ChemArt Company - Executive Summary
2.0 EXECUTIVE SUMMARY |
This is a re-submittal of the RMP. It is our understanding that the EPA has misplaced the original, submitted on June 21, 1999. Attached please find a copy of the FedEx receipt noting arrival of the package at EPA, which was signed by R. Freeman at 8:59 AM on June 21, 1999. On or about June 23, 1999, a representative of EPA contacted Lincoln Environmental, Inc. and stated that the RMP submission should have been sent to Arlington, VA, and that Region One would forward it. They suggested a duplicate be sent. A duplicate disk was sent on or about June 23rd. The local LEPC was also given a printed copy of the electronic submission on or about June 23.
ChemArt is committed to an on-going chemical safety program with employee participation at every step of the process. ChemArt has established a Process Hazard Analysis (PHA) team to evaluate, develop, and implement a management system to control the hazards associated with chlorine. The team is made up of Che
mArt employees and outside contractors with knowledge and expertise in various areas of Process Safety Management (PSM). ChemArt employees involved in the PHA Team include operators, supervisors, and managers that are effected by the usage, storage and handling of chlorine. Personnel from the following groups and departments are included: Etching, Maintenance, Laboratory, Operations, Human Resources, Senior Process, and Plant Management.
In addition to ChemArt personnel, Mabbett & Associates, Inc. (M&A) was retained by ChemArt to participate in the PHA and to develop the written PSM Program.
The PSM Plan will be reviewed at least annually, when the process changes or the plan fails.
In addition to the PSM Plan ChemArt has implemented an employee Emergency Response Team trained in accordance to 29 CFR 1920.120 and equipped to respond to chlorine releases to Level A. ChemArt also maintains a chlorine cylinder repair kit with trained personnel.
2.1 Description of Facility and Regula
ChemArt manufacturers etched decorative metal parts. The manufacturing process involves automated etching equipment utilizing closed loop systems.
The primary hazard in this process is the release of chlorine. There have been no releases of chlorine from this process that could be classified as catastrophic since the original installation. The specific hazards of the process are described in the following paragraphs in terms of the chlorine flow from cylinder delivery to the regenerators on the etching tanks.
Four one-ton cylinders of liquid chlorine are stored in a cutoff storage room that shares two walls with the rest of the building. The cylinders are manifolded in pairs with one in each pair supplying chlorine to the system while the other cylinder is held in reserve. The cylinders are set on cradles that are part of the weighing system. There is a potential for chlorine release during the change-out of empty cylinders when pipes are disconnected, cylinders
are hoisted from their cradles, full cylinders are transferred from the delivery truck with an overhead crane, and pipes are reconnected. The delivery driver and a trained ChemArt employee use the standard operating procedures to minimize the risk of a catastrophic release during cylinder change-out.
The chlorine cylinders are positioned so that chlorine is withdrawn only from the gaseous phase. The gas pressure in the cylinders and in the withdrawal lines is the vapor pressure of chlorine at the temperature of the liquid in the cylinder. At 700F, the vapor pressure is approximately 85 psig. The Chlorine Storage Room is not climate controlled, so that in the warm weather seasons with temperatures as high as 900F, the pressure could rise to about 125 psig. In colder weather, the pressure would be less that 50 psig. The cylinders have fusible plugs that release at 159 - 1650F to prevent tank rupture during a fire. There are no sources of ignition or flammable materials in the Chlo
rine Storage Room; however, a fire in the rest of the building that engaged the room could cause the fusible plugs to release large quantities of liquid and gaseous chlorine. The evaporation of chlorine in the cylinders reduces the temperature of the liquid and the vapor pressure. Immediately next to each set of chlorine cylinders is a Capital Controls pressure regulator that reduces the pressure to below atmospheric for transmission through two chlorinated polyvinyl chloride (CPVC) pipes through the Plating Room and into the Etching room. The regenerators operate in such a way as to maintain the pressure in the CPVC supply lines below atmospheric. The regulators in the Chlorine Storage Room are set below atmospheric and will not deliver gas to the transmission lines if the pressure in the CPVC lines exceeds the sub atmospheric set point.
