Safety-Kleen (Bridgeport), Inc. - Executive Summary |
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RISK MANAGEMENT PROGRAM EXECUTIVE SUMMARY FOR SAFETY-KLEEN (BRIDGEPORT), INC. SAFETY-KLEEN (BRIDGEPORT) FACILITY DESCRIPTION The Safety-Kleen (Bridgeport) incineration facility, a wholly owned subsidiary of Safety-Kleen Corporation, is located in Bridgeport, New Jersey. The Safety-Kleen (Bridgeport) facility is a USEPA and NJDEP Part B permitted hazardous waste incinerator located in southern New Jersey. The facility manages organic waste from a variety of sources, including industry and government. Organic wastes are treated in a rotary kiln/ liquid injection incinerator. The incinerator treats the organic waste to a minimum 99.99% destruction and removal efficiency. All combustion gasses are scrubbed to remove acids, particulate, and metals. During the past two years, Safety-Kleen (Bridgeport), Inc., has participated in discussions regarding the most recent Risk Management Program requirements with state and local officials and community groups. These informative interactions hav e included educational sessions with local corporations, emergency response personnel, and community activist to discuss the facilities prevention programs, emergency response preparedness, and possible worst-case and alternate-case release scenarios. An open- house information session was held at the Safety-Kleen, Bridgeport facility on May 1, 1999. 1.0 ACCIDENTAL RELEASE PREVENTION & EMERGENCY RESPONSE POLICIES 1.1 SAFETY POLICIES Every Safety-Kleen (Bridgeport) [S-K (BP)] employee is responsible for identifying all safety, health and environmental hazards in their working environment. The primary consideration in every effort is to evaluate the safety, health and environmental aspects, and to take any necessary precautions to avoid any detrimental exposures and/or releases. To accomplish this, we must provide a safe work place, safe equipment, proper materials and the necessary training, and obtain full knowledge and understanding of our safety, health and environmental responsi bilities and insist upon proper methods and practices at all times. All employees are held accountable for fulfilling these requirements on the job. The achievement of maintaining and improving our safety and environmental performance will be visible evidence of performance in safety, health and environmental operations. As a means of maintaining and improving the overall safety program, specific procedures and policies have been prepared. These procedures have been established as the minimum acceptable practices to ensure the integrity of our safety and environmental processes. These practices will provide the basis for an on-going training program and will be expanded as needed. It is every employee's responsibility to ensure safety and environmental performance. Objectives: - To properly manage all unacceptable risks and to bring residual risks to a manageable level. To ensure company compliance with all applicable Federal, State and Local regulations. To provide an ongoin g and effective means of communication between management and the collective bargaining unit on safety and environmental related issues regarding present and future work processes. - To ensure effective and cost efficient policies and Standard Operating Procedures are well written and properly adhered to. - To support line management responsibility and enforcement of the safety and environmental programs with careful, reasonable and fair consideration. - To recognize the value of learning through experience and discussion of the investigation and follow-up of all mishaps, near misses, and injuries including careful development and implementation of required corrective actions. - To identify and discuss safety and environmental concerns, and to implement effective plans to remedy those concerns. 1.2 EMERGENCY RESPONSE POLICIES The purpose of the Emergency Response Programs are to minimize hazards to human health or the environment from fires, explosions, or any unplanned release s of hazardous waste or hazardous constituents to air, soil, or surface water. Guidelines have been established for the orderly handling and reporting of emergency situations occurring or foreseeable events developing at S-K(BP). 2.0 STATIONARY SOURCES AND REGULATED SUBSTANCES 2.1 The Incinerator and Associated Process Feeds into the Incinerator. The following processes are connected by piping to the Incinerator which is made up of the Kiln, Loddby & Afterburner: Phase I Tank Farm, Direct Burn Station, PDP Station, Glove Box and the Drum Pad. The Drum Pad is in close proximity of the Phase I Tank Farm and in the event of a major incident at the Drum Pad, it could have a severe impact on the Tank Farm and therefore is included as part of the incineration process. Incineration at the S-K(BP) facility is carried out primarily in a rotary kiln. The Kiln is a large cylinder made of steel and lined with heat resistant brick (refractory). The existing kiln, installed in 1988, is 3.6 met ers (12 feet) in diameter and approximately 22 feet in length. The Kiln typically operates at temperatures between 1600 deg. F and 2000 deg. F. Solid waste