James Austin Company - Executive Summary |
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Executive Summary 1). The accidental release prevention and emergency policies. The Environmental Protection Agency (EPA) classifies two raw materials utilized by the James Austin Company as hazardous; chlorine and ammonium hydroxide. The management of the James Austin Company is cognizant of the risks such chemicals pose to its employees and the community. Austin's management is committed to ensuring that its employees adhere to safety and accident prevention procedures when handling all chemicals. Sensors provide early warning of minute leaks of chlorine and are linked to the facility's alarm system. Once detected, automatic shut off valves close quickly to seal off a leak. Alarms are also in place to automatically signal emergency personnel and evacuate the facility in the event of a potentially serious leak. Evacuation routes are clearly marked and periodic drills are conducted. Sensors, alarms, and other emergency equipment is checked for proper functioning. Defective e mergency equipment is fixed or replaced promptly. All employees who handle chlorine and ammonium hydroxide must complete specialized in-house training prior to assuming such responsibilities. These employees are also sent annually for additional outside training sponsored by our chemical suppliers. Recently, Mixing Department employees completed an additional 32-hours of EPA Hazmat Technician training, enabling the establishment of an onsite emergency response team. Local Fire Departments are invited annually for a tour of the plant. Many of the local departments attend each year. They are appraised of any significant changes in equipment, chemicals or processes that may assist in an emergency response. The company also solicits their input on ways to improve the safety of our facility. 2). The facility and regulated substances handled. The James Austin Company is a family owned business and in existence 112 years. We have been at the Mars, Pennsylvania location for appro ximately 65 years. At this location household cleaning and laundry aides are manufactured. Such as; bleach, ammonia, dish soaps, fabric softeners, laundry detergents, window cleaners, etc. Most of these products are produced by dilution and/or blending of concentrated raw materials. Of these products, the bleach and ammonia will be discussed. These are the chemicals on site, which the EPA considers to be hazardous materials. The raw materials used to produce these products are shipped to our facility by drum, tank truck and rail car. The finished household ammonia is produced by a 29.4% ammonium hydroxide solution, which is a regulated substance. It is shipped in by tank truck and unloaded into a storage tank. The maximum amount of the 29.4% ammonium hydroxide that can be stored is 98,280 pounds. When production of the household ammonia is needed, the 29.4% ammonium hydroxide is metered and diluted into another tank. The off loading of chlorine from a rail car produces the f inished household bleach. Chlorine is a regulated substance. The maximum amount of chlorine that can be stored on the rail siding is 720,000 pounds. The chlorine is metered into a mixing tank where a solution of water and sodium hydroxide has been mixed. There are alarms that signal when a batch of bleach has reached the end point of chlorinating. The mixing specialist closes the valves and has the batch tested for quality specifications. The batch is then pumped to a storage tank for production use. 3). The worst-case scenario and the alternative release scenario. A worst case scenario involves the release of the entire contents of a chlorine rail car. Chlorine would be released at the rate of 18,900 lb./min releasing the entire car of 174,482 lb./min in a 10-minute duration. A distance of 12 miles would be affected and approximately 5500 people would need to be notified and/or evacuated. These figures were determined by the use of EPA* Comp (TM). The alternative scena rio for chlorine is a leak in the pipe. When the chlorine starts to leak, the sensors detect the chlorine and send a signal to shut the 2 automatic shut off valves in the line preventing any further chlorine from entering the system. The chlorine car will need to be shut off manually. The release duration is 15 minutes with 3270 lb./min being released. The total quantity released in the amount of time is 49,050 pounds. The distance affected is 0.80 mile with approximately 500 residents in the area. These figures were determined by the use of EPA* Comp (TM). The automatic shut off valves can only reopen once the alarm has been cleared. The alternative scenario for the 29.4% ammonium hydroxide is a leak in the pipe. The tank sits in a concrete dike area limiting the surface area of the leak. A 40-minute release duration will release a quantity of 26,920 pounds at a rate of 673 lb./min. The distance affected is 0.10 mile with approximately 50 residents in the area. These figur es were determined by the use of EPA* Comp(TM). 