A chlorine sensor is positioned near the floor in the Chlorine Storage Room. An alarm sounds in the Plating Room outside the Chlorine Storage Ro
om if the chlorine concentration exceeds 2 ppm. If the alarm sounds, properly trained maintenance personnel would don protective equipment including self-contained breathing apparatus (SCBA) to enter the room, shut off the main cylinder valves and open the large doors to the outside. The irritating odor of chlorine is used for warning employees of releases in other parts of the facility. The procedure is described in the attached standard operating procedure included in Appendix A.
An etching solution regenerator is attached to each etching tank. The etching solution is circulated through educators and back to the etching tanks. The venturi effect of flow of liquid through the educator causes a partial vacuum to form which draws chlorine from the CPVC supply lines. Chlorine is automatically metered to the educators through valves actuated by a controller that responds to the oxidation-reduction potential in the etching solution. The action of the educators serves to keep the CP
VC chlorine supply lines under negative pressure all the way back to the pressure regulator in the Chlorine Storage Room.
Failure of engineering and administrative controls could result in the release of chlorine into the Chlorine Storage Room, the Maintenance Shop/Wastewater Treatment Area, the Etching Room, the Plating Room, and other parts of the plant. A What-If PHA analysis was used to identify possible failures at various points in the process, the consequences of those failures and the controls and procedures that are in place to prevent failures.
Chlorine is not released into the air in the Etching Room under normal operating conditions. Occasionally, there may be small releases that cause minor transient eye, nose or throat irritation. As exposures rise toward 5.0 ppm, severe irritation could be anticipated which might require medical treatment. Levels above 5.0 ppm of chlorine could cause permanent irreversible tissue damage and would be considered a catastrophic releas
e. It is anticipated that exposures above 5.0 ppm would be confined to the Chlorine Storage Room. If a release occurred in the chlorine storage room in excess of 2ppm, the alarm would sound and the plant would be evacuated according to established standard operating procedures. However, if a release were to occur in other areas of the plant, olfactory detection would prompt an evacuation of affected areas of the building before the concentration rose as high as 5.0 ppm. Because chlorine is so intensely irritating, concentrations in the air well below 1 ppm are readily detectable. Thus, only employees wearing appropriate personal protective equipment who enter the Chlorine Storage Room could potentially experience chlorine concentrations as high as 5.0 ppm.
2.2 Worst Case Release Scenario
A worst-case release scenario was conducted on the total release of one 2,000-pound cylinder. The analysis was performed using EPA's RMP Comp. As calculated by RMP Comp, the worst-case scenario
indicated that the end point concentration would be approximately 0.9 of mile radius. Within this 0.9 of mile radius, there are approximately 75 single and multi-family dwellings within the Hazard Zone. There are 45 manufacturing and commercial facilities, one apartment complex, a state airport, a mall, and a day care center.
2.3 Alternate Release Scenario
The alternate scenario release was also calculated using RMP Comp,( assuming a supply line failure with a 540 pound release. As calculated by RMP Comp, the hazard radius is 0.1 miles. Within this radius there are five commercial /industrial facilities.
Evacuation would be dependent on the wind direction and speed at the time of the release. Lime Rock Fire district has plans in place for notification and evacuation of the effected population.
2.4 Accidental Release Prevention Program and Emergency Response Program
All employees involved in the handling and use of chlorine are capable of operating the process on a day-to-
day basis. Special training was provided on the emergency procedures described in the attached standard PSM for catastrophic releases of chlorine. This included training and exercises in the use of Level A Protection, the selection and use of other types of personnel protective equipment and the use of the Chlorine Institute Emergency Kit. Satisfactory completion of this training was recorded in the training documentation record. The training record incorporates a certification that such covered employees have the knowledge, skills and abilities, based on classroom training and their hands-on experience, to carry out the daily duties and responsibilities specified in the operating procedures.
