon exclusively to drums. Puritan maintains a detailed emergency response plan in accordance with 29 CFR 1910.120 and 25 PA Code 264, Subchapter D (264.51 through 264.56). The Director of Operations serves as facility coordinator and incident commander for implementation of the emergency response plan. Employees are trained to respond to accidental releases at the facility. The plan is coordinated with the LEPC and included in the community off-site release plan. Because the facility is one 50,700 square foot building, the ammonium hydroxide and hydrochloric acid are considered one process that coul d potentially be released at the same time in the event of an explosion. The worst case release, defined by the EPA as the release of the contents of the largest container, would be the release of the entire contents of the 5,000 gallon HCl tank. The amount in the HCL tank is administratively controlled to an operating level of 4,500 gallons. This tank is located inside the building within a diked area with a capacity of 6,237 gallons. The dike and the building provide passive mitigation in the event of the worst case release. The two alternate case release scenarios considered were the release of a drum of hydrochloric acid and a release of a drum of ammonium hydroxide at the loading dock, the closest point to the outside air. The off-site consequence analysis was performed using the guidance document "Risk Management Program Guidance for Chemical Distributors". For the worst case analysis the EPA specified conditions of 1.5 m/s wind speed, F stability class, and ambient tempe rature were used. Urban conditions apply because of the industrial park surroundings of the facility. The toxic endpoint for HCl is 0.030 mg/l. Modelling as a ten minute release, the distance to the toxic endpoint for the worst case release scenario is 0.294 miles. This would affect other facilities in the industrial park, but no residential areas or environmental receptors. Both alternate release scenarios were also modelled using the same guidance information for chemical distributors. A wind speed of 3 m/s and D stability class atmosphere were used per EPA guidance. A release of one drum of either HCl or ammonium hydroxide outside at the loading dock would have the potential to affect only the immediate industrial neighbors. The distance to endpoint in each case is less than 0.1 miles. The release of the entire contents of a tank wagon that is unloading HCl or ammonium hydroxide is in transportation and, therefore, exempt from this regulation. However, it should be noted t hat because this accident would happen outside that a greater range of off-site receptors may be affected by such an accident. Unloading does occur in a diked area with a sump to pump spilled material to an outside emergency tank. A fire that destroys the warehouse was also not modeled because it is considered to be less likely than the worst case scenario. In addition, a sprinkler system and emergency response procedures would prevent the spread of the fire. An alarm system would immediately notify all employees and the fire department. However, it should be noted that a catastrophic fire could also have worse off-site consequences than the worst case release of the HCl tank contents. Puritan Products, Inc. has taken precautions to ensure that releases of toxic chemicals do not affect any off-site receptors. Prevention measures for the HCl tank include the following: 7 Hydrostatic and water head testing 7 Level indicator 7 High level alarm 7 Conservation vent releasing to aci d scrubber 7 Diked area with floor sensor that automatically starts pumping to a 10,000 gallon outdoor containment tank. 7 A 1,600 gallon neutralization tank inside the building to neutralize any spilled acid that has been collected. 7 Two anti-syphon holes on the tank fill tube to prevent backflow. All operators have been thoroughly trained on safe operating procedures. Drumming from the HCl tank or tank wagon occurs inside the diked area. Drumming of ammonia occurs exclusively from the tank wagons. This operation also vents to a scrubber. Operators responsible for moving or loading drums are trained in the safe operation of the forklifts both in the classroom and operating the vehicles. In the event of a leaking or punctured drum outside of a diked area, operators are trained to use containment materials such as soda ash to prevent the spread of the release. In the event of an emergency, the Director of Operations serves as the facility coordinator responsible for activating a nd overseeing the emergency response plan. This plan is coordinated with the Lehigh County LEPC. There have been no accidents involving the regulated substances at the facility in the last five years. |