Von Roll America, Inc - Executive Summary |
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Executive Summary Environmental and Safety Policy: It is the policy of Von Roll America Inc. (Von Roll) to conduct itself as a good corporate citizen, to be a responsible member of the region's industrial community, and to comply with all federal, state, and local environmental laws and regulations. Von Roll strives continuously to maintain safe operations and implements safe operating procedures in all processes at the facility. Von Roll practices a proactive approach with respect to communications with East Liverpool and neighboring communities. A monthly newsletter is published and distributed to 1200 people including employees, regulators, local residents, and elected officials. The facility's Web Page (http://www.vonrollwti.com) provides information on safety, environment, training, plant improvements, tours, and other pertinent information. Voluntarily, monthly meetings are held with two local citizens groups (Community Advisory Council and East Liverpool Liaison Committee) for updates on plant operations, permitting, and safety. Communication channels are also established through participation of facility employees in local civic organizations such as the Kiwanis, Rotary, and Lions. In short, Von Roll maintains safe operations at the facility and practices open communication with the local community, many of whom are employees of the facility. Facility Operations and Setting: Von Roll operates a hazardous waste treatment, storage, and disposal facility (TSDF) in East Liverpool, Ohio. Solid and liquid wastes within permit specifications are received in the facility and thermally treated in a rotary kiln incinerator. The facility has a final permit status under the Resource Conservation and Recovery Act of 1976 (RCRA). Wastes are received at the facility in liquid, solid, and semisolid form in packages (lined boxes, fiber packs, metal cans, drums, and reusable containers) or in bulk (dump trucks or tank wagons). The wastes are pre-approved and re gistered in a computerized tracking system. Upon arrival, the wastes are weighed and the associated paperwork reviewed to verify compliance with regulatory requirements. The wastes are sampled and, after approval, directed to the appropriate process treatment area. Bulk solids are emptied directly into storage pits, then transferred into the feed hopper of the kiln by a clamshell bucket crane. Bulk liquid wastes are unloaded under a roof in a diked, concrete area. The tankers are purged with nitrogen. Fugitive emissions are captured and ducted to the incinerator or treated through activated carbon units. Limited types of bulk liquid wastes are pumped directly to the kiln from the tankers. Drummed wastes are processed under a roof in the drum processing building. Organic waste blending occurs in an indoor tank farm. All waste handling, storage, and treatment areas are concrete diked and contain collection sumps to capture any spilled materials. In addition, overhead ventilat ion hoods that vent to the incinerator or activated carbon units service all handling areas. The facility is located approximately 30 miles northwest of Pittsburgh, Pennsylvania on the Ohio River in East Liverpool, Columbiana County, Ohio. The facility is located directly across the Ohio River from West Virginia and less than one-half mile from the Pennsylvania-Ohio border. The area in the immediate vicinity is mixed residential and commercial, with some light industrial activity present. The facility is situated on a 21.5 acre tract. The site is bordered on the north by Conrail railroad tracks, on the west by an industrial supply company (GRH Co.), and on the south and east by the Ohio River. The area immediately surrounding these properties is zoned medium-high density residential use. The topography of the area is gently rolling, except in the immediate vicinity of the site where the Ohio River forms a steep river valley. Considering the local and regional topographic elevat ions near the site, it is likely that the winds will be channeled along the valley, with predominant wind flow to the east-northeast. The closest incorporated areas to the facility include East Liverpool, Ohio; Chester, West Virginia; Wellsville, Ohio; and Midland, Pennsylvania. Regulated Substance(s): Von Roll does not generate any appreciable amount of waste or chemicals at the facility. All chemicals at the facility are received from waste generators around the nation. The facility receives wastes from various generators and the constituents of the wastes vary. It is impossible for Von Roll to predict the type of waste entering the facility. However, only wastes conforming to pre-selected profiles are accepted at the facility. The waste profiles include constituents and ranges of percentage of the constituents. The waste profiles are the basis of determining the regulated substances for the Risk Management Program. Based on a comprehensive review of waste profiles receive d at the facility in the calendar year 1998, the following regulated substances could be reasonably expected to be present at the facility at any given time above the threshold quantity (TQ) established pursuant to the Risk Management Program (RMP): ' Ethyl ether, chloroform, carbon disulfide, vinylidene chloride, methyltrichlorosilane, pentane, furan, crotonaldehyde, hydrofluoric acid, and trichlorosilane. The regulated substances are present in five processes; namely: i) the organic waste tank farm; ii) the drum storage area; iii) the pump-out/blend tanks; iv) the drum conveying area; and v) the direct feed to the kiln. Worst-Case Release Scenario: The worst-case release scenario (WCS) for toxic substances was based on the catastrophic rupture of the single largest vessel in the organic tank farm, in which 100,000 lbs of furan in a waste mixture was considered to be spilled in a diked area. Furan was assumed to be evaporating after the spill. Administrative controls on th e maximum quantity of furan was considered, based on the permitted waste profile. Credit was taken for passive mitigation such as indoor release into a diked area. The WCS for flammable substances was a theoretical spill of 340,000 lbs of a mixture containing pentane from the largest tank in the tank farm, evaporation of pentane from the liquid pool, and subsequent vapor cloud explosion. RMP default meteorological data were selected and EPA's RMP*COMP software was used for determining off-site impact. The WCS for both toxic and flammable substances were shown to have off-site impact. Worst-case release scenarios from other covered processes at the facility did not impact any additional public or environmental receptors. Von Roll believes that the WCS (i.e. catastrophic rupture of a tank in the tank farm) is extremely unlikely. First, the tank is at ambient pressure and temperature and is located indoors within a secured building. Second, per the existing process safety management (PSM) practices at the facility for this process, the tanks are regularly inspected and tested for mechanical integrity. Third, the area is not known to have earthquakes. Fourth, the WCS assumes that active mitigation measures are not functioning. Finally, a catastrophic release from such tanks has never been reported in the industry. The impact distances for these scenarios therefore are highly conservative and are not realistic. A recent EPA analysis of potential accidental release scenarios at the facility identified a most conservative on-site spill of only 5,000 gallons, or approximately 12% of the quantity considered in the WCS. Alternative Release Scenarios: Several alternative release scenarios (ARS) were evaluated for the process. The scenarios were selected based on process hazard analyses performed by the facility, EPA guidelines, and industry guidelines. Von Roll believes that these scenarios are more likely than WCS, though still unlikely in view of the on-going PSM practices. The ARS was a spill from a tank in the organic tank farm. One ARS was considered for each toxic substance. For flammable substances, the ARS was a release of a mixture containing pentane and subsequent pool fire. Administrative controls and passive mitigation were considered as in the case of WCS. Additionally, active mitigation by on-site responders was also considered to contain the spill within 10 minutes. RMP default meteorological data was selected and EPA's RMP*COMP software was used for determining off-site impact. For ARSs for toxic substances, the distance to the endpoint for the various regulated substances was between 0.1 mile and 0.7 mile (furan). For flammable substance, the impact distance of ARS was 0.07 miles. Accident Prevention Program: The Von Roll facility has developed and implemented a PSM program for the processes covered by the RMP. Von Roll performs daily, monthly, and annual inspections of all process components. Safe operating procedur es are regularly reviewed and updated whenever necessary. The operators are regularly trained on handling wastes in the various process areas and on emergency response actions. Deluge systems are installed at all possible areas of release to contain fires. In addition, any release within the buildings is vented to the incinerator or activated carbon system, which operates continuously. In November 1998, Von Roll became the first commercial hazardous waste incineration facility to obtain certification to the ISO 14001 standard, the international standard for environmental management. As part of the process, Von Roll has critically reviewed safety and health issues at the facility and has taken appropriate measures to exceed all standards. The ISO certification demonstrates Von Roll's commitment to the employees and the community by maintaining safe operations. Five-year Accident History: There have been no accidental releases from any of the covered processes at the facility in t he last five years, which meet the reporting criteria of the RMP. Von Roll is committed to maintaining this safety record. Emergency Response Program: The facility is not included in the community emergency response plans of Columbiana County. However, the facility has developed and implemented an emergency response plan. The emergency plan includes emergency and incident notification reporting, emergency health care, emergency response actions, training and drills, and an incident prevention program, which fulfills all requirements of RMP. Emergency response training is part of the plan and the most recent training was performed in April 1999. The facility's emergency response plans are coordinated with the East Liverpool Fire Department. The plan was updated in March 1998 and will be updated whenever there are changes at the facility that may impact emergency response actions. Copies of the plan are made available to the county LEPC and city fire department. Planned Safety Im provements: Von Roll believes that the processes at the facility are operated and maintained in a safe manner. There are no additional plans for changes specific to the processes covered by RMP. However, improving safety is continuously ongoing at the facility. Von Roll plans to take all necessary, realistic, and technically and economically feasible actions to improve safety, whenever determined to be necessary. |