When employees are newly assigned to tasks associated with the chlorine process, they will be trained by the operations manager or designee and by employees currently involved in the process. At the completion of the training the employee will work for two weeks under the direct supervision
of the supervisor of the department to which the employee has been assigned. At the end of this period, the supervisor will initial the training record if the employee has demonstrated the appropriate level of competence. The period of supervision may be extended at the discretion of the supervisor.
Refresher training needed for daily operation of the process will be provided annually to all employees involved in the chlorine process. The program will consist of a one-hour classroom session covering the safety and health hazards of chlorine, emergency operations, safe work practices, and the controls that are in place to prevent catastrophic releases of chlorine. A training exercise in emergency release procedures will be conducted annually.
Whenever changes are made in the process such as increases in the use of chlorine or changes in control equipment and procedures, additional training will be provided at the time the changes are made. The scheduled refresher training will be
expanded if a process change has been made during the preceding year.
ChemArt has developed this Emergency Response Plan to protect employees, the public, and the environment in case of a chlorine gas release. This plan will be reviewed at least annually, when essential personnel change and if the plan fails.
Release of any amount of chlorine is a serious release due to the corrosive effects and trauma to the respiratory system of anyone exposed. OSHA has established a 1-PPM exposure limit for workers; NIOSH has established an IDLH for chlorine at 10 ppm. EPA has determined that the end point concentration of 0.008 ppm, which is less than the OSHA permissible exposure level, because of the low exposure level, requires immediate action to mitigate the release.
In order to respond quickly to any release ChemArt has established an on-site emergency response team trained to Level A and in the usage of a chlorine cylinder repair kit. All team members have received 24-ho
ur training in accordance to 29 CFR 1910.120(q). Annual 8-hour refresher training is conducted which includes hands on exercises relating to a chlorine release. Response equipment and personal protective equipment is maintained in a designated area within the facility and accessible to all response team members for immediate use.
ChemArt has designated the following individuals to act as emergency coordinators. ChemArt emergency coordinators have the authority to commit the necessary resources to mitigate a release of chlorine. It is their responsibility to implement this Emergency Response Plan, to direct response team activities, ensure all employees are evacuated and in a secure location and to provide assistance and support to fire department personnel when they arrive on the scene. At least one designated Emergency Coordinator will be at the facility during hours of operation. During non-working hours, emergency coordinators should always be within o
ne-hour travel time to the facility.
Designated Emergency Coordinators are:
Primary: Marc Forcier 401-789-7994
Secondary: David Marquis 401-729-4676
Tertiary: Dennis Taborelli 401-884-5220
ChemArt's facility consist of two separate buildings located at 11 New England Way, Lincoln, Rhode Island. The facility is located in an industrial park which contains a variety of businesses including electro plating, stone cutting, chemical suppliers, and building contractors.
ChemArt manufacturers decorative metal ornaments and awards. The major manufacturing process consist of metal etching using ferric chloride in automated etching machines. Support processes include plating, assembly, painting, and packaging. Chlorine is used in the process to regenerate the ferric chloride used for etching. This regeneration takes place at the machines with automated controls that monitor strength of solution and flow of chlorine.
ChemArt operates one shift five days a week with a flex time w
ork schedule. A full work shift would consist of approximately 91 employees.
The main process building is one floor with cement block walls and steel bar joust and roof decking with a built up asphalt roof. The office/assembly building consists of a one-story structure with a partial second floor above the administrative offices.
Both buildings contain approximately an equal amount of employees of about 45 to 50 employees. All buildings are equipped with active sprinkler system and fire alarms.
The process building contains storage areas for all hazardous chemicals including chlorine gas, acids, cyanides, and flammable liquids. Chlorine storage is located on the eastern end of the process building and contains four (4) two thousand-pound cylinders of chlorine. Other hazardous chemicals are stored in an interior room located mid point on the southern and of the process building.
Travel to ChemArt would be from Powder Hill Road to New England Way. Powder Hil
l Road is the nearest cross street. Responding fire and police units would be required to travel this route to reach the facility. There is no other access road into the industrial park. The nearest interstate is Interstate 295, which is approximately 0.8 of a mile from the facility.
