LASER PRODUCTS, INC. - Executive Summary |
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I - Our accidental release prevention policy rely on our commitment to maintain a safe work environment. Laser Products Inc. Staff, support all the activities and proper actions required in order to comply with the regulations established by the Local Environmental Quality Board, the Environmental Protection Agency, the Occupational Safety and Health Administration, the Department of Transportation and the Local Fire Department. Our prevention program was develop mostly with information gathered from the different Chlorine Institute pamphlets and from our suppliers of Chlorine (Jones Chemical) , and Caustic Soda (PPG). Our emergency response plan includes the participation of the Plant operators, the Engineer in Charge, the Fire Department (4 differente cities) and the Local Civil Defense Office. All safety, health, prevention and emergency information is available to the public in the Fire Department, Civil Defense Office and the Local Health Department. We consider that the most impo rtant element related to the accident prevention program and the emergency response plan, is the people knowledge of the , product - process - equipment (operational & safety), involved in this operation. We expect to accomplish this thru continuous training and practice. II - The sodium hypochlorite manufacturing facility at our site, started in July 1997. Our product is registered and regulated by the EPA and the Agricultural Dept. as a pesticide. Recently was certified by the National Standard Foundation for drinking water disinfection and can be used also for waste water disifection. The location is outside-north (Road # 185) the urban zone of the city of Juncos, PR. The manufacturing process combine the use of tanks, pumps, pipelines, valves, heat exchangers, chiller and process control devices. Raw materials used are: Caustic Soda 50% liquid, Chlorine (liquified gas) in 2000 lbs. containers. We store some 150 lbs. chlorine for resale. Chlorine is a toxic gas that can cause da mage to human, animal and vegetation. There are always two persons in the plant when in operation. The process of manufacturing sodium hypochlorite is by the injection of chlorine to diluted caustic soda, at the required level. We store aproximately 50 tons containers and 22, 150 lbs. cylinders. There is a chlorine alarm detector and the proper safety equipment available in the plant. Plant operators are well trained in the use of both, process and safety equipment. III - We used the RMP*Comp version 1.06 to determine the distance endpoint for both, Worst Case and Alternative Release Scenarios. The WCS assumes the complete failure of the largest vessel at the facility, in this case a 2,000 pounds cylinder, in 10 minutes. The release rate of 200 pounds per min. with no mitigation measures in a rural zone was used. Estimated distance to endpoint is 3.0 miles for toxic level of 0.0087 mg/L (ERPG-2). Other assumptions were : wind speed of 1.5 meters/sec., stability class - F and a tempera ture of 77 degrees F. The estimated residencial population to toxic endpoint obtained was 24,700, using the 1990 US Census. Public receptors includes, schools, residences, hospitals, correctionals facilities, recreation, commercial, office and industrial areas. III - The ARS assumes a break in a 1/2 in. pipeline. Release duration of 10 sec., for a flow rate of 30 pounds/min. with no mitigation measures in a rural zone was used. Estimated distance to toxic endpoint is 0.8 miles for 0.0087 mg/L (ERPG-2). Other assumptions were : wind speed of 3 meters/sec., stability class D and a temperature of 77 degrees F. The estimated residencial population to toxic endpoint obtained was 1,100 using the 1990 US Census. Public receptors includes, schools, residences, correctional facilities and recreation areas. In both cases, environmental receptors includes National Forests and Wilderness areas. On june 10, we will review this results with the local Civil Defence and Fire Dept. for the proper pr eventive plan. IV - The most important practices in our accident release prevention program are as follow: -We will always use containers, hoses, clamps, adapters, valves, pipes, emergency kits, wrenches, SCBA and other related equipment to handle Chlorine, that are approved by the DOT, OSHA and the Chlorine Institute. -Operators will be continuously trained in the use of above equipment. -There will always be two operators when chlorinating. -We will keep periodic inspections and corrective actions to our containers, process control devices and operational and safety equipment. -Unauthorized personell will be restricted to the plant. -Hot works forbidden in the presence of cylinders, areas will be cleared of chlorine cylinders previous to work. -No more than one ton container connected at a time. -Chlorine injection rate of no more than 30 pounds per minute. -Safety equipment like SCBA and Emergency Kits will be in working conditions and available at any time. -We will work in accord ance with the recommendations of the Chlorine Institute. -Chlorine alarm detector to be in working conditions all the time. -We monitor vessels conditions and hydrostatic compliance. V - No accidental release of chlorine have occurred since the start up of the operation in 1997. VI - We have an emergency response program in place since July 1997 that includes the support from various local agencies like the Fire Dept. and the Civil Defense. We review it every year and include trainings on the use of SCBA and Chlorine Institute Emergency Kits "A" and "B". We perform drills with our own operators. We will conduct a drill every year in coordination with the local agencies starting in June 1999. VII - Only one major change has been implemented in the procedure since the start up of the operation. On May 1999, we decided to chlorinate more high strength sodium hypochlorite batches instead of low strength. With this action, we reduced the amount of times that we connect and disconnect ton s cylinders, lowering the possibilities of accidental releases when performing this operation. At this time we are not considering any major changes that will make a major effect in the operation. |