materials, which are generally received in containers such as steel drums, plastic drums, fiber (cardboard) drums and boxes can be placed directly into the kiln. These solid materials are fed into the Kiln via elevator and chute, which drops the materials into the front end of the Kiln. The Kiln rotates slowly, and is inclined to facilitate movement of material through the kiln. The waste moves from the drop area (front end) to the opposite end (discharge end). By the time the waste reaches the discharge end, all combustible components of the waste have been incinerated, and only ashes, unburnable materials and gases generated by the combustion process remain. The ash falls out of the discharge end of the Kiln, cooled via a water bath, and is collected in a bin. The bins are emptied into trucks, and the material is sent to a secure landfill for final disposal. Gases and particulate produced by the incineration process pass into the Afterburner section of the Incinerator. In addition to solid materials, sludge's, liquids and gases for incineration can be fed to the Kiln through a group of burners and lances located at the front end of the Kiln. The individual units that feed these wastes are described in the following sections. The Afterburner is a rectangular chamber attached to the Kiln. Like the Kiln, the Afterburner is lined with refractory. Gases produced by the burning of waste materials are swept into the Afterburner where they are subjected to temperatures between 2000 F and 2400 F. The Afterburner is designed to ensure that gases are subjected to these temperatures for at least two (2) seconds (residence time). The temperatures and residence time ensure that any unburned volatilized organic materials and particles created by the combustion in the Kiln are further combusted, if necessary. The Lod dby burner is a device attached to the Afterburner, which allows liquid and gaseous wastes to be injected directly into the Afterburner for incineration. The wastes processed through the Loddby burner are pumped from the storage/blending tanks (Phase I Tank Farm) and/or from Direct Burn Station (described below). Phase I Tank Farm: Many of the wastes treated at the S-K(BP) facility are received as liquids. Some of the liquids are received in small containers (i.e., drums) while others are received in tank trailers. Most liquids are pumped into one or more of the four tanks for storage prior to incineration. To ensure the safe storage of waste in tanks, all blending/storage tanks are blanketed with nitrogen to prevent an explosive atmosphere in the headspace of the tanks. In addition, all tanks are surrounded by concrete containment to contain leaks, and are equipped with high level alarms and automatic cut-offs to prevent overfilling. Emissions from the blending/storage tanks are ven ted to the incinerator for destruction when the incinerator is operating. Vapors are directed to carbon absorbers when the incinerator is not in operation. The Direct Burn Station allows for the incineration of liquid or gaseous wastes directly from tank trailers. A piping system connects the trailer on the Direct Burn Station to the Loddby or Kiln burners. A sump is built into this area to assure that any spilled or leaked wastes are contained within the area. Incompatible and highly reactive wastes are processed using the direct burn system to ensure they are handled safely, and remain segregated from other waste materials during storage and processing. The PDP Station is similar to the Direct Burn Station except that a positive displacement pump is utilized to transfer viscous substances to the Kiln for incineration. A sump is built into this area to assure that any spilled or leaked wastes are contained within the area. The container pump station, also known as a "Glove Box", is a small plexiglas enclosure located adjacent to the Kiln staging area. Pneumatically operated doorways are opened to allow the placement of containers inside of the enclosure. After the containers are positioned inside the enclosure, the doors are closed creating a seal, which prevents escape of vapors from the unit. A jet pump is utilized to draw a negative pressure (i.e., vacuum) on the enclosure. The pump discharges all vapors to the Afterburner for incineration instead of releasing them to the atmosphere. Operators access the inside of the enclosure using glove inserts attached to the wall of the enclosure. Observation windows are provided to allow the operator to remove the container top or bung or to open the valve on a gas cylinder to remove the contents. For liquid materials, the operator inserts a hose or wand into the container, and the contents are pumped to the Kiln for incineration. To process gases, the valve of a cylinder is connected to a separate line inside of the e nclosure and the gas is fed to the Kiln for incineration. The Drum Pad is utilized for storage, repackaging and vacuuming of containerized wastes. The pad is equipped with curbing and/or sumps designed to collect spilled or leaked waste materials, and prevent releases from breaching the storage area. The Incinerator and its' connected and/or associated processes handle the following regulated substance(s): - Acrylonitrile