Solvay Fluorides, Inc. - Executive Summary |
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RISK MANAGEMENT PLAN EXECUTIVE SUMMARY SOLVAY FLUORIDES, INC. 1.0 Introduction Solvay Fluorides, Inc. is committed to operating in a manner that is safe for our employees, the public, and the environment. As part of this commitment, Solvay Fluorides, Inc. has established a system to help ensure safe operation of the processes at this facility. One component of this system is a risk management program (RMP) that helps manage the risks at Solvay Fluorides, Inc. and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at Solvay Fluorides, Inc. This plan is intended to satisfy the RMPlan requirement of the RMP rule ('68.150 through '68.185) and to provide the public with a description of the risk management program at Solv ay Fluorides, Inc. 2.0 Accidental Release Prevention and Emergency Response Policies Solvay Fluorides, Inc. is committed to the safety of our employees and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. Solvay Fluorides, Inc. implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, Solvay Fluorides, Inc. controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. 3.0 Facility Processes and Regulated Substances Solvay Fluorides, Inc. manufactures a dry brazing flux for the automotive industry. The manufacturing process uses aqueous hydrofluoric acid (HF). HF acid at solution concentrations of 50% or greater are regulated by the RMP rule. And although only dilute (about 25 wt.%) HF acid solutions are used in the manufacturing process, HF acid at a solution conc entration of 70% is stored in a large tank at the facility for use in the process. A maximum of 7,200 gallons of 70% HF acid is stored in one 8,000 gallon tank located in the middle of the Solvay Fluorides, Inc. site. The weight of HF acid in 7,200 gallons of 70% solution is right at 75,000 lb., which exceeds the RMP rule threshold quantity for HF acid in a process (1,000 lb.). Because the HF acid storage creates the potential for offsite consequences resulting from an accidental release of HF acid and the specific use of the acid falls under one of the 10 "targeted" NAICS codes, the process falls under the RMP Program 3 prevention program. 4.0 Offsite Consequence Analysis The RMP rule requires Solvay Fluorides, Inc. to perform an offsite consequence analysis for one worst-case and one alternative release scenario for aqueous HF acid, a toxic substance. The worst-case release scenario is failure of the 8,000-gallon storage tank releasing 75,000 lb. of aqueous HF acid (70 wt.%). A dik ed area contains the released aqueous HF acid, which evaporates, forming a vapor cloud. The maximum distance to the toxic endpoint concentration is well beyond our site perimeter.. Several houses are located within this distance from the release, with a total population of about 20 people; no environmental receptors are within this distance. There are number of commercial operations within this distance with a daytime workforce of about 2,000. The alternative release scenario for aqueous hydrofluoric acid is rupture of a 2-inch diameter liquid line connecting the aqueous HF acid (70 wt.%) storage tank to the process vessels. This scenario assumes that the solution's release is not discovered for 10 minutes at which the line is isolated and leaking ceases. The released acid forms a pool, with HF evaporating from the pool and forming a vapor cloud. The maximum distance to the toxic endpoint is 0.19 mile. No residences are located within this perimeter from the storage tank. There are no environmental receptors within this distance. There are three commercial operations in this distance. 5.0 Accidental Release Prevention Program and Chemical-specific Prevention Steps The RMP rule requires a Program 3 prevention program for the aqueous HF acid storage process. The following paragraphs describe the prevention program elements at Solvay Fluorides, Inc. which apply to this unit. Safety Information Solvay Fluorides, Inc. maintains a variety of technical documents that are used to help ensure safe operations of the covered process. Material Safety Data Sheets (MSDS) document the physical properties of hazardous substances handled at Solvay Fluorides, Inc., including HF Acid. The engineering design documents include the operating parameters, the design basis and configuration of the equipment of the covered process, and references to applicable codes and standards. Hazard Review Solvay Fluorides, Inc. performs and periodically updates hazard reviews of the HF acid sto rage process to help identify and control process hazards. Checklists include items to help ensure that Solvay Fluorides, Inc. operates and maintains the equipment in a manner consistent with the applicable design specifications, codes, standards, and regulations. Operating Procedures Solvay Fluorides, Inc. is an ISO9000/QS9000 certified company. As such we are required to develop and maintain operating procedures to define how tasks related to process operations should be performed. The operating procedures are used to (1) train employees and contractors and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Training Solvay Fluorides, Inc. trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks. A training documentation file is maintained to