Chemical & Metal Industries, Inc. - Executive Summary |
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Chemical & Metal Industries, Inc. ((C&MI) is a manufacturer of antimony pentachloride catalyst. Antimony pentachloride is a fluorination caytalyst used primarily in the manfucture of refrigerants (CFC replacement fluorocarbons), fluoropolymers, and pharmaceuticals. C&MI uses chlorine and chloroform in this manufacturing process. In additon, C&MI utilizes reactor residues containing antimony chloride fluoride -- a byproduct from the fluorocarbon manufacturing industry. The utilization of this byproduct substantially reduces the amount of primary raw materials, including chlorine, necessary for manufacture. 1. Accidental release prevention and emergency response policies. The handling of antimony pentachloride and of the chlorine, chloroform, and other raw materials used in its manufacture requires certain safety precautions. C&MI's manufacturing process is a closed system. C&MI has developed an emergency response and contingency plan in accordance will applicable regulations. This plan has been reviewed by several governmental agencies and consulting firms. The plan includes procedures for notification of the local fire department and of potentially affected neighbors in the event of an unauthorized release of hazardous chemicals. C&MI is dedicated to continual process and engineering improvements to reduce the amount of hazardous materials utilized and stored, to upgrade the manufacturing process and facility, and to improve process alarms and controls. 2. The stationary source and regulated substances handled. The regulated sustances handled at Chemical & Metal Industries, Inc., are chlorine and chloroform. Chlorine is received and handled in one-ton cylinders. The total inventory of chlorine stored at this plant is 6,000 lb. C&MI also receives and handles chloroform. The maximum inventory of chloroform is 4,000 gallons (~50,000 lb.); average inventory of chloroform is estimated to be 2,800 gallons (~35,000 lb.). The chloroform, primarily rec eived as an impurity in returned antimony catalyst residues, is isolated for reuse in C&MI's manufacturing process. 3. The worst case release scenarios and the alternative release scenarios. Worst case scenario -- chlorine. The worst case chlorine scenario is the failure of a 1 ton cylinder releasing 2,000 lb. of chlorine. It is assumed that the entire contents of this cylinder are released in 10 minutes. The distance to the endpoint of 0.0087 mg / L (3 ppm) was determined to be 0.9 miles. C&MI is currently designing containment and mitigation equipment for its chlorine storage area. This equipment, to be installed within the next several months, will greatly reduce potential for chlorine to impact the surrounding areas. Alternative release scenario -- chlorine. The alternative release scenario for chlorine assumes the failure of a one-half inch liquid chlorine transfer hose. The distance to the endpoint of 0.0087 mg / L was determined to be 0.2 miles. Worst case scenario -- chloroform. The worst case scenario for chloroform assumes the failure of a process vessel containing 6,000 lb. chloroform. This vessel is located in an indoor, diked area. The distance to the endpoint of 0.49 mg / L was determined to be less than 0.1 mile. Alternative release scenario -- chloroform. The alternative release scenario for chloroform assumes the failure of a three-quarter inch valve on a tank containing 2,200 lb. (172 gallons) of chloroform. The primary chloroform storage is in 200 gallon ton tanks in an indoor area. The distance to the endpoint of 0.49 mg / L was determined to be less than 0.1 mile. 4. The general accidental release prevention program and the specific prevention steps. This manufacturing facility complies with EPA's Accidental Release Prevention Rule. C&MI operates its chlorine handling based on recommendations of the Chlorine Institute as applied to C&MI's unique process. 5. Five-year accident history. March 18, 1999: C&MI had an acci dental release of approximately 110 gallons (1,855 lb.) of spent antimony catalyst. This spent catalyst did not contain either free chlorine or chloroform. However, antimony pentachloride will react with the moisture in air to form hydrogen chloride gas. An estimated 226 lb. of hydrogen chloride was released. No one off-site or on-site was injured. Surrounding businesses were evacuated and adjacent streets and highways closed. The incident was initiated by a defective valve on a one-ton tank containing spent antimony catalyst. The valve had been installed by a customer, and the tank was undergoing its initial check in. The operator sampling this tank was unable to reclose the tank valve. To prevent a recurrence C&MI has redesigned its sampling equipment and procedure. Steps have been taken to ensure customers send only C&MI approved valves on tanks of spent antimony catalyst and C&MI operators do not attempt procedures with non-approved tank valves. March 13, 1999: On Marc h 13, 1999, C&MI notified 911 of a potential hazardous materials situation. A high pressure condition was noted on one of C&MI's process vessels. The operator shut down the process and the process condtions returned to a normal range without serious incident. C&MI's in-plant gas monitoring system did not detect alarm conditions during this event. Though the pressure exceeded normal process conditions, the reactor pressure rating was not exceeded. Operating procedures were revised and reviewed. July 31, 1998: C&MI notified 911 of an unauthorized release. Approximately 200 mL of antimony pentachloride product was released from a process gasket during a pressure purge. The