Scott Specialty Gases - Executive Summary |
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(a) The accidental release prevention and emergency response policies at the facility: Scott Specialty Gases, Northeast Region, is recipient of the Corporate Board of Director's Safety Award and the Compressed Gas Association Safety Award. Safety is our number one priority with an in-house emergency response team, a detailed, computerized preventive maintenance program, written standard operating procedures, more than three years without a lost-time accident and over five years without an accidental release. From the owner of the company, down through the regional Vice President, to the newest employee, Scott Specialty Gases is committed to safety as a neighbor and concerned member of the community. (b) The facility and regulated substances handled: Scott is a regional manufacture of specialty gases, including gas mixtures and filling of pure gas products. Our company purifies and transfills chlorine and hydrogen chloride (the two regulated substances at the facility) into a vari ety of cylinder sizes to meet customer needs. The purification and transfill manifolds for both systems are essentially identical, except for a few components due to the pressures and rating of the two chemicals. The scrubber, monitoring, alarm and other systems are common to both processes. (c) The worst-case release scenario and the alternative release scenarios: The worst-case release scenario is complete evacuation of a one-ton cylinder of chlorine into the atmosphere. Chlorine is purified from one-ton containers at the site and transfilled into smaller containers from 150 pound cylinders down to less than one pound cylinders (100 pound cylinders are the most common). The impact was calculated using the EPA RMP*Comp (TM) modeling program. Because the process is enclosed, mitigation was entered into the equation, resulting in an endpoint of 3.5 miles from the facility. The population impact was estimated at 170,000 people, with no environmental receptors within the distance to the endpoint, using LandView III (TM) as the modeling program. The alternative release scenarios were (1) complete evacuation of a cylinder filled with 100 pounds of chlorine and (2) complete evacuation of a cylinder filled with 60 pounds of hydrogen chloride. These are the most common size cylinders handled at the facility and a release could occur if the cylinders were overfilled and the fill hose broke off, leaving an evacuation point the size of the cylinder valve opening. This would be mitigated by the enclosure of the building and the facility's scrubber system, which is designed to neutralize 100% of these types of releases. However, for these alternative release scenarios and in the unlikely event that breakthrough could occur in the scrubber system, it was assumed that the scrubber would only neutralize 75% of the released product, resulting in endpoints of 0.30 miles for chlorine and 0.15 miles for hydrogen chloride as calculated by RMP*Comp (TM). The population impac t was estimated at 1,400 and 270 people respectively, with no environmental receptors within the distance to the endpoint, using LandView III (TM) as the modeling point. (d) The general accidental release prevention program and chemical-specific prevention steps: The facility has highly trained operators, with many years of experience handling the regulated substances. However, this does not replace the need for detailed operating procedures, following strict guidelines, in accordance with applicable Compressed Gas Association recommendations. In addition, the facility has a comprehensive preventive maintenance program, an alarm system that is monitored continuously both internally and by an outside monitoring company and an extensive emergency response program. The scrubber system is also checked on a daily basis by the EHS operators and a two person "buddy" system is adhered to at all times in the plant. (e) The five-year accident history: The facility has had no accidents in the past five years. (f) The emergency response program: Almost 30% of the personnel on site are part of the emergency response team. The program is centered around the elements of public awareness and notification, personnel training, including facility drills and on-site hazmat courses, detailed evacuation and response procedures in the event of a release, proper first-aid treatment, emergency response equipment and periodic reviews. A comprehensive written program is maintained on site, as well as provided to the local fire, police and emergency planning departments. (g) Planned changes to improve safety: While the facility has the capability of handling 600 pound containers of hydrogen chloride, we have chosen not to handle them so the overall inventory of regulated substances is reduced. In addition, it is a normal policy to empty one ton of chlorine before bringing a new ton to the facility, so inventory levels are maintained at the lowest level possible. The facility pla ns to install a scrubber heater and secondary level monitoring system to increase efficiency during cold weather operation. |