IOCHEM CORPORATION - Executive Summary |
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STATIONARY SOURCE AND PROCESS Iochem produces iodine from sodium iodide at a facility located near Vici, OK. Sodium iodide is extracted from brine production wells. Brine flows from the wells to the facility where the iodide containing brines are oxidized with chlorine and converts the iodides to elemental iodine vapor. Iodine vapor is stripped and reabsorbed into a more concentrated iodide solution with the addition of sulfur dioxide. This solution is again oxidized to solid elemental iodine that is melted, flaked, and packaged into fiber drums. EPA regulated substances in this single process are toxic chemicals chlorine and sulfur dioxide. These substances are stored in adjacent tanks under pressure in the liquid state. The liquids are vaporized and piped to the processing units. Maximum inventory is 91,536 pounds of chlorine and 73,790 pounds of sulfur dioxide, which exceeds EPA's threshold quantities of 2,500 and 5,000 pounds respectively. OFFSITE HAZARD ASSESSMENT In th e event that the regulated substance is released to the atmosphere, EPA requires that the facility provide an offsite hazard assessment and consequence analysis. This must include analyzing two release scenarios (Worse Case and Alternate Case) to determine the toxic end point. Toxic end point is based on ERPG-2 concentrations developed by the American Industrial Hygiene Association (AIHA). The ERPG-2 is a maximum air borne concentration in which is believed that almost all individuals could be exposed for up to one hour without developing serious irreversible health effects or other symptoms that could impair an individuals ability to take protective action. AIHA has identified the toxic end point for chlorine and sulfur dioxide as .0087 mg/l and .0078 mg/l respectively. The worse case scenario is releasing in ten minutes the entire contents of pressurized sulfur dioxide from the storage tank into the partially open building. The partial enclosure is a passive mitigating factor. The toxic end point as modeled by EPA's RMP*Comp software is 17 miles. Modeling does not include the effects of fires, chemical reactions, and other factors. The Alternate Case is more likely to occur than the Worse Case. An alternate case is required for each toxic chemical. For chlorine and sulfur dioxide, the scenario is ?" leak from ruptured tubing or pipe. Operator's response time to stop the leak is estimated at 60 minutes. Release rates are 8.2 and 3.4 pounds/min respectively. Toxic end points are .1 mile radius from each storage tank. PREVENTION OF RELEASE The process is designed in compliance with recognized and generally accepted good engineering practices as shown in the Process Safety Information according to Process Safety Management (PSM). It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle sulfur dioxide and chlorine, safety devices inherent in the design of this facility, safe handling and operating procedures, and training of our personnel. By emphasizing at Iochem well-maintained equipment, proper procedures, and well-trained staff, the likelihood of a release will be reduced. Recommendations for addressing the process hazards that are generated in the PHA, compliance audits, incident investigations, and management of change are used to improve the process safety. Prevention Program 3 (PSM) as described in 40 CFR Part 68 is followed to accomplish these goals and will minimize the potential for an unplanned release of the regulated substances into the environment. FIVE YEAR ACCIDENT HISTORY In the past five years, no accidental releases have occurred. EMERGENCY RESPONSE PROGRAM Iochem is a non-responding facility to an accidental release of hazardous substances. The employees will not conduct a full-fledged response to the release. Instead, they will evacuate and coordinate with Vici Voluntary Fire Department. Iochem has ensured that the Vici Fire Department is prepared to respond to an emergency at the plant. The plant has prepared an emergency action plan that includes evacuation procedures and is subject to OSHA 29 CFR 1910.38. |