P. B. & S. CHEMICAL COMPANY, INC. (64) - Executive Summary
General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities |
1. Accidental Release Prevention and Emergency Response Policies
We at P. B. & S. CHEMICAL COMPANY, INC. are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with the WESTSIDE FIRE DEPARTMENT which provides highly trained emergency response personnel to control and mitigate the effects of the release.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass Distribution of chemical products. We have 4 regulated subs
tances present at our facility. These substances include Chlorine, Sulfur Dioxide (anhydrous), Hydrofluoric Acid, and Aqua Ammonia. Chlorine is received into St. Albans in 180,000 pound railcars. This product is then repackaged in different size containers for distribution to customers and in the manufacture of Sodium Hypchlorite. Sulfur Dioxide, Hydrofluoric Acid and Aqua Ammonia are received prepackaged in different size containers. Chlorine, Sulfur Dioxide, Hydrofluoric Acid, and Aqua Ammonia is used for resell to our customers.
The maximum inventory of Chlorine at our facility is 1,247,444 lbs. while Sulfur dioxide (anhydrous), Hydrofluoric Acid, and Aqua Ammonia are present at our facility in quantities of 41,150 lbs., 36,900 lbs. and 30,180 lbs. respectively.
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To evaluate the worst
case scenarios and alternative release scenarios, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as SAFER/TRACE. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from a 180,000 pound railcar of chlorine. The scenario involves the release of 180,000 lb. of chlorine in a gaseous form over 10 minutes. Under worst case weather conditions, namely Class D atmospheric stability and 1.5 m/s windspeed, the maximum distance of 44.1 miles is obtained corresponding to a toxic endpoint of .0087 mg/L.
The alternative release scenario for chlorine involves a release from a Ton CHLORINE CONTAINER STORAGE process. The scenario involves the release of 2000 lb. of Chlorine in a gaseous form over 10 minutes.
With Class D atmospheric stability and windspeed of 1.5 m/sec the maximum distance
of 6.8 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/l.
The alternative release scenario for Sulfur Dioxide (anhydrous) involves a release from a TON SULFUR DIOXIDE CONTAINER STORAGE process. The scenario involves the release of 2000 lb. of Sulfur Dioxide in a gaseous form over 10 minutes. With Class D atmospheric stability and windspeed of 1.5 m/sec the maximum distance of 8.3 miles is obtained corresponding to a toxic endpoint of 0.0078 mg/l.
The alternative release scenario for Hydrofluoric Acid involves a release from a 350 gallon portable tank in storage. The scenario involves the release of 3262 lb. of Hydrofluoric Acid in a liquid form over 4.5 minutes. With Class D atmospheric stability and windspeed of 6.7 m/sec the maximum distance of 0.44 miles is obtained corresponding to a toxic endpoint of 0.016 mg/l.
The alternative release for Aqua Ammonia involves a release from a 350 gallon portable tank in storage. The scenario involves the release of 2,480
lb. of Aqua Ammonia in liquid form over 4.0 minutes. With class D atmospheric stability and windspeed of 3.0 m/sec the maximum distance of 0.30 miles is obtained corresponding to a toxic endpoint of 0.14 mg/l.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA STANDARD 30-1996). A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119.
The following sections briefly describe the elements of our release prevention program that are in place at our stationary source.
Process Safety Information
P. B. & S. CHEMICAL COMPANY, INC. maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with a
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is "WHAT IF" The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of three years. Any findings related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting activities within our covered processes, P. B. & S. CHEMICAL COMPANY, INC. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved with the processes.
P. B. & S. CHEMICAL COMPANY, INC. has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every three (3) years and more frequently as needed.
P. B. & S. CHEMICAL COMPANY, INC. carries out highly documented maintenance checks on process equipment to ensure proper functions. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any eq
uipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at P. B. & S. CHEMICAL COMPANY, INC. to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at P. B. & S. CHEMICAL COMPANY, INC.. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
P. B. & S. CHEMICAL COMPANY, INC. conducts audits on a regular basis to determine whether the provisions set out under the RM
P rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
P. B. & S. CHEMICAL COMPANY, INC. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
P. B. & S. CHEMICAL COMPANY, INC. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation to the RMP ru
le in particular information resulting from process hazard analyses.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. P. B. & S. CHEMICAL COMPANY, INC. has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-year Accident History
P. B. & S. CHEMICAL COMPANY, INC. has had 0 accidental releases over the last 5 years.
6. Emergency Response Plan
P. B. & S. CHEMICAL COMPANY, INC. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, n
otification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
Kanawha/Putnam County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.
7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. A chlorine and Sulfur Dioxide monitoring systems are some of the major steps along with a employee alarm system that we have taken to improve safety at our facility.