Morton Delinting - Executive Summary

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Morton Delinting is an agricultural seed processing facility located in Morton, Texas. As part of our cottonseed processing and packaging activities, we utilize anhydrous hydrogen chloride (CHL).   To safeguard our employees and the local community, Morton Delinting is committed to operating the HCL process in compliance with local, state and federal regulations.  This includes both OSHA-required Process Safety Management and EPA Risk Management Planning.  The information provided here is an overview of our safety program for using HCL. 
Morton Delinting utilizes HCL in the removal of lint from cottonseed (delinting).  The HCL is maintained in a seven-container tube trailer.  Each tube contains approximately 3,000 pounds of HCL.  The maximum inventory of HCL onsite is 21,000 pounds.  The chemical is only used during the delinting season, which is approximately September - May.   
In compliance with RMP rules, Morton Delinting has conducted both worst-case and alternative-release scenar 
ios.   These scenarios are based on the distance to the toxic endpoint.  For the purpose of these scenarios, the toxic endpoint for HCL is 0.03 mg/L.   This concentration was established by the American Industrial Hygiene Association as the Emergency Response Planning Guideline Level 2 (ERPG-2).  ERPG-2 is the maximum concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take action. 
For the worst-case scenario, we considered the complete failure of an HCL tube, and the subsequent release of the chemical over a 10-minute period.  Using release modeling guidance from EPA, it was determined that offsite receptors are within the ERPG-2 concentration radius.  For the alternative-release scenario, a vessel leak over a 60-minute period was considered.  This type of release could also effect offsite recept 
ors.  It should be noted that Morton Delinting has never had an offsite release of HCL.  Additionally, the design of the storage containers and built-in safeguards make any offsite release extremely unlikely.  In fact, our chemical supplier has estimated that the probability of complete tube failure is once per 1,000,000 years.   
Even though the relative likelihood of release is low, Morton Delinting has instituted a prevention program for the process.  This program is consistent with requirements of Process Safety Management and Risk Management Planning Program 3.  The program includes a management system, employee involvement, process hazard analysis, preventive maintenance, procedures for managing changes to the system, pre-startup safety reviews, written operating procedures, hot work permitting, contractor review, incident investigation, emergency operations and periodic program review.  
The best safety features of the process are those that were built in during design.  These i 
nclude ventilation systems, relief valves, and interlocks to name a few.  Additionally, we have identified and planned for new improvements.  Some of these include installation of automatic and emergency shutdown systems. 
Although we believe that the process engineering and administrative controls would mitigate the majority of potential releases, Morton Delinting does have procedures in place to notify local emergency personnel if a release should occur.
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