Mission Valley Fabrics - Executive Summary
EXECUTIVE SUMMARY |
PROCESS SAFETY / RISK MANAGEMENT PLAN -- Chlorine & Sulfur Dioxide
This document summarizes the steps taken by Mission Valley Fabrics' employees to minimize the consequences of catastrophic chemical releases. The primary goal is to assure the health and safety of employees, guests and the community. Other reasons for developing a plan include:
1) minimizing the risk to MVF property, equipment and products;
2) helping to protect our land, water and air;
3) complying with current local, state and federal regulations;
4) preparing responses ahead of time so production disruptions are minimized;
5) participation in national and industry recognition programs.
The senior management of Plains Cotton Cooperative and its Mission Valley Fabrics Division bear the ultimate responsibility for process safety. However, the task of developing and communicating the management plan lies with the Environmental Compliance Manager. This person identifies particular risks
or concerns, then works with the affected departments to develop appropriate responses. The Environmental Compliance Manager is also responsible for internal training, drills & exercises and for coordinating with other outside groups such as local police, fire and emergency planning units.
The PROCESS SAFETY / RISK MANAGEMENT PLAN - Chlorine & Sulfur Dioxide has two specific purposes. The first is to fulfill requirements for Process Safety Management found in OSHA regulation 29 CFR 1910.110 and the second is to fulfill requirements for a Risk Management Plan found in EPA regulation 40 CFR 68. The final purpose is to provide MVF employees and supervisors with a set of practical, step-by-step actions and responses.
The management of Plains Cotton Cooperative and Mission Valley Fabrics recognizes that emergencies are chaotic, fluid events....
In the event immediate action is necessary to prevent loss of life, serious injury, or extensive property or environmental damage, Direct
ors and Shift Supervisors have the authority to take whatever action necessary to control the situation and minimize risks.
II. BACKGROUND INFORMATION
Mission Valley Fabrics (MVF) is a textile division of Plains Cotton Cooperative Association, a farmer-owned cotton marketing and manufacturing cooperative. The mill uses raw cotton and, at times, some man-made fiber to manufacture yarn, dyed yarn and woven fabrics. The facility is located adjacent to the Guadalupe River at 555 Porter Street, in the City of New Braunfels, Comal County, Texas. There are about 675 full time employees working in a single tenant, one- and two-story, 563,000 sq. ft. building that is located on a 25 acre site.
III. EMPLOYEE INVOLVEMENT
Workers associated with the chlorine and sulfur dioxide system were involved in the initial process hazards analysis in August, 1994 and have been consulted regarding any changes or revisions since then. Typically, information is collected and evaluated by the Environmental Com
pliance Manager and Plant Engineer. They prepare an initial draft of proposed changes and circulate to affected employees for comment and criticism. After reviewing the suggestions and revising the proposal, a final copy is prepared for distribution and approval.
IV. CHLORINE SAFETY INFORMATION
1) Acute Toxicity -- Chlorine
In concentrations near the threshold, chlorine gas may cause mild irritation of the eyes and of the mucous membrane of the respiratory tract. As concentrations increase there is an increase in irritation, the coughing mechanism reacts, and breathing becomes difficult. As the duration of exposure and/or the concentration increases, the affected person may become apprehensive and restless with coughing accompanied by throat irritation, sneezing and excess salivation. At higher levels there is vomiting associated with labored breathing. In extreme cases difficulty in breathing can progress to the point of death through suffocation.
2) Chronic Toxicity -- Chlorine
concentrations of chlorine gas in the air may have minor irritating effects or may produce slight symptoms after several hours of exposure, but careful examination of persons repeatedly exposed to such conditions reportedly has shown no permanent physiological effect.
3) Reactivity Data - Chlorine
Chlorine is very corrosive to most common metals when mixed with water. It reacts explosively, or forms explosive compounds with many common chemicals, especially acetylene, turpentine, ether, ammonia gas, fuel gas, hydrocarbons, hydrogen and finely divided metals, except the noble gases and carbon. Forms a corrosive solution in water: Hydrochloric acid and/or hypochlorous acid.
4) Corrosivity Data -- Chlorine
Very corrosive when mixed with water; forms hydrochloric acid and/or hypochlorous acid. Corrosive to most common metals when mixed with water. Platinum, silver, tantalum and titanium are resistant.
5) Stability Data -- Chlorine
Will react chemically with many substances, usually with t
he evolution of heat. Slightly soluble in water. Chlorine will support combustion.
V. PROCESS DESCRIPTION
Chlorine is used as an oxidizing agent to remove color from the final effluent before discharge. Sulfur dioxide is used to remove the chlorine from the effluent after the chlorine has removed most of the color. The maximum inventory for chlorine is 8,000 lbs.
