PVS TECHNOLOGIES, INC. (DETROIT) - Executive Summary

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PVS Technologies, Inc. is a manufacturer and marketer of chemicals used in the treatment of industrial and municipal water.  In addition to the iron salts (ferrous chloride solution and ferric chloride in both liquid and anhydrous forms), PVS Technologies also produces blends of ferric chloride and polymers for its customers.  Liquid ferric chloride is primarily used in water/wastewater treatment and phosphate removal.  Anhydrous ferric chloride, also a water treatment chemical, is utilized as a raw material for many industrial applications such as pharmaceutical, plastics, chemical milling, etc.  PVS Technologies, Inc. operates a ferric chloride manufacturing facility that is located on 10825 Harper Avenue, Detroit, Michigan 48213. 
 
The ferric chloride production process uses chlorine as a reagent.  Chlorine, the 17th element on the periodic table, is commonly used in the purification of potable water.  Other uses include hospital sanitation, swimmimg pool treatment, etc.  Chlorine is 
also a basic ingredient in the production of pharmaceutical and agricultural products as well as consumer products such as vinyl siding for houses, PVC pipes for plumbing, etc.  The same properties that make chlorine valuable as a commodity also necessitate the adoption of safety precautions in its handling. 
 
In concert with our overall commitment to Responsible Care, it is our policy to design, operate and maintain our manufacturing facility in such a manner that minimizes any risks to our employees, our local community and the environment.  In brief, our goal is as follows:"No accidents, injuries or environmental mishaps." The PVS Technologies-Detroit Facility has no accidents as defined under the RMP rule in the previous five years. 
 
In addition to our pledge for full compliance with all applicable federal, state and local rules and regulations, we have been actively engaged in developing and applying not only innovative and sound technology but also safe operating standards to our 
production processes.  Our chlorine unloading system is designed in accordance with the Chlorine Institute standards.  We conduct Hazard and Operability (HAZOP) studies on all chlorine related process designs and modifications.  Pre-startup safety reviews are also performed whenever necessary.  Ambient chlorine sensors (local and perimeter) and automatic shut off valves are in place in order to detect and minimize any chlorine releases to the atmosphere.  A two-stage scrubber system is installed for proper neutralization of any residual levels of chlorine from our production processes.  Continuous camera surveillance from the plant control room is in place to visually detect any releases from the scrubber stack, the railcar hookup stations or the process areas.  A standby electric generator is provided for backup power to critical systems such as the fume scrubbers, the transfer pumps, etc.  A preventive maintenance program is in place for properly planning and documenting the repair  
and/or maintenance of our process equipment.  Routine safety audits (tailored to the Dupont Safety Audit Program) by supervisors and managers are conducted.  The employee training program, including the annual PVS 32- Hour training requirement, the OSHA 24-Hour HAZWOPER training (initial and refresher) and others, are conducted in order to maintain and/or enhance process safety.  Our Emergency Response Plan includes specific guidelines for getting the right people (both on-site and off-site) and equipment to the scene quickly.  In the event of an emergency involving a chlorine release, PVS Technologies personnel are trained in measures to control the release.  In addition, our Emergency Reponse Plan has been provided to local response organizations for inclusion into the Community Emergency Response Plan.   
 
The regulated material, i.e., liquid chlorine, is brought to the manufacturing facility by railcars that are unloaded directly into the process.  Access to the site is restricted t 
o authorized facilty employees, management staff and approved contractors.  The maximum inventory of chlorine stored at the Detroit Facility is 720,000 pounds (four railcars).  Only two railcars are hooked up to the production processes at any time. 
 
The worst-case scenario, as required by USEPA,  involves the failure of a 90-Ton railcar, thus releasing 180,000 pounds of chlorine to the atmosphere.  It is assumed that the entire content is released within a ten-minute period.  The release would have off-site consequences.  With regards to the alternative release scenarios, the Detroit Facility has three covered processes, i.e., liquid ferric chloride ("LFC"), anhydrous ferric chloride ("AFC") and railcar storage as stationary source.  The three alternative release scenarios are as follows.  For the LFC process, the scenario involves an instantaneous release of 17 pounds of liquid chlorine from a ruptured chlorine hose.  Active mitigation involves an automatic isolation of the ruptured  
section from the chlorine source and the rest of the chlorine delivery system.  The liquid chlorine flashes immediately to vapor and fine liquid droplets and is carried downwind.  The scenario for the AFC process pertains to a 36-pound release of chlorine vapor from a pressure gauge failure.  It is assumed that the angle valve on the railcar will be manually closed by an operator within three minutes.   For the stationary source, the scenario involves a slow seepage from the railcar safety valve, thus releasing about six pounds of chlorine vapor.  An emergency capping kit will be used to stop the release.   All three scenarios would have off-site consequences. 
 
Through the use of employee suggestions, periodic safety meetings, safety audits and formal process safety reviews, PVS Technologies continuously evaluates the safety of our processes and operating procedures and makes improvements as appropriate.  No major process changes are planned.
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