Sandel Glass Company - Executive Summary
SANDEL GLASS COMPANY EXECUTIVE SUMMARY |
Sandel Glass Company utilizes 70 % hydrofluoric acid in the production of non-glare glass for the picture frame industry. Sandels facility in Bessemer, Alabama is the only site which uses the acid or any other regulated substance. Sandel Glass recognizes the risks in dealing with hydrofluoric acid and is committed to operating in a manner that is safe for its workers, the public, and the surrounding environment.
RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
Sandel Glass has established a system to help ensure safe operation and handling of hydrofluoric acid. The system is made up of two components: a risk management plan (RMP) and a emergency response program. The purpose of the RMP is to help Sandel Glass manage the risk associated with handling hydrofluoric acid, and also to aid Sandel Glass in meeting the requirements of the EPAs regulation 40 CFR part 68. The purpose of the emergency response program is to coordina
te emergency response procedures in the event of an accidental release. Additional details regarding the prevention and emergency response programs are provided in this plan.
SANDEL GLASS FACILITY AND REGULATED CHEMICALS
Sandel Glass uses aqueous hydrofluoric acid to etch glass. HF acid with concentrations greater than 50% weight are regulated by the RMP rule. Although Sandel Glass etches glass using a diluted HF solution, 70% HF acid is stored at the facility. A maximum of 50,000 lb. of HF acid is stored in a 5,100 gallon storage tank, which exceeds the threshold limit for HF acid in a process (1,000 lb.). Sandel Glass falls under program 2 RMP Rule since HF is not covered by the requirements of OSHAs process safety management regulations, and there is potential for offsite consequences resulting from an accidental HF release.
OFFSITE CONSEQUENCE ANALYSIS
The RMP rule requires Sandel Glass to perform an offsite consequence analysis for the worst case and alternative release scena
rios for 70 % HF acid. The worst case scenario would be failure of the 5,100 gallon acid storage tank, resulting in a maximum spill of 50,000 pounds of HF acid. A containment bay would contain the liquid; however, a vapor cloud would form from the evaporating liquid. The maximum distance to the toxic endpoint concentration would be 0.19 miles, modeled using the EPAs OCA Guidance Document. Several businesses and a few residences are located within the distance from the storage tank, with a residential population of about 15 people. No environmental receptors are within this distance.
The alternative release scenario would be a failure of a 2 welded discharge connection located at the bottom of the acid storage tank. The scenario assumes that a maximum of 50,000 pounds of acid would be released through the ruptured line. The liquid would be contained, but a vapor cloud would form. The maximum distance to the toxic endpoint would be 0.06 miles, modeled using the EPAs OCA Guidan
ce Document. Two businesses and no environmental receptors are located within this distance
ACCIDENTAL RELEASE PREVENTION PROGRAM
The RMP rule requires a prevention program for storing 70% HF acid. The following are elements used to describe the prevention program at Sandel Glass:
The facility of Sandel Glass in Bessemer, Alabama was designed by a veteran team of acid engineering consultants using industry standards and guidelines. All 70 % HF piping and storage tank are internally protected to reduce corrosion and deterioration. Numerous equipment documents, designs, and parameters are on file at the Bessemer facility to ensure safe operation. All Sandel employees have access to Material Safety Data Sheets for 70% HF acid which describe the physical and chemical properties of the acid. A self contained breathing apparatus and numerous respirators and safety equipment are available to deal with minor accidental releases.
Sandel Glass performs
hazard reviews periodically on several areas where there could be potential for problems. Checklists are used to ensure proper operation and maintenance for each area of concern. Reviews are routinely performed on the acid unloading area, storage facility, pipes, valves, and miscellaneous environmental and safety concerns.
TRAINING & OPERATING PROCEDURES
All Sandel employees who work with 70 % HF acid have been trained to practice safe and precautionary performance of their assigned tasks. Periodic training is performed to ensure consistent handling and operation. Sandel Glass has developed operating procedures which train employees how process operations should be performed during start-up, normal, and abnormal operations. A shutdown checklist is available to help monitor the integrity of all acid equipment and to verify that all pumps and valves are closed.
Sandel Glass has an inspection and maintenance program which helps target damaged or deteriorated equipment wh
ere failure can occur. The program also trains employees how to observe safe practices while maintaining acid equipment.
Sandel Glass has initiated a compliance audit checklist to ensure that the process and operations are in accordance with the RMP rule. The audits will be performed on a routine basis, and any irregularities will be noted and corrected in a timely manner.
Sandel Glass investigates any incidents which could have potentially resulted in a serious accident involving personnel, the public, or the environment. The results of the investigation are documented and an analysis is performed to determine how and why the incident occurred. Recommendations are given to prevent the incident from occurring again.
FIVE YEAR ACCIDENT HISTORY
Sandel Glass has not had an accidental release of HF acid within the past 5 years.
EMERGENCY RESPONSE PROGRAM
Sandel Glass has established a written emergency response plan that complies with th
e RMP rule. The plan consists of 1) procedures for informing the public and emergency response agencies about releases. 2) documentation of proper first aid and medical treatment necessary to treat human exposures, and 3) procedures and measures for emergency response.
PLANNED CHANGES TO IMPROVE SAFETY
Sandel Glass has hired a production superintendent with an extensive background working with hazardous chemicals. His experience will help Sandel monitor and enforce the RMP rule and provide suggestions to improve process safety.