Delta Chemical Corporation - Executive Summary

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Delta Chemical Corporation manufactures chemicals and repackages chlorine used in water and wastewater treatment and general industry.  Delta Chemical Corporation manufactures Aluminum Sulfate, Sodium Aluminate, Polyaluminum Chloride, Polymer and Sodium Hypochlorite (bleach).  The raw materials in Polymer that exceed the reporting threshold are Formaldehyde and Dimethylamine.  Formaldehyde is in an aqueous solution and stored in an 8,000-gallon tank at the facility.  The Dimethylamine is also in an aqueous solution and stored in an 8,000-gallon tank on site, although administrative controls limit the storage to 7,000 gallons.  Delta Chemical Corporation uses a 54 step truck unloading process to ensure the safe unloading/delivery of the Formaldehyde and Dimethylamine to our facility.  Dimethylamine and Formaldehyde storage tanks have secondary containment to prevent the spread of the material if a leak would develop in the storage tank area.  During the unloading/delivery of these chemi 
cals to our facility, a Delta Chemical Corporation employee is stationed at the truck with the truck driver to quickly engage the emergency-shutoff valve if a leak should occur.  The tanker truck unloading area is sloped toward a containment sump to stop the spread of a leak outside the secondary containment wall.  Dimethylamine is our worst case flammable and alternate case flammable.  Formaldehyde is an alternate case toxic. 
 
Delta Chemical Corporation repackages chlorine into 1 ton, 150 lb. cylinders and 100 lb. cylinders directly from a 90-ton railcar.  Chlorine is also used in the manufacture of Sodium Hypochlorite (bleach).  During the transfer of chlorine from the railcar, an automatic railcar shut off device is used as well as automatic chlorine pipeline pneumaticially operated closure valves.  This equipment is tied into the alarm system and if the chlorine limit is exceeded in the atmophere or a panic button is pushed, the chlorine alarm sets off an audible alarm to warn plan 
t personnel and automaticially turns off the flow of chlorine at the railcar and pipeline.  The worst case toxic scenario is based upon a catastrosphic failure of a chlorine railcar (180,000 lb.).  Chlorine is also an alternate case toxic with the failure of a chlorine railcar unloading hose being the alternate case toxic scenario. 
 
Delta Chemical Corporation is committed to handling chemicals responsibly and through various associations subscribes to the principles of the Responsible Care (R) program.  This includes continual environmental, health and safety training for plant employees as well as training our customers in the safe use of our products.  At Delta Chemical Corporation we believe that all jobs can be accomplished without injury to employees or harm to the environment.  Delta Chemical Corporation maintains a Hazardous Material Response Team that will respond to any chemical release at our facility or customer's facilities.  The Hazardous Materials Response Team has monthl 
y meetings along with practice drills to maintain proficiency. 
 
The information regarding population and receptors was taken from Landview III and is made available at "The Right to Know Network" web site.  This program can be downloaded at www.rtk.net/landview. 
 
 
WORST AND ALTERNATE CASE SCENARIOS 
 
Delta Chemical corporation has completed the Offsite Consequence Analysis and the results are summarized below: 
 
Scenario Desription                                        Endpoint of Interest                         Distance to Endpoint 
 
Worst Case Toxic - Chlorine                          ERPG 2 - 0.0087 mg/L                            14.00 miles 
Worst Case Flammable - Dimethylamine        Overpressure of 1 psi                                0.20 miles 
Alternate Case Toxic - Chlorine                     ERPG 2 - 0.0087 mg/L                                0.30 miles 
Alternate Case Toxic - Formaldehyde            ERPG 2 - 0.012 mg/L                                  0.10 miles 
Alternate Cas 
e Flammable - Dimethylamine   Overpressure of 1 psi                                0.03 miles 
 
 
Worst Case Toxic Scenario - Chlorine 
 
Delta Chemical Corporation typically retains two 90-ton chlorine railcars onsite, although one is utilized in the process at a time.  The model used for this scenario was the EPA's RMP COMP.  This scenario is based on one railcar releasing the chlorine at a rate of 18,000 lbs./min. for a total of 10 minutes.  The following assumptions were made: 
 
- The surface roughness was urban. 
- Meteorological conditions: 
    Stability Class                          F 
    Wind Speed                            1.5 m/s 
    Atmospheric Temperature      77 degrees F 
 
 
Worst Case Flammable - Dimethylamine 60% (DMA) 
 
Delta Chemical Corporation has one listed flammable onsite: Dimethylamine (DMA).  The DMA is stored as a 60% Dimethylamine and 40% water solution.  Administrative controls limit the total tank capacity to 7,000 gallons.  The storage tank has secondary conta 
inment and a nitrogen blanket is placed on the storage tank, but these mitigation measures are not relevant to a vapor cloud explosion release scenario.  The model used was the EPA's RMP COMP for this scenario.  The following assumptions were made: 
 
