Hampshire Chemical Corporation - Executive Summary
General Executive Summary for Hampshire Chemical Corporation Deer Park, Texas Site |
1. Accidental Release Prevention and Emergency Response Policies
We at Hampshire Chemical Corporation (HCC) Deer Park, Texas are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of all substances.
2. The Stationary Source and the Regulated Substances Handled HCC - Deer Park primary activities encompass Chemical Manufacturing. We have 4 regulated substances present at our facility. These substances include Ammonia (anhydrous), Ethylenediamine [1,2-Ethanediamine], Formaldehyde (44.5 % solution) and Hydrocyanic Acid. The primary businesses are
the manufacturing of a surfactant called DAXAD, Glycine, and Chelating agents. The DAXAD manufacturing process regulated raw material is Formaldehyde. The Glycine manufacturing process regulated raw materials are Anhydrous Ammonia, Formaldehyde, and Hydrocyanic Acid. The Chelant process utilizes Ethylenediamine, Formaldehyde, and Hydrocyanic Acid.
The maximum inventory of Formaldehyde (44.5 % solution) at our facility is 408,276 lb. while Ammonia (anhydrous), Hydrocyanic Acid, and Ethylenediamine [1,2-Ethanediamine] are present at our facility in quantities of 284,438 lb., 262,219 lb., and 205230 lb. respectively.
3. The Worst Case Release Scenario and the Alternative Release Scenarios, including administrative controls and mitigation measures
To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario su
bmitted for Program 3 toxic substances as a class involves a catastrophic release from Hydrocyanic Acid Storage System. In this scenario 106140 lb. of Hydrocyanic Acid is released from a railcar. The toxic gas is assumed to be released within 10 minutes. The released quantity is 100 % of the maximum capacity of the source. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 15 miles is obtained corresponding to a toxic endpoint of 0.011 mg/L.
The alternative release scenario for Hydrocyanic Acid involves a release from Hydrocyanic Acid Storage System. The scenario involves the release of 5487 lb. of Hydrocyanic Acid. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by an emergency shutdown system and water monitor. These active mitigation systems have the effect of reducing the liquid relea
se and vapor suppression. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.011 mg/L of Hydrocyanic Acid is 1.4 miles.
The alternative release scenario for Formaldehyde (44.5 % solution) involves a release from the Formaldehyde Storage System. The scenario involves the release of 19180 lb. of 44.5 % Formaldehyde solution. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 1918 minutes. The release is also assumed to be controlled by an emergency shutdown system and water monitor. These active mitigation systems have the effect of reducing the liquid release and vapor suppression. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.012 mg/L of Formaldehyde (44.5 % solution) is 0.43 miles.
The alternative release scenario for Ammonia (anhydrous) involves a release from the Anhydrous Ammonia Storage System. The scen
ario involves the release of 158 lb. of Anhydrous Ammonia. The Toxic gas is assumed to be released within 10 minutes. The release is also assumed to be controlled by a sprinkler system, excess flow valves and water monitor. These active mitigation systems have the effect of reducing the gas release and vapor suppression. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.38 miles.
The alternative release scenario for Ethylenediamine [1,2-Ethanediamine] involves a release from the Ethylenediamine Storage System. The scenario involves the release of 71100 lb. of Ethylenediamine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 357 minutes. The release is also assumed to be controlled by water monitor . This active mitigation system has the effect of reducing evaporation of liquid to the air (vapor suppressio
n). Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.49 mg/L of Ethylenediamine [1,2-Ethanediamine] is 0.19 miles.
4. The General Accidental Release Prevention Program
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with industry accepted design practices and engineering standards. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Hampshire Chemical Corporation maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. For example, this information can be found in our Material Safety Data Sheets (MSDS), process design files, equipment specification files and process safety information
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodologies used to carry out these analyses are What If, Checklist, Hazop Dow Fire and Explosion Index, Dow Exposure Index and Dow Reactive Chemical Process Hazard Analysis. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated every 5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 03/01/1999.
For the purposes of safely conducting activities within our covered processes, Hampshire Chemical Corporation maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup
after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
Hampshire Chemical Corporation has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every year and more frequently as needed.
Hampshire Chemical Corporation carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the mai
ntenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at Hampshire Chemical Corporation to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 04/15/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Hampshire Chemical Corporation. The most recent review was performed on 05/28/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Hampshire Chemical Corporation c
onducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 05/26/1999. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
Hampshire Chemical Corporation promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
Hampshire Chemical Corporation truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to
recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct specialized maintenance, construction and various other activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Hampshire Chemical Corporation has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-year Accident History
Hampshire Chemical Corporation has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release
during this period as defined by the Risk Management Program rule of regulated substances.
6. Emergency Response Plan
Hampshire Chemical Corporation carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
Deer Park and La Porte is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. We are also coordinated with Channel Industries Mutual Aid (CIMA) which provides additional emergency resp
7. Planned Changes to Improve Safety
Hampshire Chemical Corporation - Deer Park, a subsidary of The Dow Chemical Company is in the process of implementing the Dow Environmental, Health and Safety (EH&S) standards. This would include the implementation of an EH&S management system and work process which would manage the execution of the following standards: personnel safety, process safety, industrial hygiene and environmental compliance. These changes are expected to be implemented by 12/31/99.