Pfister Chemical Inc. - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies Pfister Chemical is committed to protecting the public, employees, and the environment while producing chemicals that are important to industry and providing employment for its employees. This Executive Summary describes the regulated processes at this facility and the precautions that are taken to prevent the escape or release of noxious materials. Facility Description The Pfister plant occupies the area between US Route 46, the Overpeck Creek, and the north-south Conrail tracks, in Ridgefield, New Jersey, and consists of nine buildings, including administrative offices, a laboratory, and the Number 7 process building of interest. In this building, the regulated chemicals - bromine, nitric acid, and oleum - are used in four reactors. Although these are reactive and toxic materials, special procedures and controls are used in their handling and processing. As a result, there have been no serious incidents in volving these materials in twenty years of operation. Worst-Case Release Scenario Bromine is received in tank trucks or ISO containers that are approved by the U. S. Department of Transportation, having capacities up to 45,000 pounds. It is theoretically possible - but highly unlikely (because of the construction and safety devices) - that a container could rupture, and such an incident would be considered a "worst-case" scenario. The U. S. Environmental Protection Agency [USEPA] requires that the consequences of such an incident be determined, as is done in this Registration Report, and this involves an estimation of the maximum number of persons who possible could be affected. As a result of the low bromine concentration that could cause discomfort (less than one-hundreth of the life-threatening concentration), the downwind distance to which persons might be affected is significant. The USEPA "Offsite Consequence Analysis Guidance" [OCA] was used, together with a cens us program called "Landview", to determine the maximum downwind distance and the number of persons who could be exposed. Among the features which are provided to prevent the occurrence of the "worst-case" incident are devices to prevent overpressurization of containers, sprinkler protection against fire exposure of containers, excess-flow shutoff valves, full-time attendance by operators during unloading, leakage detectors, remote-controlled shutoff valves, enclosure and diking of the storage tank, and systems to control temperatures, pressures, container levels, and flows. Alternative Release Scenarios The USEPA also requires that consequences of "alternative" release scenarios be evaluated, such as leaks from piping or other equipment and for the other regulated materials (nitric acid and oleum). This report also presents the results of Offsite Consequence Analysis computations and "Landview" census summations for these materials. With the close control of storage, transfe rs, and processes, these "alternative" releases also are unlikely and would be stopped promptly. As a result, it is unlikely that the public or the environment would be affected by Pfister operations. Accidental Release Prevention Programs Operations involving bromine, nitric acid, and oleum (sulfur trioxide in sulfuric acid) are regulated by the "Process Safety Management" standard of the Occupational Safety and Health Administration and by the "Accidental Release Prevention" standard of the U. S. Environmental Protection Agency. To comply with these standards, Pfister follows strict guidelines for operating procedures, training of employees, analysis of processes for potential hazards, preventive maintenance programs, emergency plans, and investigation of incidents, with employee participation in this process safety effort. In addition, the Pfister facility has been involved in the New Jersey Toxic Catastrophe Prevention Act [NJTCPA] program since 1990, with annual reviews of the regulated processes, annual inspections of the facility by the New Jersey Department of Environmental Protection, and with two process-safety audits by an outside consultant since that date. Five-Year Accident History There have been no incidents involving release of bromine, nitric acid, or oleum in the past five years. The most-recent incident occurred on September 3, 1992, and involved the release of about 1/2 pound of bromine in a pump housing which was believed to be empty. An employee was injured when some of the bromine entered a glove, but there were no off-site effects. Emergency Response Program As a part of the NJTCPA program, the Pfister facility has conducted two emergency-response drills every year since 1990. Many of these drills involved the Ridgefield Police and Fire Departments, and the Local Emergency Planning Committee, as well as employees who are trained to recognize and respond to the simulated emergency situation and to actuate shutdown a nd other protective systems. Annual tours are arranged for members of the Fire Department, to show the locations of the unloading and storage facilities and fire protection systems. A weather station is maintained on-site, to provide information to local authorities regarding the protection of occupants of residences and business establishments in the downwind direction. Planned Changes to Improve Safety To provide additional containment in the trench system at the bromine and nitric acid unloading spot, the in-trench weirs are to be re-located. |