1) Materials of Construction
The Chlorine Building is constructed with 8" x 12" cinder blocks on a concrete foundation with a sheet metal roof. Gas containers are welded tanks having a capacity of on (1) short ton, 2,000 lb (907 kg) and a loaded weight of as much as 3,700 lb (1,678 kg). The heads are convex inward and forge welded to the barrel. The sides are crimped inward at each end to form chimes which provide a substantial grip for lifting beams. The container valves are protected from accidental breakage by a removable steel protective housing. The following information may be stamped into the chime at the valve end:
) DOT or CTC specification number,
b) material and cladding material,
c) owner's or builder's identification symbol and serial number,
d) inspector's mark, test date(s) and water capacity
2) Relief System Design
The chlorine feed system is operated by three Ecometrics Series 2000 vacuum operated regulators. The regulators are designed to work on a supplied vacuum. Any break in this vacuum during use will cause the regulators to close and prevent any chlorine from escaping. This safety feature will stop the supply of gas being fed to the system in the event of live rupture.
The sulfur dioxide feed system is operated by two Wallace & Tiernan 200 lb./24 hr. capacity vacuum regulators. A vacuum must be applied to operate the regulator. This regulator will also close if the vacuum is removed.
All ton cylinders have safety relief devices in the form of fusible metal plugs. The fusible metal is designed to yield or melt between 158oF and 165oF to relieve pressure and prevent rupture of the
container in case of fire or other exposure to high temperatures.
3) Safety Alarm/Warning System
A Wallace & Tiernan series 50-135 chlorine gas detector is located inside the building. When the alarm relays are activated, signals are sent to an alarm siren mounted on the chlorine building and the maintenance shop building. The same audible siren is used for both the chlorine and sulfur dioxide leaks. The maintenance shop building audible siren and light will signal in the event of either type of leak. To determine the type of leak it is necessary to view the chlorine building which can been seen from a distance. The red light at the chlorine building indicates a chlorine leak. No light at the chlorine building indicates a sulfur dioxide leak.
VI. EMERGENCY RESPONSE
The Chlorine/Sulfur Dioxide Emergency Response Plan is initiated by any employee telling his/her supervisor a chlorine/sulfur dioxide leak has triggered the chlorine/sulfur dioxide leak detection monitor. The supervisor w
ill contact the Facility Chemical Coordinator and then the clerk in the personnel department. This clerk will then notify the Emergency Response Team and management.
However, on weekends or whenever no employees are present, the security guard will contact the Facility Coordinator, Dept. Mgr., Mechanical/Electrical and/or the Safety Director. One of these employees will contact the Emergency Response Team.
1) Initial Alarm
When the alarm relays are activated, signals are sent to an alarm siren mounted in the chlorine building. The same audlble alarm is used for both chlorine and sulfur dioxide leaks. The maintenance shop building audible alarm and light will signal in the event of either type of leak. To determine the type of leak it is necessary to look at the chlorine building.
RED LIGHT at the chlorine building indicates a chlorine leak.
NO LIGHT at the chlorine building indicates a sulfur dioxide leak.
2) Reporting an Alarm
When an EMPLOYEE discovers an emergency, they need to do
one of two things
If there is an IMMEDIATE DANGER...to people, property or process,
MOVE TO SAFETY and CALL 9-911.
If there is NOT AN IMMEDIATE DANGER...to people, property or process,
Report to a Shift Supervisor or member of the Emergency Response Team.
These people are experienced, knowledgeable employees who can assess a situation and determine the appropriate response.
The SUPERVISOR or EMERGENCY RESPONSE TEAM MEMBER will immediately contact the Facility Chemical Coordinator and then the clerk in the personnel department. This clerk will then notify the Emergency Response Team and management. On weekends or whenever no employees are present, the SECURITY GUARD will contact the Facility Coordinator, Dept. Mgr., Mechanical/Electrical and/or the Safety Director. One of these employees will contact the Emergency Response Team.
3) Responding to an Alarm
a) Facility Chemical Coordinator will:
determine the need for RESCUE TEAM,
determine the need for EMERGENCY RESPONSE TEAM,
ine the need for OUTSIDE ASSISTANCE
b) Emergency Response Team Members will:
secure their jobs,
report to the PRIMARY ASSEMBLY area (the shop area adjacent to Plant Engineer's office),
report to the SECONDARY ASSEMBLY area (river gate between mill store and plant).
c) Department Managers and Shift Supervisors will:
shut-off supply fans bringing outside air into the plant building,
account for all visitors and employees in their department,
tell them that there has been a release,
tell them which direction to go if an evacuation is necessary.
4) Emergency Operation: Personal Hazards and Protection
Responding to a cylinder alarm can present an employee with significant physical and chemical hazards. One ton cylinders are heavy, pressurized containers which can be difficult and awkward to move. They can cause serious physical injury if they are not handled carefully. In addition, their chemical contents can fatal if inhaled and can cause severe burns to other body organs.
Tools and equ
ipment for safely handling cylinders are kept available for use in an emergency. Employees are also provided with, and trained in the use of, personal protective equipment including:
a) self-contained breathing equipment,
b) chemical protective clothing,
c) protective eyeware and gloves.
