Chicago Specialties 115th Street - Executive Summary |
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Facility Information The Chicago Specialties plant has approximately 130 employees. The facility produces organic dyes and pigments and intermediate cyclic organics. Chicago Specialties uses three regulated chemicals in processes above threshold quantities. The facility uses sulfur trioxide as a feed material in the manufacture of paracresol, and sulfur dioxide as a diluent in the paracresol process. The facility stores up to 215,000 pounds of sulfur trioxide in an indoor storage vessel, and up to 50,000 pounds of sulfur dioxide in an outdoor storage vessel. The facility also uses anhydrous ammonia as a feed material in the production of isopthalonitrile. The regulated anhydrous ammonia process is a storage vessel, which can store up to 175,000 pounds of the material. Risk Management Planning In addition to our existing information sharing practices, Community Right-to-Know, emissions inventories, and Title V Permit, Chicago Specialties shares information regarding the chemica ls used and their associated risk with the public. The facility uses both passive and active mitigation to minimize the likelihood of releases and their impact to the public and to the environment. These mitigation systems emergency shutdown equipment and revised operating procedures and equipment for the covered sulfur dioxide process. The sulfur trioxide process uses dikes, sumps, emergency shutdown equipment, and a CO2 cryogenic mitigation system, which entails freezing the material if released. Accident History and Safety Improvements The table below lists Chicago Specialties' five-year accident history of all accidental releases from covered processes, which resulted in off-site evacuations, shelter-in-place, property or environmental damage, injuries, or significant property damage on-site. The incident in 1997 occurred on August 4. During the incident a transfer hose failure released 8,500 pounds of sulfur trioxide in to the environment, of which 7,000 pounds were release d to the atmosphere. A portion of the local vicinity was evacuated. There were no deaths or off-site property damage associated with this accident. The facility conducted an extensive safety review after the incident. Chicago Specialties has determined that the most likely cause of the accident was water the unloading connections of the tanker truck, which was loading sulfur trioxide into the facility's storage tank. The facility has subsequently installed several safety measures to reduce the likelihood of a reoccurrence of this type of incident: improved and upgraded equipment involved in the process, revised training, maintenance, emergency response plans, and operating procedures. The facility also installed new mitigation systems, which significantly reduced the risk of such an occurrence happening again. Chicago Specialties' 5-year Accident History The five year accident history was prepared in accordance with 68.42. The accidents reported in the RMP data elements only i nclude accidents related to a regulated chemical (SO2, SO3 or Anhydrous Ammonia) that resulted in deaths, injuries or significant property damage on-site or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. There were four releases of regulated chemicals in the past five years. Only the August 04, 1997 release meets the requirements of 68.42 for a release which must be reported. Year 1994 1995 1996 1997 1998 Number 0 0 0 1 0 Prevention Program Chicago Specialties believes the best way to manage risk is to prevent accidents. Chicago Specialties has performed a HAZOP analysis to identify and reduce the risk posed by the RMP covered processes. The prevention program will continue to reduce the risk through improved safety. Chicago Specialties' process safety management program includes but is not limited to; process safety information, operating procedures, training, pre-startup safety review, mechanical integrity, and man agement of change. In addition, the facility has incorporated process controls including, relief and check valves, manual and automatic shutoffs, interlocks, alarms, backup pumps, grounding equipment, rupture disks, sprinkler systems, fire walls and blast walls where appropriate. Emergency Response Policy Chicago Specialties has coordinated with the Local Emergency Preparedness Committee (LEPC) and Fire Chief Frank Moriarty. Chicago Specialties has prepared an extensive written emergency response plan. Specifically, the emergency response plan works to minimize the amount of material released to the environment and to establish control and mitigation of any releases in an expedited manner while communicating the nature of the incident to the public and local agencies. Worst-Case Release Scenario and Alternative Release Scenarios The RMP rule requires development of scenarios or examples for an accidental release of each RMP regulated chemical. The scenarios developed for Chic ago Specialties are outlined in the table below. About the Example Event Accident Prevention Scenario Radius of Emergency Response Chemical Chemical In-Place Concern1 Measures Sulfur Colorless Worst Case Toxic Standard Instantaneous failure 5.7 miles Communication with Trioxide liquid, forms Release Example Operating of tank walls public agencies; crystals at Procedures Worst possible weather Coordinate with 90 degrees F Tank conditions (low wind, low LEPC; Emergency Inspections humidity) Response Plan; Total release of entire Personal Protective contents of tank (215,000) Equipment; lbs) inside the building Response Equipment Sulfur Sulfur Alternative Case Relief Valves Rupture disk over- 0.68 miles See above Dioxide Dioxide is a Toxic Release Rupture Disk pressurization colorless gas Example Manual Shutoffs Average weather or liquid, with Automatic conditions a strong Shutoffs Duratio n of vent release -4 pungent odor. Interlocks minutes Sulfur Colorless Alternative Case Relief Valves Transfer hose rupture 0.75 miles See above Trioxide liquid, forms Toxic Release Rupture Disk Average weather crystals at Example Manual Shutoffs conditions 90 degrees F Automatic Release of 8,500 lbs. Shutoffs Interlocks Anhydrous Colorless Alternative Case Relief Valves 2,100 lb/min release per 0.30 miles See above Ammonia Caustic Gas Toxic Release Rupture Disk EPA RMP Ammonia with pungent Example Manual Shutoffs Guidance Document odor Automatic Shutoffs Interlocks 1. These distances are based upon an EPA-designated endpoint. |