Textile Chemical Company, Inc - Executive Summary |
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1. Accidental Release Prevention and Emergency Response Policies We at Textile Chemical Company, Inc. are strongly committed to employee, public and environmental safety. This committment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. 2. The Stationary Source and the Regulated Substances Handled Our facilitiy's primary activities encompass wholesale chemical distribution. We have six (6) regulated substances present at our facility. these substances include, Hydrofluoric Acid, Oleum, Cyclohexylamine, Ammonia >20%, Formaldehyde solutions, and Chlorine. The maximum inventory of hydrofluoric acid at our facility is 126,000 lb., while oleum, cyclohexylamine, ammonia, formaldehyde and chlorine are present at our facility in quanties of 45,000 lb., 44,4550 lb., 23,490 lb., 22,200 lb. and 10,800 lb. respectively . 3. The Worst Case Release Scenario and the Alternative Release Scenarios, Inckuding Administrative Controls and Mitigation Measures to Limit Distances for each Reported Scenario To perform offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from chlorine storage and handling. In this scenario, 10,800 lb. of chlorine is released. The toxic liquid is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. At class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 11 miles is obtained. The alternative release scenario for oleum involves a release from oleum repackaging and handling. The scenario involves the release of 1246 lb. of oleum. Toxic liquid is assumed to be released to form a 1cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 43.5 minutes. Passive mitigation controls such as buildings are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance of 0.50 miles is obtained. The alternative release scenario for formaldehyde involves a release from formaldehyde repackaging and storage. The scenarion involves the release of 1363 lb. of formaldehyde. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as buildings and drains are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance of 0.28 miles is obtained. The alternative release scenario for ammonia >20% involves a release from ammonium hydroxide storage and handling. The scenario involves t he release of 1179 lb. of ammonium hydroxide. Toxic liquid is assumed to be released to form a pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dikes and drains are taken into account to calculate the scenario. Under neutral weather conditions the maximum distance of 0.19 miles is obtained. The alternative release scenario for hydrofluoric acid 70% invloves a release from the storage tank. The scenario involves the release of 2908 lb. of Hydrofluoric Acid. Toxic Liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated in 10 minutes. Passive mitigation controls such as dikes and drains are taken into account to calculate the scenario. Under neutral weather conditions the maximum distance of 0.19 miles is obtained. The alternative release scenario for chlorine involves a release of chlorine from a cylinder. Th e scenario involves the release of 25 lb. of chlorine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated in 10 minutes. Under neutral weather conditions, the maximum distance of 0.12 miles is obtained. The alternative release scenario for cyclohexylamine involves a release from several drums. The scenario involves the release of 2864 lb. of cyclohexylamine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. Passive mitigation controls such as dikes are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance of 0.06 miles is obtained. 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. The following secti ons briefly describe the elements of the release prevention program. Process Safety Information: Textile Chemical Company maintains a record of safety information that describes the chemical hazards and equipment designs associated with all processes. Process Hazard Analysis: Our facility conducts studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analysis is the what if methodology. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA was performed on 6/11/1999. Operating Procedures: For the purposes of safely conducting activities within our covered processes, Textile Chemical Company maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, emergency shutdown, and normal shutdown. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training: Textile Chemical Company has a comprehensive training program in place to ensure that employees who are operating processes are competent in the procedures associated with these processes. Refresher training is provided at least annually and more frequently if needed. Mechanical Integrity:Textile Chemical Company carries out maintenance checks on process equipment to ensure proper operation. Equipment examined by these checks includes; storage tanks, piping systems, relief and vent systems, controls and pumps. Maintenance operations are carried out by qualified personnel. Any equipment deficiencies identified by maintenance checks are corrected in a safe and timely manner. The most recent review of mechanical integrity was performed on 6/8/1999. Management of Change: Procedures are in place at Textile Chemical Company to manage changes in process chemicals, equipment and procedures. Operators ,maintenance personnel, or any other employee whose job tasks are affected by a modification are promptly made aware of the modification. Pre-startup Reviews: Pre-startup safety reviews related to new processes and to major modifications are conducted at Textile Chemmical Company. The most recent review was performed on 12/10/1997. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment in operation. Compliance Audits: Textile Chemical Company conducts compliance audits to determine whether the provisions set out under RMP are being implemented. These audits are to be carried out at least every three years. Incident Investigation: Textile Chemical Company 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 reoccurr ing. Employee Participation: Textile Chemical Company truly believes that process safety management and accident prevention is a team effort. Employees are 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 of the RMP rule. Contractors: On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Textile Chemical Company has a policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of emergency procedures should an accidental release of a regulated substance occur. 5. Five-Year Accident History Textile Chemical Company has had an excellent record of preventing accidental relases over the last five years. Due to our prevention procedures, there have been no accidental releases during this perio d. 6. Emergency Response Plan Textile Chemical Company carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including medical treatment, evacuations, notification of local emergency response agencies, and the public. 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 lace that would require a modified emergency response. Berks County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Improvements to tapping and strorage areas and monitoring systems, are some of the major steps we want to take to improve safety at our facility. These improvements are expected to be implemented by 12/31/1999. |