CSM Industries, Inc. - Executive Summary
1. Accidental release prevention and emergency response policies:
In this facility, we roll molybdenum and tungsten sheet and foil products. As part of operation, we use hydrofluoric acid, nitric acid, and sulfuric acid in the cleaning operations. Hydrofluoric acid is considered to be an extremely hazardous substance by the EPA. The EPA classifies nitric and sulfuric acids as toxic chemicals. The nature of hydrofluoric, nitric, and sulfuric acids make it necessary to observe certain precautions in their handling to prevent unnecessary human exposure in the facility and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and State rules and regulations. Safety depends upon the manner in which we handle these substances, the safety devices inherent in the design of this facility, and the safety training and procedures that we use.
Our emergency response program is based on a worst-case scenario and assumes the spill being c
ontained with in the building. This plan includes procedures for notification of the local fire authority and notification of any potentially affected neighbors.
2. The stationary source and regulated substances handled.
The primary product of this facility is rolled molybdenum and tungsten sheet and foil products. Hydrofluoric acid is used in our pickling line to help remove surface contaminates. Hydrofluoric acid is stored on site in two concentrations. A high (70%) grade of acid is maintained in drums in side the facility in a diked area. No more than two drums are on site at any one time. The hydrofluoric acid bath contains a 1150-gallon mixture of hydrofluoric acid (11%), nitric acid (21%), and water. This lower (11%) grade is also intermittently stored in the basement in small quantities until it is nuetralized. The regulated substances handled at this facility are hydrofluoric acid, sulfuric acid, and nitric Acid.
The maximum amount of hydrofluoric acid that can
be stored on site is 17,000 pounds of the mixture or 3000 pounds of the pure 70% acid. The maximum amount of nitric acid that can be stored on site is 28,000 pounds of the 80% pure acid. The maximum amount of sulfuric acid that can be stored on site is 47,000 pounds of the 20% pure acid.
3. The worst-case scenario and alternative release scenario, including administrative controls and mitigation measures to limit the distance for each reported scenario.
Worst-Case Scenario: Failure of HF pickling tank when filled to the greatest amount would release 1100 gallons of a 11% HF mixture. The resulting spill would be contained by the diked neutralization room in the basement. This room has a low velocity ventilation system. The vented air is sent to scrubber systems on the roof. The scrubber is rated to be 95% efficient. A deluge system is available if needed. If the ventilation unit failed, the distance to the end point for the worst case scenario is 0.20 miles. If the scrub
ber unit were operating, the distance to endpoint would be less than 0.1 miles. This assumes that the temperature is 77degrees F.
Alternative Scenario: During a drum delivery, a drum falls of the dock and ruptures leaking 25 gallons of 70% HF acid onto the drive way. The area would be diked off and drains covered to prevent the material from leaving the property line. The material would be neutralized, clean up and disposed in accordance with Federal and State regulations. The distance to the endpoint is 0.10 miles. This assumes a release rate of 2.3 pounds per minute [QR=QS (246) x2.4XLFA (0.01) XDF (0.39)] and a spill duration of 107 minutes.
Additional Alternative Scenario: Mixed acid bulk storage tank fails. The tank is completely filled and results in 5700 gallons of a 70/30 mixture of sulfuric and nitric acid is released. 3990 gallons of a 20% oleum or sulfuric acid being released. 1710 gallons of an 80% nitric acid is released. The spill is contained by a 6000-gallon containment dike. This structure is 14' x 24' or 336 sq. ft of surface area and 3 feet deep. The resulting spill has an estimated distance to toxic endpoint of 0.1 miles.
The population of people that would be affected would vary greatly depending on the time of the incident. The 1996 US Census estimated that 52,472 people live in Euclid. The US Census "Tiger" Mapping Service classifies the area surrounding CSM Industries as having a population of 0.1- 24570 people per square mile. Assu
ming a worst case scenario of 24570 people per square mile, the 0.2 mile radius incident could affect around 3000 people and the 0.1 mile radius incident could affect 1500 people. These numbers were calculated assuming that 60% of the population would be home or in the area at the time of the incident. For Example, the 3000 affected population=(24570people x.2 mile radius x.6 (60 %) =_2948 people). These estimates seem high when considering the location of the plant. The 0.2 radius surrounding the plant is primarily industrial and railroad property. Much of the surrounding property inside of the 0.2-mile radius is used by the railroads and is not inhabited. When these factors are considered, an affected population numbers of 1500 for the 0.2-mile incident and 750 for the 0.1-mile incident are still conservative numbers. If the incident were to occur during an evening and/or weekend, these numbers would be significantly lower.
4. Prevention Program/Chemical-Specific Prevention: CSM Industries relies on several policies, procedures, and process control systems to prevent an accidental release from occurring at our facility. All transfers of liquids are completed within containment walls or diked areas with an employee present. The surfaces of these areas have been lined with an acid resistant epoxy resin system. Under the top coat of resin, there is a layer of figerglass that is designed to prevent thermal stress from fracturing the structure. All process holding tanks are located in secondary containment areas and have overflow/secondary reserviors. Once again, these containment areas are lined with an acid resistant coating. The secondary reserviors are sized to hold the entire contents of the main process holding tank(s) in the case of a process failure. As part of our preventativ
e maintenance program, every shutdown the piping and valving are given a visual/operational inspection. If problems are noted, the are fixed immediatley. CSM Industries conducts yearly training on its ERP program elements. This training is given to all of the process employees who handle regulated materials and includes spill policies and procedures. The final preventative measure that CSM has implemented is an around the clock staffing of the facility. Our plant is occupied 24 hours a day, seven days a week, ever day of the year by a Stationary Engineer. Part of their job duties is an hourly visual inspection of the process equipment.
5. Five Year Accident History: No reportable spills have occurred at this facility.
6. Emergency Response: The CSM Emergency Response Plan covers a wide range of emergency situations ranging from tornados to fire prevention. The plant is equipped with a manual pull station fire alarm system that has a direct link to a monitoring company. Pull stations are located at every exit and audio/visual strobe lights are strategically located throughout the plant. In the event of an emergency, if the alarm system is sounded, the monitoring company will call the Euclid Fire Department. The plant is occupied 24 hours a day, seven days a week by a Stationary Engineer. Part of their normal hourly duties include plant inspections of the process equipment. CSM's Emergency Response Plan details the course of action that shall be taken in the event of a spill. This plan includes a list of privately operated Hazmat facilities and Government Agencies which may need to be contacted in the event of an emergency. CSM Indusries mailed a copy of its mo
st recently reviewed ERP to the Euclid Fire Department on May 12, 1999. The emergency response plan also includes a section on first aid and possible health effects for the toxic and hazardous materials in the plant. MSDS sheets are also included in this document. CSM Industries conducts yearly training on the different components of the ERP and conducts a yearly fire drill. 7.Planned Changes to improve Safety:During the Risk Management assessment process several areas in the process were noted that could be improved. CSM Industries intends to add additional ventilation to the neutralization area. A Colag scrubber unit will be added to this area to prevent fumes from an accidental release from escaping to the basement air. Air monitoring equipment will be purchased and installed in this area to monitor the air borne a
cid concentrations. Additional enclosures will be added to this room to better seal it off from the rest of the plant. The electrical conduit runs and lighting will be upgraded to resist the possible corrosive environment. CSM Industries hopes to complete these improvements in the next fiscal year.