help ensure that refresher training is provided, as necessary. Maintenance Solvay Fluorides, Inc. properly maintains the proces s equipment. The maintenance program includes (1) procedures to safely guide workers in their maintenance tasks, (2) worker training in the maintenance procedures, and (3) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails. Management of Change Solvay Fluorides, Inc. has a program in place to document changes to the process. A significant change in process chemicals, technology, equipment, practices or procedures prompt implementation of this program. The program is designed to (1) evaluate the impact of the change on the process, (2) update records on the process and (3) ensure that workers are informed and trained on any changes. Pre-startup Review Solvay Fluorides, Inc. performs audits on a new process or an existing process that has under gone a modification affecting the safety information. This review is done prior to operating. The review (1) confirms proper equipment was used, (2) safety, operating, mainten ance, and emergency procedures are updated, (3) a hazard evaluation has been conducted, and (4) training has been updated. Compliance Audits Solvay Fluorides, Inc. performs periodic compliance audits of the covered process to verify that the process is operating in compliance with the requirements of the RMP rule. A compliance audit report is prepared after each audit, and any deficiencies noted by the audit are corrected in a timely manner. Incident Investigations Solvay Fluorides, Inc. investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment. The company trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. Employee Participation Solvay Fluorides, Inc. requ ires participation by the effected employees in development (1) of the process hazard evaluation, (2) process safety management, and (3) operating procedures of all covered processes. The employees that work with or maintain the processes are given access to all information required under the rule. Hot Work Permit Solvay Fluorides, Inc. has written safety practices in place for fire protection and process operation. A permitting system is used to prevent any unsafe acts on or around the covered process. Contractors Solvay Fluorides, Inc. reviews all contractors prior to working on or near a covered process. The contractor must demonstrate that the work will be performed competently and safely. The company will provide information on the hazards of the process and the safety practices in place. Documents are kept to confirm that the information was received and understood. HF Acid-specific Prevention Steps Industry standards are followed at Solvay Fluorides, Inc. to help ensure safe han dling of aqueous HF acid. The vendor supplies aqueous HF acid via a Department of Transportation (DOT) approved tank truck and follows DOT standards when loading the aqueous HF acid storage tank. The storage tank design and construction are consistent with American National Standards Institute codes. Workers who perform operations involving HF acid receive training emphasizing safe handling procedures for HF acid developed by Solvay Fluorides, Inc. 6.0 FIVE-YEAR ACCIDENT HISTORY Solvay Fluorides, Inc. maintains a 5-year accident history that fulfills the requirements of the RMP rule ('68.42). This history indicates a good record of accidental release prevention over the past 3 years and 9 months that the facility has been in existence. No releases of regulated substances have occurred from Solvay Fluorides, Inc. in that time that have resulted in consequences of interest (i.e., deaths, injuries, or significant property damage on site; or known deaths, injuries, evacua tions, sheltering-in-place, property damage, or environmental damage off site). 7.0 EMERGENCY RESPONSE PROGRAM Solvay Fluorides, Inc. has established a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations. This plan has been communicated to local emergency response officials through the local fire department. Regular dialogue is maintained between the facility and the local response personnel, and the company provides appropriate information to the fire chief. Solvay Fluorides, Inc. periodically conducts emergency response drills, including annual drills coordinated with the local response authorities. 8.0 PLANNED CHANGES TO IMPROVE SAFETY Solvay Fluorides, Inc. constantly strives to improve the safety of the processes at the plant through both the incident investigation program and a program soliciting safety suggestions from the workers. The following changes to improve process safety are planned or have been recently been completed: 7 A manually activated emergency button has been installed on the HF tank platform to alert personnel inside the building of an incident immediately. This will protect employees working on the tank platform and alert personnel inside quickly to engage the remote closure valve on the HF tank. 7 Continuous HF detectors are to be purchased to provide early warning to plant personnel in the event of a leak in the HF acid storage or transfer system. 7 An additional shower is to be placed on the tank platform. 7 Non-flanged pipe runs from the tank to the reactors are being considered to do away with the potential of leakage at flange connections during HF acid transfers. |