- The DMA tank has a catastrosphic failure. 
- Although the DMA is an aqueous solution, only the DMA portion, 32,769 lbs. was considered to take part in the vapor cloud explosion.  It is assumed that the water would have an insignificant effect on the consequences. 
- The surface roughness was urban. 
- Explosion overpressure level 1 = 1 psi 
- Meteorolgical conditions: 
    Stability Class                         F 
    Wind Speed                            1.5 m/s 
    Atmospheric Temperature      77% 
 
 
Alternate Case Toxic Scenario - Chlorine 
 
Delta Chemical Corporation's alternate case toxic scenario involves the catastrosphic failure of a 1-inch monell unloading hose connecting a 90-ton railcar of chlorine to our process.  If the hose were 
to catrotrosphicailly fail, the local chlorine atmospheric monitors energizes and shuts the automatic chlorine pipeline pneumaticailly operated closure valve in 1 second, the excess flow valve on the railcar limits the flow to a maximum of 250 lbs./minute (but does not stop the flow) and the air motors located on top of the angle valves on the railcar would stop the flow from the railcar in 10 seconds.  The amount released in the scenario is 43 lbs. in 10 seconds from the railcar through the angle valve plus an estimated 50 lbs. over 30 seconds from the hose and piping up to the automatic chlorine pipeline pneumaticially operated closure valve on the pipeline.  The total release would be 93 lbs. (43 + 50 ).  The model used for this scenario was the EPA's RMP COMP.  The following assumptions were made: 
 
- The surface roughness was urban. 
- Local atmospheric chlorine monitors energize and shut the automatic chlorine pipeline pneumatically operated closure valve in 1 second. 
- The excess 
flow valve limits the flow to 250 lbs./minute (but does not stop the flow). 
- The automatic railcar angle valve shut-off device is engaged by chlorine atmospheric monitors and the flow stops from the railcar in 10 seconds. 
- Meteorolical Conditions: 
    Stability Class                         D 
    Wind Speed                            3 m/s 
    Atmospheric Temperature      77 degrees F 
 
 
Alternate Case Toxic Scenario - Formaldehyde 37% 
 
Delta Chemical Corporation's alternate case toxic scenario involves a leaking unloading hose during the unloading/delivery of a tanker truck of Formaldehyde to our facility.  A 54 step checklist is used to ensure the safe unloading/delivery of Formaldehyde and therefore a Delta Chemical Corporation employee is able to turn off the emergency shutoff valve on the delivery truck within one minute and that a maximum of 542 lbs. is spilled.  The spill would take place on a concrete pad that slopes towards a sump.  There is a backflow device on the stora 
ge tank to prevent additional product from escaping backwards from the storage tank.  The EPA's RMP COMP was used for this scenario.  The following assumptions were made: 
 
- The surface roughness was urban. 
- An Active Mitigation factor of 0.5 is used.  A Delta Chemical Corporation employee is always stationed with the truck during unloading/delivery of Formaldehyde and can stop the flow within one minute and activate the Delta Chemical Corporation HAZMAT Team to contain and begin neutralizing the spill. 
- Meteorological Conditions: 
    Stability Class                         D 
    Wind Speed                            3 m/s 
    Atmospheric Temperature      77 degrees F 
 
 
Alternate Case Flammable - Dimethylamine 60% (DMA) 
 
Delta Chemical Corporation's alternate case flammable scenario involves a leaking unloading hose when DMA is unloaded/delivered from a tanker truck to the storage tank at our site.  A 54 step checklist is used to ensure the safe unloading/transfer of Dimethylamine 
and therefore a Delta Chemical Corporation employee is able to turn off the emergency shutoff device on the delivery truck within on minute and that 60 gallons are spilled onto a concrete pad that slopes toward a containment sump.  There is a backflow device on the storage tank to prevent additional product from escaping backwards from the storage tank.  The EPA's RMP COMP was used for this scenario. The following assumptions were made: 
 
- Although the Dimethylamine is an aqueous solution, only the DMA portion, 250 lbs. was considered to take part in the vapor cloud explosion.  It was assumed that the water would have an insignificant effect on the consequence. 
- A Delta Chemical Corporation employee is always stationed at the truck for unloading/delivery of Dimethylamine and can stop the flow within one minute. 
 
    Dimethylamine 60% Calculation: 
 
         60 gallons DMA at 6.92 lbs/gallon =          415.20 lbs. 
 
    x    60%   concentration 
                                                                          =249.12 lbs. 
 