4). The general accidental release prevention program and chemical-specific prevention steps. There are several regulations which aide as preventive measures in reducing the risk of injury or a release that James Austin Company must comply. One of these regulations is the Process Safety Management Standard of highly hazardous chemicals, Title 29 CFR 1910.119. This standard is to prevent unwanted releases that could expose employees and others to serious hazards. The standard covers the hazards of the chemicals used in the process, technology of the process, equipment in the process and employee involvement. Another regulation is the Department of Transportation 49 CFR 174.67 tank car unloading. Preventive measures are taken each day during start-up and shut down of the system to reduce the rise of problems. This includes the checking of valves, making sure of a secure hook up seal and meters are calibrated. There is a chlorine batch meter that is used during each batch of bleach (sodium hypochlorite) made which signals the mixer when the finished point has been reached. A high level alarm will signal at a point when the chlorinating of a batch must be stopped to prevent over chlorinating and lose a batch. A chlorine air monitoring system is constantly monitoring the air inside the building and at each rail car. Upon the detection of chlorine, the alarm will signal either a first or second alarm depending on the amount detected. Either alarm will close the automatic shut off valves at the rail car. First alarm is a warning, second alarm employees must evacuate the building and the proper personnel on site will respond. Also in second alarm, the outside monitoring company will call the facility for a clear code. If no answer or proper clear code given, they will dispatch emergency response crews. The hooking up and disconnection of a chlorine rail car is a 3-person must operation. Two will perform the job while the third watches on the monitor. All are in contact with 2-way radios during the procedure and throughout the day. 5). The five-year accident history. There has not been a reportable release of 29.4% ammonium hydroxide or chlorine. We are continuously updating and adding safety features to the systems and training personnel to prevent a future possible release. 6). The emergency response program . All employees are given general safety training who work around the chemicals in the plant. The training informs the employees how to recognize, understand, and use labels and material safety data sheets. It provides what safety procedures to follow when working with chemicals to reduce hazards. Explanation of the different alarm signals and what evacuation procedures to follow. In the event of an emergency that requires evacuation, an announcement is given over the PA system or the alarms will signal. The evacuation routes to follow are posted in each department. T here are fire alarms throughout the entire plant, office, and warehouse. These will set off anytime there is water movement in the sprinkler system. A chlorine monitoring system has also been set up inside the building and by each rail car. If the sensor head detects chlorine it will alert employees and close the automatic shut-off valves at the rail car. The chlorine monitoring is tied into the fire protection system. The outside company monitoring our system will call the facility upon a chlorine alarm for a clear code. If there is no answer or proper clear code given, they will dispatch emergency response crews. The mixing department receives a more specialized training. New employees work very closely with a veteran mixer. During their training period they observe, follow, and learn the system along with the safe handling of chlorine. Once they are knowledgeable about what they have learned thus far, training will continue with hands-on duties and responsibilities of the standard operating procedures. They will have to prove their capabilities through a verbal testing giving explanation of the system. The purchasing of response equipment, continuously upgrading the system and by establishing an in-house emergency response team all aid in reducing the amount of time in which a release occurs. There has recently been an in-house emergency response team established. The team is comprised with mixing and maintenance personnel. They have completed a 32-hour EPA Hazmat Technician level class. The class and in-house training has educated the team and made them capable of the following: *Implement the emergency response plan *Determine what material is involved *Which personal protective equipment is needed *Understand the hazards *Contain and/or stop a release *Proper decontamination procedures A major supplier of the chlorine provides a hands-on and classroom training on the safe use and handling of chlorine once a year. The classroom trainin g consists of a lecture, video, and question and answer. The hands-on training involves the application of the rail car kit C. They also perform a walk through of the system and provide improvement and prevention suggestions. The local volunteer fire departments are invited to the facility once a year for a plant tour to keep them familiar with the operations and set-up of the systems. They also provide improvement and prevention suggestions. 7). Planned changes to improve safety. We have recently established an in-house response team. They have completed a 32-hour EPA Hazmat Technician level class and will receive refresher courses as necessary. We will be installing a barometric loop and expansion chamber to the chlorine line. The barometric loop prevents back flow through the chlorine line that could cause contamination to the rail car contents. The expansion chamber prevents the line from rupturing caused by trapped chlorine building pressure between two closed valves. We will be installing a measuring level meter in the 29.4% ammonium hydroxide tank. The meter will give the exact amount being delivered and the amount in the tank at all times. Both of these projects are to be completed within the next six months. |