5) Emergency Operation: Patching a Leaking Cylinder
Although leaks in one ton cylinders are rare, they can occur and require prompt action from trained personnel. An Emergency Kit "B", approved by the Chlorine Institute, is used for response to leaking cylinders. Procedures for using the kit are described in its instruction booklet, a copy of which is in Appendix XI Instruction Booklet for Chlorine "B" Kit. The kit is designed to contain leaks from:
a) unseated, broken or blown valves,
b) blown or corroded fusible plugs,
c) damage cylinder walls.
VII. WORST CASE RELEASE
1) Hazard Identification
EVENT: Complete release of chlorine cyliner contents within ten minutes.
LOCATION: Mission Valley Fabrics'
Wastewater Treatment Plant
MATERIAL: 2,000 lbs. of Chlorine Gas (one ton cylinder) Poisonous gas; may be fatal if inhaled. Respiratory conditions aggravated by exposure. Contact may cause burns to skin and eyes. Corrosive. Effects may be delayed.
AREA: A release of 2,000 lbs of chlorine in ten minutes from a one ton cylinder could have a Toxic Endpoint Distance of 1.3 miles (2.1 kilometers). Analysis from USEPA's RMP*COMP software.
PEOPLE: Approximately 350 employees at the manufacturing facility, approximately 5,400 residential citizens within worst-case release area. Public receptors include residential neighborhoods, schools, recreational areas and commercial developments.
2) Risk Assessment
RISK: (personal) Significant. High levels of chlorine gas in the facility work area or residential area could cause respiratory distress, even fatalities.
RISK: (property) Nominal. Mission Valley Fabrics equipment and structures susceptible to superficial damage from corrosive fumes. Any fuel i
n immediate area may spontaneously combust when exposed to chlorine. Effects should be limited to MVF property.
RISK: (environment) Nominal. Impact on plant and animal populations should be short-term and limited to MVF property, but could be significant. Effects could range from short-term stress on individua organisims to destruction of habitat immediately surrounding the Chlorine Facility.
POTENTIAL: Low. Chlorine is stored in an area with continuously operating leak detection alarm equipment.
VIII ALTERNATIVE RELEASE
1) Hazard Identification
EVENT: A leak from a <" inch hole for twenty minutes.
AREA: A release of about 830 lbs of chlorine over twenty minutes from a <" inch hole in a one ton cylinder could have a Toxic Endpoint Distance of 0.1 miles (0.2 kilometers). Analysis from USEPA's RMP*COMP software.
PEOPLE: Approximately 350 employees at the manufacturing facility, approximately 54 residential citizens within alternative release area. Public receptors limited to residential
2) Risk Assessment
RISK: (personal) Nominal. High levels of chlorine gas in the facility work area or residential area could cause respiratory distress. Toxic concentrations should dissiipate rapidly.
RISK: (property) Minimal. MVF equipment and structures in immediate area susceptible to superficial damage from corrosive fumes.
RISK: (environment) Minimal. Impact on plant and animal populations should be limited to the short-term stress of individual organizms. Effects should be limited to MVF property.
POTENTIAL: Low. Alarm sytem is in place. Equipment is checked and maintained regularly. Repair kit is on-hand and repsonse of trained personnel should be better than twenty minutes.
IX. HAZARD ANALYSIS
A HAZARD REVIEW CHECKLIST is used to evaluate chlorine / sulfur dioxide hazards because the system used at Mission Valley Fabrics is not complex. It is simply designed, simple to operate and built with equipment commonly found in the water treatment industry. The initial
process hazard analysis for a catastrophic cylinder release was done by Roy Thiele in August 1994 and revised by Ed Sprencel in December 1997. This analysis was reviewed and a checklist was developed in 1999 by Chip Higgins during the preparation of a Risk Management Plan for USEPA CAA 112 regulations.
TOXIC RELEASE: Possible. If an accidental release occurred, a regulated toxic substance could be released.
FIRE: Not Likely. Process does not involve listed flammables. Building construction is fire resistant.
EXPLOSION: Possible. Failure of pressurized containers would result in an unnconfined release of material.
RUNAWAY REACTION: Not Likely. Materials kept in separate containers. Reaction chemistry not particularly violent.
POLYMERIZATION -: Not Likely. Chemistry does not involve bonding of monomers.
OVERPRESSURE: Possible. Overpressure in either containers or system components could cause equipment failure and release of material.
CORROSION: Possible. Corrosion could lead to equip
ment failure and release of material substance.
OVERFILLING: Not Likely. System designed to consume material and deplete containers.
CONTAMINATION: Possible. Any moisture that contaminates the system can cause an immediate corrosion and failure of valves, cylinders and related hardware.
EQUIPMENT FAILURE: Possible. System has a number of connections, pipes and lines.
LOSS of HEAT, COOLING, and ELECTRICITY: Not Likely. Loss could impair system performance, but unlikely to cause uncontrolled releaseof material.
EARTHQUAKE: Not Likely. No design frequency for such events in our area.
FLOOD: Possible. Chlorine Building located within 100 year flood plain of Guadalupe River and facility has been flooded in the past.
TORNADO: Possible. Tornadoes are common in our area.
HURRICANE: Not Likely. Site is located well inland.
OTHER: None noted.