Sybron Chemicals - Executive Summary |
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Facility Information Sybron Chemicals Inc. operates a facility in Norwich, Connecticut, which employs approximately 38 full time employees. The Norwich Plant is a specialty chemical manufacturer servicing the textile industry. The chemical manufacturing at the facility is conducted in the batch mode. The Norwich facility uses only one regulated chemical that is above threshold quantity as specified in the Risk Management Program regulations. The facility stores a 37 % formaldehyde solution in a storage tank at a 95% administrative volume control, which holds 31,635 pounds. Sybron Chemicals adheres to the appropriate government rules and industry guidelines for the storage and use of this toxic substance. Risk Management Planning Sybron Chemicals has an extensive information sharing practice with its workers and the general public regarding the chemicals used at the facility and their associated risks. Sybron Chemicals is subject to the Risk Management Program requirement un der Section 112 (r) of the Clean Air Act due to its storage and process use of formaldehyde. The facility uses both passive measures and active mitigation to minimize the likelihood of releases and their potential impact on the public and on the environment. These mitigation systems include a range of various deterrents to further minimize a release. The mitigation system for the formaldehyde tank and associated reactor vessels include: - excess flow valves that limit the possibility of excess fluid escaping, - a vapor recovery system, - relief vents, which redirects the chemicals into a water scrubber that vents into an emergency blow-down trap tank to prevent overpressurization of the reactor and to control the releases to the atmosphere, - an N2 purge, which suppresses the potential ignition of a fire, and has a water cannon to slow down the evaporation rate and squelch fire. - a dike surrounds the formaldehyde tank, which is designed to contain its entire contents. Worst-C ase Release Scenario The instantaneous failure of the formaldehyde solution tank and complete failure of both the active and passive mitigation systems is used as the Regulated Toxic Substance Worst-Case Scenario at the facility. The only surviving passive mitigation system is considered to be the dike, which controls the liquid in a 2,100 sq. foot pool. This scenario results in a total release of the tank contents (33,300 pounds). Moreover, the worst case meteorological conditions for Norwich are incorporated into the calculation of the endpoint distance for the formaldehyde release. The conditions are: temperature of 36 oC, humidity of 64.5%, and a windspeed 1.5 m/sec. This endpoint extends beyond the facility's property line. The radius of concern includes a residential population, industrial facilities, and recreational. Alternate Release Scenarios Alternate release scenarios are examined for the formaldehyde tank and process at the Norwich facility. Three plausible situat ions can possibly occur involving the formaldehyde tank and its reaction vessel. The first scenario involves the failure of the formaldehyde storage tank, causing a liquid pool to form. The second and third scenarios involve the complete failure of the formaldehyde reaction vessel. Typical meteorological conditions for Norwich, Connecticut are used to determine the three alternate scenarios. The average conditions are: temperature of 10 oC, humidity of 68%, and windspeed 3.1 m/sec. Alternate Scenario 1: There is assumed to be a complete failure of the formaldehyde storage vessel, resulting in a total release of the liquid (33,300 pounds) into a containment area of 2,100 sq./ feet. The release rate is calculated to be 1.0 pounds/minute and is assumed to continue for 8 hours, at which time the spill is further mitigated. The endpoint distance includes a residential population, industrial facilities, and recreational areas. Alternate Scenario 2: There is assumed to be a complete failure of the unmitigated formaldehyde reaction vessel, releasing 16,650 pounds of solution. This release forms an unmitigated pool of 7,326 square feet. It is assumed that a portion of the solution has evaporated since the spill may take 8 hours to clean up. The solution evaporates at a rate of 3.6 lbs./minute for 8 hours. The endpoint distance for this scenario includes a residential population and industrial facilities. Alternate Scenario 3: There is assumed to be a complete failure of the formaldehyde reaction vessel, resulting in a total release of the liquid (16,650 pounds), forming an unmitigated pool of 7,326 sq./ feet. The building however, mitigates the spill. The release rate is calculated to be 0.4 pounds/minute and is assumed to continue for 8 hours, at which time the spill is completely mitigated. The endpoint distance of this formaldehyde release scenario does not include a residential population or environmental receptors. Accident History and Safety Informat ion Sybron Chemicals is committed to keeping preventive procedures, safety precautions, and alternatives updated. In addition, standard operating procedures are available for all pieces of equipment, which entail process descriptions, safety information, and emergency shut down instructions. Furthermore, personnel are trained to respond to minor accidental releases. The facility is continuously improving operating procedures, equipment, and several safety measures to reduce the likelihood of an incident. A five-year accident history is defined by the RMP regulations to include accidents related to regulated chemicals that result in deaths, injuries, or significant property damage on site or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Sybron Chemicals has not had any accidents involving a release of a regulated substance in processes within the past five years. Emergency Response Program Sybron Chemicals believes t he best way to manage risk is not only to prevent accidents, but to also correctly know what to do if an accident should occur. After careful consideration of the identified release scenarios, the accident history, and a review of the latest inspection report from the Connecticut Department of Environmental Protection and the Fire Department, no changes to the current systems are planned. The Emergency Response Program will continue to reduce the risk through continuous use of safety precautions and instruction manuals that already exist at the facility. Sybron Chemicals' Manufacturing Practices and Procedures Manual includes such Risk Management components as: process safety information, equipment identification, operating procedures, inventory restrictions, process or facility change, employee participation plan, injury/incident reporting and investigation, chemical hygiene, forklift safety, wastewater treatment procedures, line breaking, head/eye/foot protection, respiratory prote ction, hazard communication plan, and plant emergency operations. |