Eagle-Picher Tech., LLC - EOM Department - Executive Summary |
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CHORINE Eagle-Picher Tech., LLC - EOM Department Accidental Release Prevention and Emergency Response Polices at EOM Dept. Eagle-Picher Industries, Inc. is committed to the highest standards of integrity in all aspects of its business conduct. The Companys Policy on Environmental and Health and Safety Responsibility and Ethics requires employees and facilities to conduct operations in conformance with all applicable laws and regulations and in a manner that will protect employees, the community and the environment. This Policy is implemented by our facility through specific programs designed to assure safe and responsible handling of all chemicals throughout the manufacturing process. Regulated Substance The covered process is the chlorine storage building. The storage area is a separate building located away from other processes on the north side of the facility site on the west side of the warehouse. It can hold up to nine partially full one ton chlorine containers. We hav e a contract with a chemical supplier to partially fill one ton chlorine containers not to exceed 1400 lbs of chlorine. These will be used one at a time in other processes. A container is located on the west side of the building connected to the germanium tetrachloride production area. A container is also located on the east side of the gallium trichloride production area. The storage area maximum intended inventory of chlorine is 13000 lbs., and contains no process vessels or equipment of any kind. The storage area is a three-sided enclosure isolated from other structures to reduce potential fire hazards, with no sources of energy associated with the building. Worst Case AFTOX dispersion modeling predicts that the worst case release of 1400 pounds over 46 minutes would adversely affect an areas extending 2.29 miles from the release. Census data from 1990 indicates that 692 people reside in this area. AFTOX further predicts that a less serious alternate case release of 55 pou nds would adversely affect an area extending 0.3 miles, which includes only one single residence. The worst case affected area includes schools and residences, whereas the alternative case affected area includes no public receptors . No release scenario is predicted to affect any environmental receptors. Release Protection The chlorine process area has been regulated by OSHAs Process Safety Management (PSM) since 1994. The facility has successfully implemented all fourteen elements of the PSM program for the covered process. This facility has developed written operating and safety procedures for the storage and handling chlorine containers. Employees working with these containers are routinely trained annually in forklift safety and chlorine handling. The handling of chlorine is routinely reviewed by operating staff. A process hazard analysis must be preformed at least every five years and in the event of specific process modifications to identify process concerns and deve lop solutions for them. In addition, all fourteen elements of the PSM program are reviewed every three years to ensure the program is in compliance with all OSHA PSM requirements. The EOM facility has 41 operators that are trained under the Hazardous Waste Operations and Emergency Response (HAZWOPER) 40-hour operations level. This program requires that operators be trained in the hazardous chemical awareness and emergency response procedures. These individuals are trained to respond to hazardous chemical releases and implement proper responses to minimize any affects on human health and the environment. All HAZWOPER operators receive an annual eight-hour refresher training to maintain their certification. In addition, the operators in the facility undergo an annual evaluation for their specific duties. They are evaluated on all aspects of their job including hazardous chemical safe work practices. Any deficiencies noted in this evaluation would require retraining before the ope rator can return to their duties without direct supervision. Practices at the EOM facility to prevent chemical releases include preventative maintenance program on the forklifts that routinely to transports chlorine cylinders to and from the storage area. All forklift operators are trained to the new OSHA forklift standard and are evaluated annually and retrained every three years. The chlorine storage is in a secured area where access is restricted to authorized personnel only. The storage area is a three-sided enclosure isolated from other structures and chemicals to reduce potential fire hazards and striking by heavy objects or vehicles. The enclosure also has secondary containment. A removable steel valve protective housing protects the individual chlorine container valves. All ton containers are equipped with fusible metal pressure relief devices. These containers have six fusible metal plugs that are designed to yield or melt between 158oF and 165 oF to relieve pressure an d prevent rupture of the container in the unlikely event of fire or other exposure to high temperature. The relief device is activated only in the event of a temperature increase. The chlorine container storage area is inspected once per operating shift. The containers are maintained by our supplier. EOM facility has a very experienced operating staff with years of experience handling hazardous materials. We have an excellent safety record that demonstrates our commitment to safety. Five Year Accident History There have been no accidents at this facility in the past five years involving chlorine. The Emergency Response Program Eagle-Picher has a monitoring system in the process area that continuously monitors for gas releases. In the event the monitors detect a release, an alarm will sound alerting trained personnel to don the necessary safety equipment to mitigate the concern. If warranted, Eagle-Picher will notify the local fire department and request assistance. In the e vent of a chlorine release from a container, the EOM Department has trained personnel in the prevention and mitigation of a chlorine leak from this equipment. Our personnel have been trained by our supplier and have the necessary personnel protective equipment and replacement parts to address any process leaks described in the alternative release scenario. In the event of a release that may potentially affect an area offsite, EOM Department personnel will notify the proper local authorities as outlined in our Emergency Response Plan to inform them of the situation and advise accordingly. EOM Department officials have met with local officials and outlined a course of action for informing the public. Planned Changes to Improve Safety No process modifications have occurred in the storage area since it was constructed in 1996 as part of our process safety management program. |