Chicago Specialties 115th Street - Executive Summary |
|
Executive Summary Facility Information The Chicago Specialties plant has approximately 130 employees. The facility produces organic dyes and pigments and intermediate cyclic organics. Chicago Specialties uses three regulated chemicals in processes above threshold quantities. The facility uses sulfur trioxide as a feed material in the manufacture of paracresol, and sulfur dioxide as a diluent in the paracresol process. The facility stores up to 215,000 pounds of sulfur trioxide in an indoor storage vessel, and up to 50,000 pounds of sulfur dioxide in an outdoor storage vessel. The facility also uses anhydrous ammonia as a feed material in the production of isopthalonitrile. The regulated anhydrous ammonia process is a storage vessel, which can store up to 175,000 pounds of the material. Risk Management Planning In addition to our existing information sharing practices, Community Right-to-Know, emissions inventories, and Title V Permit, Chicago Specialties shares in formation regarding the chemicals used and their associated risk with the public. The facility uses both passive and active mitigation to minimize the likelihood of releases and their impact to the public and to the environment. These mitigation systems emergency shutdown equipment and revised operating procedures and equipment for the covered sulfur dioxide process. The sulfur trioxide process uses dikes, sumps, emergency shutdown equipment, and a CO2 cryogenic mitigation system, which entails freezing the material if released. Accident History and Safety Improvements The table below lists Chicago Specialties' five-year accident history of all accidental releases from covered processes, which resulted in off-site evacuations, shelter-in-place, property or environmental damage, injuries, or significant property damage on-site. The incident in 1997 occurred on August 4. During the incident a transfer hose failure released 8,500 pounds of sulfur trioxide in to the envir onment, of which 7,000 pounds were released to the atmosphere. A portion of the local vicinity was evacuated. There were no deaths or off-site property damage associated with this accident. The facility conducted an extensive safety review after the incident. Chicago Specialties has determined that the most likely cause of the accident was water the unloading connections of the tanker truck, which was loading sulfur trioxide into the facility's storage tank. The facility has subsequently installed several safety measures to reduce the likelihood of a reoccurrence of this type of incident: improved and upgraded equipment involved in the process, revised training, maintenance, emergency response plans, and operating procedures. The facility also installed new mitigation systems, which significantly reduced the risk of such an occurrence happening again. Chicago Specialties' 5-year Accident History The five year accident history was prepared in accordance with 68.42. T he accidents reported in the RMP data elements only include accidents related to a regulated chemical (SO2, SO3 or Anhydrous Ammonia) that resulted in deaths, injuries, or significant property damage on-site or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. There were four releases of regulated chemicals in the past five years. Only the August 04, 1997 release meets the requirements of 68.42 for a release which must be reported. Year 1994 1995 1996 1997 1998 Number 0 0 0 1 0 Prevention Program Chicago Specialties believes the best way to manage risk is to prevent accidents. Chicago Specialties has performed a HAZOP analysis to identify and reduce the risk posed by the RMP covered processes. The prevention program will continue to reduce the risk through improved safety. Chicago Specialties' process safety management program includes but is not limited to; process safety information, operating procedures, tr aining, pre-startup safety review, mechanical integrity, and management of change. In addition, the facility has incorporated process controls including, relief and check valves, manual and automatic shutoffs, interlocks, alarms, backup pumps, grounding equipment, rupture disks, sprinkler systems, fire walls and blast walls where appropriate. Emergency Response Policy Chicago Specialties has coordinated with the Local Emergency Preparedness Committee (LEPC) and Fire Chief Frank Moriarty. Chicago Specialties has prepared an extensive written emergency response plan. Specifically, the emergency response plan works to minimize the amount of material released to the environment and to establish control and mitigation of any releases in an expedited manner while communicating the nature of the incident to the public and local agencies. Worst-Case Release Scenario and Alternative Release Scenarios The RMP rule requires development of scenarios or examples for an accidental rel ease of each RMP regulated chemical. The scenarios developed for Chicago Specialties are outlined in the table below. Chemical About the Chemical Release Type Accident Prevention In- Place Scenario Description Emergency Response Measures Sulfur Trioxide Colorless liquid, forms crystals at 90oF Worst-case Release ? Standard Operating Procedures ? Tank Inspections ? Instantaneous failure of tank walls ? Worst possible weather conditions (low wind, low humidity) ? Total release of entire contents of tank (215,000 lbs) inside the building ? Communication with public agencies; ? Coordinate with LEPC; ? Emergency Response Plan; ? Personal Protective Equipment; ? Response Equipment. Sulfur Dioxide Sulfur Dioxide is a colorless gas or liquid, with a strong pungent odor. Alternative Case Release ? Relief Valves ? Rupture Disk ? Manual Shutoffs ? Automatic Shutoffs ? Interlocks ? Rupture disk over-pressurization ? Average weather conditions ? Duration of vent release - 4 minutes See above Sulfur Trioxide Colorless liquid, forms crystals at 90oF Alternative Case Release ? Relief Valves ? Rupture Disk ? Manual Shutoffs ? Automatic Shutoffs ? Interlocks ? Transfer hose rupture ? Average weather conditions ? Release of 8,500 lbs. See above Anhydrous Ammonia Colorless caustic gas with pungent odor Alternative Case Release ? Relief Valves ? Rupture Disk ? Manual Shutoffs ? Automatic Shutoffs ? Interlocks ? 2,100 lb/min release per EPA RMP Ammonia Guidance Document See above |