Prillaman Chemical, Suffolk Division - Executive Summary |
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Prillaman Chemical Corporation, a wholly owned subsidiary of Ellis and Everard, was originally founded in 1939. Prillaman Chemical is an industrial chemical distributor that provides products in support of industries, ranging from food and water treatment to textiles and furniture. Activities include warehousing, packaging, bulk transfer and formulation of many common industrial chemicals. We serve Virginia, North Carolina, South Carolina and Tennessee. We are members of the National Association of Chemical Distributors (NACD) and as members, we pledge to manage our business according to the principles of the NACD's Responsible Distribution Process. This process provides a system that promotes continuous improvement in the health, safety and environmental performance of our company. It is designed to be sensitive and responsive to community needs and public concerns. In addition, Prillaman Chemical has a Quality Improvement Process that makes safety and environmental concerns an on-going priority. We as team members of Prillaman Chemical and as menbers of our communities are committed to the safe handling of the products that we distribute as well as the safe operation of our facilities, but we also recognize that emergencies relating to those activities can occur. It is our policy to ensure that emergency response units and the public will have adequate information to allow them to react properly to emergencies, which could result from our activities. Accordingly, we have written procedures, which we will take to minimize the effects of such events. Prillaman Chemical Corporation-Suffolk, VA operates a warehouse, two bulk inorganic tank farms, bleach manufacturing plant and chlorine repackaging plant. All of these operations are located at 201 Suburban Drive in Suffolk, VA. The facility site occupies approximately 7 acres. Prillaman stores and distributes chlorine, sulfur dioxide, ethylenediamine (EDA) and aqua ammonia. EDA, chlorine and aqua ammonia ar e packaged at the facility and regulated as toxics under EPA's Risk Management Program (RMP), 40 CFR Part 68. Sulfur dioxide, which is stored at the facility, is also regulated under RMP. Chlorine and sulfur dioxide are regulated as toxic under OSHA's Process Safety Management (PSM), 29 CFR 1910.119. Bleach is also manufactured at the facility from chlorine and caustic soda using a continuous process. The worst case scenario for aqua ammonia would be a sudden and large rupture of a tanker containing 45,000 lbs. This would affect the area contained in a 1.15 mile radius from the release. Public receptors within this radius include residences, offices, industrial areas and one school. This is not a very likely scenario in that it would take a large sharp object moving at a high rate of speed to cause such a rupture. A more likely scenario would be a valve being sheared off a liquid container holding 2550 lbs. of aqua ammonia. This would affect the area contained in a 0.30 mile ra dius from the release. The only public receptors would be a nearby industrial area and a small number of residences. The worst case scenario for chlorine would be a sudden and large rupture of a chlorine railcar containing 180,000 lbs. This would affect the area contained in a 14 mile radius from the release. Public receptors within this radius include schools, residences, hospitals, correctional facilities, recreational facilities, commercial areas and industrial areas. This is not a likely scenario in that chlorine railcars are made of thick metal and have valves that do not permit excessive flow. A more likely scenario would be the over chlorination of a manufacturing tank. This would release 4000 lbs and affect the area contained in a 0.5 mile radius from the release. Public receptors within this radius includes residences, offices, industrial areas and one school. Several safeguards are in place to prevent this scenario. The chlorine levels in the manufacturing tanks are monitored by detectors that sound a warning signal followed by full alarm as the concentration increases. Additionally, if the recirculation pump shuts down, an alarm is sounded in the department warning the user of the manufacturing tank to cease the flow of chlorine. This scenario has also been used in a city-wide drill done at the Prillaman site. The worst case for EDA would be the sudden and large rupture of a tanker containing 45,000 lbs. This would affect the area contained in a 3.50 mile radius from the release. Public receptors within this radius would include schools, residences, a correctional facility, a hospital, recreational facilities, offices and commercial/industrial areas. This is not a very likely scenario for the same reasons mentioned previously for the aqua ammonia tanker. A more likely scenario would be a leak in a container holding 400 lbs. of EDA. This would affect the area contained in a 0.60 mile radius from the release. Public receptors would include residences, commercial/industrial areas, offices and one school. The worst case scenario for sulfur dioxide would be a sudden and large rupture of a 2000 lb. container. This would affect the area contained in a 1.3 mile radius from the release. Public receptors would include residences, offices, commercial/industrial areas and one school. This would not be a very likely scenario in that these are thick walled, heavy metal containers. A