- The surface roughness was urban. 
- Explosion Overpressure Level 1 = 1 psi 
- Meteorological Conditions: 
    Stability Class                         D 
    Wind Speed                            3 m/s 
    Atmospheric Temperature      77 degrees F 
 
 
GENERAL ACCIDENT RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
Delta Chemical Corporation's Polymer Manufacturing and Chlorine Repackaging/Sodium Hypochlorite (bleach) operations fall under the Occupational Safety and Health Administration (OSHA) Process Safety Management standard, 29 CFR 1910.119.  The elements of PSM are: employee participation, process safety information, process hazard analysis, operating procedures, training, contractor safety, pre-startup safety review, mechanical integrity, hot works permit, management of change, incident investigation, emergency planning and response, compliance 
audits and trade secrets.  PSM has enhanced Delta Chemical Corporation's commitment to safety and conducting our operations in an environmentally friendly manner.  Employees are required to help with Process Hazard Analysis of PSM processes and participate in PSM Audits of covered processes in accordance with the Employee Participation Program.  Standard Operating Procedures are used to provide clear instructions and training in PSM covered processes.  Our Mechanical Integrity Program ensures that process equipment remains in a safe and reliable condition.  All contractors are required to attend safety orientation in accordance with our Contractor Safety Program.  All welding and cutting in regulated areas must be accompanied by a "Hot Work" permit in accordance with our "Hot Work" Permit Program.  This ensures that personnel take the time to survey the area to make sure all potential sources of ignition and fuel are eliminated/removed from the area prior to starting work. 
 
The Chlori 
ne railcar is equipped with an excess flow valve and an automatic railcar shutoff device.  In the event of a chlorine railcar unloading hose failure, the local atmospheric monitor energizes and shuts the automatic chlorine pipeline pneumaticailly operated closure valve in 1 second, the excess flow valve on the railcar limits the flow to a maximum of 250 lbs./minute and the air motors located on top of the angle valves on the railcar would stop the flow from the railcar in 10 seconds. 
 
Delta Chemical Corporation is committed to providing a safe and healthy workplace and conducting its operations in an environmentally friendly manner.  Delta Chemical Corporation employees are highly trained in environmental, health and safety work practices and conduct emergency drills on a routine basis.  These drills are sometimes conducted with no notice and conducted as a real emergency scenario.  All personnel are then given a chance to talk with their supervisors to discuss the positive and negativ 
e aspects of the drill and are given a chance to input answers to develop solutions to problems. 
 
Delta Chemical Corporation's chemical operators go through drug and alcohol testing at initial hire, for cause and as part of a random pool.  Employees are encouraged to participate in the Safety Committee, Communications Committee and the PSM/RMP Committee meetings. 
 
Delta Chemical Corporation uses standard operating procedures for handling chemicals in various processes.  These procedures plus the knowledge and experience of the employees coupled with the design, maintenance and integrity of the various processes allow for a continuation of our five year accident history. 
 
 
FIVE YEAR ACCIDENT HISTORY 
 
Delta Chemical Corporation has not had a reportable release in the last 8 years. 
 
 
EMERGENCY RESPONSE PROGRAM 
 
Delta Chemical Corporation maintains a Hazardous Material Response Team onsite with the ability to contain and mitigate emergencies at Delta Chemical Corporation.  Delta Chemical C 
orporation is a member of the South Baltimore Industrial Mutual Aid Program (SBIMAP).  SBIMAP is a group of private companies and public agencies that have entered a mutual agreement to interact and practice scenarios that may arise in the Baltimore Area.  These companies are committed to Mutual Aid by providing technical assistance and supplies to aid in the prevention and in recovery of an incident or accident. 
 
Delta Chemical Corporation's Hazardous Material Response Team maintains proficiency through monthly meetings and plant drills conducted at various times throughout the year.  All Hazardous Materials Response Team Members recieve the 40 hr. OSHA Hazardous Waste Operations and Emergency Response training.  This is the basis for further plant specific training in the areas that utilize Chlorine, Dimethylamine and Formaldehyde.  These drills simulate our alternate scenarios, as they will be the most likely. 
 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
Delta Chemical Corporation is curren 
tly researching the possibility of utilizing Lower Explosive Limits (LEL) sensors to monitor the Formaldehyde and Dimethylamine storage tanks to ensure the earliest possible notification of a release of Formaldehyde and Dimethylamine to protect our employees and the environment and potentially automaticially shut down the respective process.  Delta Chemical Corporation's Hazardous Material Response Team is training on a monthly basis to maintain proficiency and as part of Responsible Care (R) principles; training our customers on environmental, health and safety subject pertaining to our products.
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