Clearon Corp. - Executive Summary |
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ACCIDENTAL RELEASE AND EMERGENCY RESPONSE POLICIES At Clearon Corporation's South Charleston, WV Manufacturing Plant, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management acitivities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk managment program STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility produces chlorinated dry bleaches which are used extensively as sanitizers and disinfectants in detergents, cleansers, water treatment, and swimming pool and spa water treatment. The manufacture of our products utilizes a variety of chemicals and processing operations. One of our primary raw materials is chlorine, which EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release. Chlorine is the only chemical at the Clearon Corp. Manufacturing Plant which is subject to the EPA RMP rule. Chlorine is received in railroad tankcars and the maximum inventory at the site is 720,000 pounds. The inventory of chlorine is kept as low as practicable and the normal i nventory is much less than the maximum level which is only reached during unusual supply situaitons. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario and alternative release scenario for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case release scenario: Our worst-case accident scenario involving chlorine would occur in the highly improbable event that the walls of a full 90-ton railroad tankcar catastrophically fail, releasing the entire contents within 10 minutes. According to EPA's OCA Guidance Reference Table, the distance to the endpoint of the cloud is 14 miles. Administrative controls and mitigation measures in place to limit the distance include the following: * Water curtain sprays and stationary water monitors can be used to slow the vaporization of a liquid chlorine spill. Alternate release scenario: Our alternate release accident scenario involving chlorine would invovle a puncture or other failure in a steel reinforced hose used to hook to the chlorine railcar for unloading purposes wth the entire 1700 pound liquid chlorine contents of the unloading piping being released in 10 minutes. According to EPA's OCA Guidance Reference Table, the distance to the endpoint of the cloud is 0.2 miles. Administrative controls and mitigation measures in place to limit the distance include the following: * Only chlorine cars equipped with excess flow valves that automatically shut down the flow of chlorine in the event of a rapid release are used at the plant. * Water curtain sprays and stationary water monitors can be used to slow the vaporization of a liquid chlorine spill. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable c ontingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We maintain a number of programs to help prevent accidental releases and ensure safe operation. The plant has a Process Safety Management/Risk Management Planning organization with management systems in place to ensure that all elements of the OSHA PSM and EPA RMP regulations are followed. All new facilities are subject to thorough hazard reviews during design, construction and startup utilizing a program called "Safety in Engineering, Technology, Construction, and Operations" (SETCO). This program is intended to eliminate or mitigate any possible releases of hazardous chemcials in the workplace or environment. The entire chlorine process was studied during a comprehensive Process Hazard Analysis (PHA) led by one of the leading U.S. process safety consulting companies in 1997. All improvement recommendations from that study have been or are being addressed. As part of our preventio n efforts, we have implemented the following chlorine-specific prevention steps to address the scenarios given above. Worst-case release scenario: * Movement of chlorine cars within the facility is highly controlled by both plant personnel and railroad personnel. * The chlorine unloading station is isolated from other operations, thereby reducing exposure to fire or accidents. Cars positioned at the unloading station are protected by derail switches and monitored by video surveillance cameras. Alternate release scenario: * The chlorine unloading area is monitored by video surveillance cameras, periodic personnel inspections, and equipped with a number of highly sensitive chlorine detection instruments with alarms. * A computerized operating system automatically monitors the chlorine system at all times. * The chlorine unloading system is equipped with automatic shutoff valves that can be activated from three separate locations. * The system is equipped with pressure relief valves, whi ch will vent chlorine to a scrubber in the event of an overpressurization. FIVE-YEAR ACCIDENT HISTORY We have not had an accident involving chlorine that caused deaths, injuries, property or environmental damage, evacuations, or sheltering in place. EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our plant has designated and specially-trained emergency response teams on the site at all times. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. PLANNED CHANGES TO IMPROVE SAFETY A large number of recommendations to improve the prevention or response to accidental chemical releases were proposed in the extensive Process Hazards Analysis (PHA) mentioned above. Add itional recommendations were proposed during a Process Safety Compliance Audit conducted by the same leading process safety consulting company in 1997. Recommendations from these studies are either completed or scheduled for completion before the end of 1999. Furthermore, a capital project is approved and planned for 1999, which will significantly reduce the potential quantity of chlorine released in the alternate release scenarnio. |