Travel for trucks carrying hazardous material will likely travel from Interstate 295 to RI 146 to Route 116 south to Powder Hill Road to New England Way.
MSDS sheets are maintained throughout the facility for access by any employee. A master MSDS file is maintained by the Vice President of Operations.
Extremely Hazardous Substances
Chlorine is the only extremely hazardous substance above the threshold planning quantity. Normal operation could have as much as four (4) two thousand-pound cylinders and as low as two (2) two thousand-pound cylinders. Small quantities of acids, caustics, cyanides, and flammable liquids are on hand. These quantities would not exceed 110 gallons.
Upon discovery of chlorine release, the following actions shall be taken.
Leak in Chlorine Storage Room:
1) Alarm would sound.
2) Evacuate the building in accordance with ChemArt's evacuation procedure
3) Invoke ChemArt's Emergency Response Plan. Notify the Lime Rock Fire Department and Lincoln Environmental, Inc. in accordance with the plan.
4) Notify chlorine supplier and request assistance.
5) Don respiratory equipment and personal protective equipment (four people minimum).
6) Open the personnel door to the Chlorine Storage Room and assess the situation.
7) If safe to enter, open the large exterior doors to the Chlorine Storage Room.
8) Assess the situation. If safe to work, proceed with stopping the leak. If unsafe, evacuate and wait for assistance.
9) If the leak is not in the chlorine cylinder, shut off the valves on the chlorine cylinder(s).
10) If the leak is in the chlorine cylinder, assess the problem and perform the repairs in accordance with the
Chlorine Institute Emergency Kit "B" Instructions.
11) Close out emergency response and cleanup procedure in accordance with ChemArt's Emergency Response Plan.
Oxidation - Reduction (Redox) potential is too high in the Etcher/Regenerator.
This would be accompanied by a release of free chlorine to the local exhaust system or the room.
1) Immediately notify the emergency response coordinator who will determine if the building is to be evacuated, the emergency response plan is to be implemented, and the requirement for use of respiratory equipment and personal protective equipment by responders is necessary.
2) Close the chlorine valve(s) on the affected etcher(s).
3) Add brass (copper) sheets to the etcher until the redox potential falls below 590. This will chemically reduce iron which then allows chlorine to be consumed.
4) Assess the problem and perform the necessary repairs.
Notification of other agencies will be the responsibility of the Emergency Coordinator when the assessm
ent of the release has been evaluated. Initial notification will be given by the Limerock Fire Department.
Hazmat Response Resources
ChemArt has a trained emergency response team in place. All members have received training as outlined by 29 CFR 1910.120(g). Members are trained to Level A response.
The Level A response team consists of eight members which includes:
* Two entry teams
* One emergency coordinator
* Three support personnel for Decon, etc.
* Five 30-minutes North 8800 SCBA with spare bottle
* Four Tychem 10,000 Level A rear entry suits.
* Outer boots
* Outer shoes
* Five portable walkie talkies
* Decon equipment for a two stage decon
* Air sampling equipment (MSA detector tub for chlorine)
Emergency Public Information
Emergency public notification and evacuation will be the responsibility of the Lincoln Police Department. The evacuation radius could exceed a one-mile radius. Notification would require door to door contact.
Hazard Zone Evacuation
he Emergency Planning Zone as calculated by EPA RMP Comp Program( is 0.9 mile radius for a catastrophic release and as low as 0.1 mile for the alternate scenario release.
Population in the effected areas include commercial and residential neighborhoods, a shopping mall, daycare center, and elderly housing. Depending on wind direction and type of release, the Lincoln Police Department would notify door to door effected residences, commercial buildings, etc.
Transient populations include shoppers at the Lincoln Mall, fast food restaurants, a walk-in medical clinic, and portions of Interstate 295 and Route 146.
Topography Surrounding the Facility
The area to the East and South in woodlands for a distance of approximately one half mile to the north is commercial facilities, mall, and Route 116 and Interstate 295. To the southwest is North Central Airport and the Lincoln Industrial Park.
EMERGENCY RESPONSE PLAN
11 NEW ENGLAND WAY
INCOLN, RHODE ISLAND