Eagle-Picher Technologies LLC Chemicals Department - Executive Summary |
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CHLORINE CHEMICALS DEPARTMENT Eagle-Picher's Policy on Chemical Safety Eagle-Picher Industries, Inc. is committed to the highest standards of integrity in all aspects of its business conduct. The Company's Policy on Environmental and Health and Safety Responsibility and Ethics requires employees and facilities to conduct operations in conformance with all applicable laws and regulations and in a manner that will protect employees, the community and the environment. This Policy is implemented by our facility through specific programs designed to assure safe and responsible handling of all chemicals throughout the manufacturing process. Regulated Substance This facility processes chlorine to manufacture Lead Peroxide. The chlorine is stored in one ton containers and 150 pound cylinders and the maximum amount at any one time in the storage area is 8000 pounds. However, only one cylinder is connected to the covered process at any one time. The chlorine supply company personnel of fload the chlorine containers at the facility using the hoist located on the back dock of this covered process. Facility operators are responsible for hooking up the chlorine cylinder to the process feed line. The chlorine gas is fed into the process via a regulator and is sent through a vaporizer to heat the gas before being transferred to the reactor. Prescribed amounts of water and sodium hydroxide are first added to the lead dioxide reactor. Lead oxide or litharge is then added to the reactor under agitation. Once the slurry has been thoroughly mixed, the prescribed amount of chlorine is added to the reactor, an intermediate reaction occurs with sodium hydroxide and chlorine to form sodium hypochlorite. Once this reaction occurs, the potential release of gaseous chlorine has diminished. Release Scenarios AFTOX dispersion modeling predicts that the worst case release of 2000 pounds over 10 minutes would adversely affect an area extending 3.71 miles from the release. Census data from 1990 indicate that 30,341 people reside in this area. AFTOX further predicts that a less serious alternate-case release of 15 pounds would adversely affect an area extending 0.14 miles, which would just reach the nearest residence. The worst-case affected area includes residences, schools, and recreational and commercial areas, whereas the alternative-case affected area includes a single residence. No release scenario is predicted to affect any environmental receptors. Release Protection The chlorine process area has been regulated by OSHA's Process Safety Management (PSM) since 1994. The facility has successfully implemented all fourteen elements of the PSM program for the covered process. This facility has developed written operating and safety procedures for every facet of the covered process from delivery of the chlorine cylinder through the production of the final products. Employers working in the covered process are routinely retrained every three years in the o perating procedures as required by the PSM standard. The covered process is routinely reviewed by operating staff. A process hazard analysis must be preferred every five years to identify process concerns and develop solutions for them. In addition, all fourteen elements of the PSM program are reviewed every three years to ensure the program is in compliance with all OSHA PSM requirements. Eagle-Picher has trained personnel in the prevention and mitigation of a chlorine leak. Our trained personnel have the necessary personnel protective equipment and replacement parts to address any process leaks described in the alternative release scenario. Chlorine monitors are present in the process area that will sound an alarm in the event of a chlorine leak for emergency personnel to address the concern. In the covered process, the Chemicals Department has eight operators that are trained under the Hazardous Waste Operations and Emergency Response (HAZWOPER) 40-hour operations level. Thi s program requires that operators be trained in the hazardous chemical awareness and emergency response procedures. These individuals are trained to respond to hazardous chemical releases and implement proper responses to minimize any affects on human health and the environment. All HAZWOPER operators receive an annual eight-hour refresher training to maintain their certification. Practices at the Chemicals Department facility to prevent chemical releases include preventative maintenance program on the covered process equipment. Furthermore, any changes to the process must receive a process review and operators must be appraised of the modifications before they are implemented. Five Year Accident History There have been no accidents at this facility in the past five years involving chlorine. The Emergency Response Program Eagle-Picher has a monitoring system in the process area that continuously monitors for chlorine releases. In the event the monitors detect a release, an ala rm will sound alerting trained personnel to don the necessary safety equipment to mitigate the concern. Eagle-Picher has trained personnel in the prevention and mitigation of a chlorine leak from any storage container or processing equipment. Our trained personnel have the necessary personnel protective equipment and replacement parts to address any process leaks described in the alternative release scenario. In the event of a release that may potentially affect an offsite area, Eagle-Picher personnel will notify the proper local authorities as outlined in our Emergency Response Plan to inform them of the situation and advise accordingly. Eagle-Picher staff have met with local officials and outlined a course of action for informing the public. Planned Changes to Improve Safety No process modifications have occurred in this area since the PSM program went into effect. |