Detrex, Chemicals Division - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Detrex, Chemicals Division 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 regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Semi-conductor grade hydrochloric acid and zinc diakyldithiophosphates. We have 4 regulated substances present at our facility. These substances include Chlorine, Hydrochloric acid [Hydrogen chloride], Hydrogen and Furan. Chlorine is used for Making hydrochloric acid.. Hydrochloric acid [Hydrogen chloride] is used for shipments to customers. Hydrogen is used for making hydrochloric acid . Furan is used for making pyrrole and n-methyl pyrrole. . The maximum inventory of Chlorine at our facility is 180000.00 lb. while Hydrochloric acid [Hydrogen chloride], Hydrogen and Furan are present at our facility in quantities of 157500.00 lb., 100000.00 lb. and 40000.00 lb. respectively. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. 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 submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Chlorine storage and handling system.. In this scenario 180000 lb. of Chlorine is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 100% of the maximum capacity of the source by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The alternative release scenario for Furan involves a release from nmp/pyrrole manufacturing. The scenario involves the release of 40000 lb. of . 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 561.47 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of controlling the spill to enable cleanup. Under neutral weather conditio ns, the maximum distance to the toxic endpoint of 0.0012 mg/L of Furan is 3.1 miles. The alternative release scenario for Hydrochloric Acid (conc 37% or greater) involves a release from Storage of hydorchloric acid.. The scenario involves the release of 3750 lb. of . 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. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of controlling the liquid to enable quick cleanup.. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.030 mg/L of Hydrochloric Acid (conc 37% or greater) is 1.9 miles. The alternative release scenario for Chlorine involves a release from Chlorine storage and handling system.. The scenario involves the release of 1000 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporatio n takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by emergency shutdown system(s). These active mitigation systems have the effect of shut off of chlorine flow when the perimeter sensors detect chorine. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 1.4 miles. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Hydrogen storage and handling system. In this scenario 100000 lb. of Hydrogen is released. The release quantity has been limited to 100% of the maximum capacity of the source by a system of administrative controls. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.51 m iles is obtained corresponding to an endpoint of 1 psi overpressure. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 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 NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Detrex, Chemicals Division maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Checklist, What If/Che cklist (combined), HAZOP, FMEA and Fault Tree. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of yearly. Any findings related to the hazard analysis are addressed in a timely manner. The most re |