Delta and Pine Land Company - Aiken, TX - Executive Summary |
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Delta and Pine Land company is an agricultural research and seed packaging operation located in Aiken, TX. As part of our cotton seed packaging activities, we use anhydrous hydrogen chloride (HCL). Delta and Pine Land is committed to operating this process safely and comply with all regulations regarding HCL, including OSHA Process Safety Management and EPA Risk Management. A maximum amount of 21,000 pounds of hydrogen chloride gas is maintained onsite for use in the removal of lint from cottonseed (Delinting). The chemical is delivered and stored in a 7 - container tube trailer. Each tube contains 3,000 pounds of product and only one tube of HCL gas at a time is used for delinting. HCL is only used during the cotton delinting season (September - May). As part of the requirements of Risk Management Planning, Delta and Pine land has conducted off-site consequence analyses for HCL release. Both a "worst-case" and an alternative-release scenario have been conducted. As required by E PA, the worst-case scenario considered a failure of a single tank of HCL and release of the entire contents (3,000 pounds) over a 10 minute period. Using guidance published by EPA and EPA's RMP Comp. release modeling software, it was determined that the toxic cloud formed by the release could reach offsite receptors. For the alternative release scenario, a vessel leak over a 60 minute period was considered. Using RMP Comp, it was found that this type of leak could not reach off-site public receptors. It should be noted that Delta and Pine Land has not had a reportable release of HCL in the past 5 years. In order to protect our employees and the local community, Delta and Pine Land has implemented an incident prevention program for the process. This prevention program has many elements including employee training, preventive maintenance, safe operating procedures, hazard analysis and identification, incident investigation and emergency operation procedures. The best safet y features of the process are those that we have built into the design. These include emergency shut-downs, one-way check valves, and ventilation systems, among others. The emergency shut-down device alone should succeed in stopping the majority of potential releases identified in our hazard assessment. Although we believe that the majority of potential releases can be stopped by the engineering and administrative controls utilized in the process, Delta and Pine Land will coordinate with local emergency personnel if a release should occur. At the present time, we would depend on these local emergency personnel to provide release response, however, as part of our commitment to constantly improving the safety of our systems, we are considering training a number of facility personnel to provide emergency response. Other planned improvements include refinement of operating procedures and installation of additional control measures recommended during the hazard assessment. |