operator immediately ceased the purge such that the release duration was only seconds. The material was immediately neutralized. A maximum of 0.25 lb. of hydrogen chloride may have been released as the antimony pentachloride reacted with the moisture in air. Air monitoring conducted in the immediate plant area indicated that the concentration of hydrogen chloride did not exceed exposure limits during the incident. No on-site or off-site injuries occurred. Operating procedures which call for the pressure testing of this gasket prior to each use were reviewed. In addition, C&MI has modified production processes to attempt to reduce the frequency of the operation involved. Allternative equipment is actively being investigated. July 24, 1998: C&MI notified 911 of an unauthorized release. During the pressure testing of equipment a quantity of vent gases was released to C&MI's facility. The estimated hydrogen chloride release was less than 0.03 lb. No on-site or off-site injuries occurred. June 14, 1998: During the manufacturing process, the air pollution control scrubber was not operating for a period of approximatly 2 to 4 hours. The estimated emission during this period is 0.001 lb. of hydrogen chloride gas. No on-site or off-site injuries occurred. The scrubber alarm an d control system was subsequently modified. July 17, 1997: During the dilution of a hydrochloric acid solution with spent process water, the receiver 55 gallon drum foamed over. Less than one-half gallon of the 12% hydrochloric acid solution foamed over and was contained in the lip of the drum. This procedure was immediately and permanently discontinued. No on-site or off-site injuries occurred. March 19, 1997: Due to an operational error, antimony pentachloride was misdirected to a caustic scubber system causing a release of an estimated 347 lb. hydrogen chloride. Approximately 10 people were evacuated from the business immediately north of C&MI's operations. They were taken to a hospital for observation and released. No on-site or off-site injuries occurred. Additional alarms, process monitoring, and operating procedures were instituted. A ventilation fan on the north side of C&MI production operations was removed to reduce off site impacts. Additional emergency no tification procedures were instituted. December 17, 1995: During a period when the facility was unoccupied, a reactor overheated, causing a pipe failure and the spill of an antimony pentachloride, antimony trichloride mixture. This mixture, reacting with the moisture in air resulted in the release of an estimated 500 lb. of hydrogen chloride. No on-site or off-site injuries occurred. The practice of holding a reactor at an elevated temperature during periods when the facility is unoccupied was immediately and permanently discontinued. The heating unit controls were also modified to eliminate the potential for the heating unit to fail in a heating mode. Additional emergency equipment was installed and procedures instituted to alert a C&MI employee during periods when the facility is unoccupied. 6. Emergency Response Program. C&MI's Emergency Response and Contingency Plan has been submitted to and reviewed by OSHA, the Denver Fire Department, Colorado State University's Occu pational Health and Safety Service, URS Operating Services, Inc. and EPA during a voluntary consultatation in October 1998, Region VIII EPA and CDPHE as part of an Hazardous Waste Management audit in October 1998, and VECO Engineering Consulting firm as a part of a facility hazard assessment conducted in March-May, 1999. A representative of the Denver Fire Department will visit our plant site at least annually. C&MI has also contracted an outside emergeny response contractor, E. T. Technologies, to be available in the event of future spill clean-up activities. C&MI's Emergency Response team receives annual training at Front Range Community College. More frequent training and drills are part of C&MI's safety and training program. 7. Planned changes to improve facility safety. C&MI is currently planning the relocation and expansion of its facility. The goal is to be relocated by the third quarter of next year (2000). This relocation will allow a complete redesign and upgrade of t he manufacturing and storage facility. The relocation will consider facility siting to reduce the potential for off-site impacts. In addition, the proposed relocation site will be close to C&MI's supplier of chlorine, thus reducing hazardous materials transportation distances. At its current facility, C&MI is engineering mitigation equipment for the chlorine storage area. Our goal is to install this equipment by the third quarter 1999. This equipment will greatly reduce the potential for off-site impacts in the event of a chlorine ton tank failure. Additional spill control diking for the current facility storage area has been ordered and is expected to be installed in July 1999. Also in July 1999 installation will begin on process equipment which will modifiy a portion of the process involving chloroform use. This equipment will have greater automatic controls and will reduce the operator involvement. The installation of spill control diking in this process area will be part o f this improvement. C&MI has a continuing program to evaluate and improve the safety and operability of its processes, procedures, and equipment. This effort is supported by in-house research and engineering and outside engineering and environmental consultation support. Dedicated to serving the inorganic specialty chemical and catalyst markets, Chemical & Metal Industries has based more than twenty years of growth on a commitment to research and environmental awareness. |