more likely scenario would be a fuse plug failure in a 2000 lb. container. This would affect the area contained in 0.10 mile radius from the release. The only possible public receptor in the area would be an adjacent industrial area. Release scenarios above were modeled using EPA's RMP* Comp (TM) or EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations. Release prevention measures for aqua ammonia and EDA include but are not limited to the following: -Intermediate bulk container valves are recessed. -Intermediat e bulk containers are all double walled and by site policy only designs that weigh in excess of 500 lbs are used. -Drum inspections done via procedure. -Forklift Training required for all operators. -Transfer hose inspections done on a schedule by procedure. -All scales certified quarterly to prevent overfilling. -Aqua ammonia is filled by operators using supplied air. -Scrubber system used for aqua ammonia filling. -Facility containment includes dikes, berms and sumps. -All facility electrical redone and evaluated in the last 5 years. -Ongoing federal and corporate required training for employees. -The facility has a monthly tested Evacuation Alarm System with manual activation switches at - locations all around the facility. -Facility wide fire detection system that is monitored 24 hrs/day, 7days/wk. Release prevention measures for chlorine and sulfur dioxide include but are not limited the following: -Battery backed up, perimeter chlorine detection system that is monitored 24 hrs./day, 7 days/wk. -Single point, battery backed up chlorine detection system that is montiored 24 hrs./day, 7 days/wk. -Low vacuum alarm system with audible and visual alert. -Scrubber system shutdown alarm system with signal that is sounded in the Repackaging Area. -Multi-set point manufacturing alarm with settings for warning and full alert. -Dual contained piping system with steel outer piping and Kynar(TM) inner piping. -Barometric loop to prevent reaction within piping system and overload of the vacuum system. -Two pager dispatched Emergency Response Teams with one one call at all times. -Extensive emergency response equipmeny including but not limited to A, B and C, Kits, SCBAs, atmospheric monitors, Level A suits and Level B suits. -Two annual drills per year with one in conjunction with outside agencies. -Microprocessor controlled air padding system with check valve system and dew point monitoring. -E xpansion chambers in the liquid system with volumes well over the calculated requirements. -Vacuum chambers within the vacuum system to handle sudden large demand. -Pneumatic Shut Off valves in the liquid system that fail shut if there is a loss of air pressure. -Microprocessor controlled bleach manufacturing system with numerous automatic shut off systems. -Camera, motion and infared security system monitored 24 hrs./day, 7 days/wk., and includes the entire facility. In the last 5 years there have been no releases from a process covered by 40 CFR Part 68 that have caused: -On site death, injuries or significant property damage. -Known offsite deaths, injuries, property damage, environmental damage, evacuations or sheltering in place. Additionally, there have been no RQ releases from the facility in over 7 years. In the last 7 years the facility has gone one, 2-year period and two, 1-year periods without any type of recordable accident. The facility curren tly lacks approximately one month from completing another 2-year period within this 7 years. Prillaman Chemical Corp.-Suffolk has a very detailed Emergency Response and Contingency Plan for both on and offsite Technical Assistance/Hazmat Response. All on site personnel receive extensive training in the handling, use and emergency procedures for all hazardous materials on an annual basis. A portion of the on site personnel are specifically trained, qualified and equipped under OSHA 1910.120 as Emergency Hazmat Responders to immediately handle on and offsite problems. Two times per year drills are conducted with one of these drills involving the outside agencies. These drills are targeted toward both worst case and alternative scenarios. These drills are observed, audited and evaluated for training purposes. At all times, at least one senior operations management employee can be reached via several numbers available on the company phone recording or facility entrance sign. This emp loyee will be qualified as an Emergency Coordinator and have the authority to commit the resources needed to carry out the Contingency Plan. Contact numbers are also available via copies of the Contingency Plan annually updated and given to all potential responding agencies. The Emergency Coordinator will notify all appropriate local, State and Federal emergency response groups as needed. Documented checks on all evacuation, alarm and alert sytems are performed monthly. In the future we intend to install a fully automatic shut down system to control the chlorine railcars. This system will be activated by the plantwide Chlorine Detection System making no human response necessay to stop chlorine flow from the railcars. The proposed system has just become very reliable in the last year and the facility Process Safety Management Group has recommended its installation. The Process Safety Management Group meets on a regular basis with its sole responsibility being to continually improv e and evaluate the systems that handle the covered chemicals along with the procedures and emergency response. |