Isolated parts of the Incineration process also handle additional substances. These parts of the Incineration process include the Direct Burn Station and the Loddby & Afterburner. The following substances are unloaded from tank trailers at the Direct Burn Station and are fed into the Incinerator exclusively through the Loddby & Afterburner section of the Incinerator: - Hydrogen Fluoride (non aqueous) - Flammable Mixture containing the following regulated flammable substances: 2-Butene- cis; 1,3-Butadiene; and Vinyl Chloride 2.2 The E2 Pad is the only other area on the site where the regulated substances, at or above their specific regulatory thresholds, may be stored temporarily until they are moved to the incineration process. The E2 Pad handles the following regulated substances: - Acrylonitrile - Hydrogen Fluoride (non aqueous) - Flammable mixture containing the following regulated flammable substances: 2-Butene- cis; 1,3-Butadiene; and Vinyl Chloride 3.0 WORST CASE SCENARIOS & ALTERNATE CASE SCENARIOS 3.1 WORST CASE SCENARIOS (The EPA's RMP Offsite Consequence Guidance Analysis Document, which includes several equations and lookup tables, was used to calculate the endpoint distances). 3.1.1 Worst Case Scenario for Toxic Substances A catastrophic failure of acrylonitrile tank trailer resulting in the loss of the entire contents within 10 minutes. This Worst Case Scenario assumes a tanker with a maximum of 5,100 gallons of 100 percent acrylonitrile being released in an area without containment. The distance of the plume to its reg ulated endpoint was calculated to a distance of 5.8 miles. Safeguards and administrative controls to prevent or minimize this Worst Case Scenario include: 7 Continual camera monitoring of the processes/storage areas where this material would be stored and/or processed. 7 Containment dikes/sumps. 7 Grounding equipment and procedures during the transfer of or unloading of waste. 7 Tankers are unloaded with a nitrogen pad in place. 7 Tankers have the following safety devices: 7 Tankers have the following safety devices: - Safety relief/vacuum breaker devices. - Internal and external unloading valves. - Isolated shutoff valve located near the front of the trailers. - Maintenance & integrity testing: Annual pressure testing of the tankers; testing of relief valve/vacuum breakers, etc. 7 Nitrogen pressure safety devices: regulators, relief valves, and low pressure alarm. 7 Processes are heavily monitored, alarmed in some cases, interlocked to automatically shut down if a problem occurs using complex computer controls. 7 Quarterly pressure testing of hoses. 7 Venting devices are connected to the incinerator ensuring destruction. 7 Daily visual inspection of hoses and containment areas. Mitigation measures include: 7 Sprinkler protection in critical areas of the facility. 7 Fire water monitors to mitigate a fire or diffuse a vapor release. 7 Foam capability utilizing the fire water monitors or the site fire truck to utilize foam on a puddle of spilled liquid to minimize the vapor release. 7 Spill response equipment and supplies. 7 An Emergency Response Team on all shifts to respond to fires and/or chemical releases. The facility's process safety management program includes the following elements: 7 Profiling of waste to identify special hazards and/or handling procedures. 7 Process Hazard Analysis to identify and address potential hazards before they occur. 7 Risk Assessment to estimate and reduce the likelihood and impact of potential accident scenarios. 7 Pre-startup reviews on all equipment that has undergone a change in procedures or equipment. 7 Standard Operating Procedures that are kept current, used for training and are reviewed annually to ensure that they are accurate and being followed. 7 Management of Change procedures to ensure that all changes to equipment, procedures and chemicals are analyzed for potential hazards prior to implementation so that the hazards can be controlled. 7 Hot Work Permit procedure to ensure that hot work is controlled to minimize potential for fire and/or explosion. 7 Preventive Maintenance (PM)/Mechanical Integrity Program to inspect and test equipment to ensure mechanical integrity and prevent equipment failure. 7 Operator and Mechanic Training Programs to ensure that only qualified personnel operate and maintain hazardous chemical operations. 7 Contractor Safety Program to ensure that unsafe contractors are not permitted to work at this fa cility and to ensure that contractors are aware of the plant hazards and safety procedures; and are trained to safely perform their job. 7 Incident Investigation Program to identify the root causes of incidents and prevent recurrence. 7 Annual compliance audits to verify that procedures are being followed and to institute corrective actions if necessary. 3.1.2 Worst Case Scenario for Flammable Substances A catastrophic failure of a LPG (Liquid Pressurized Gas) tank trailer resulting in the loss of the entire contents within 10 minutes. This Worst Case Scenario assumes a tanker with a maximum of 5,100 gallons of 100 percent 2-butene-cis being released in an area without containment. The distance to 1 psi overpressure for vapor cloud explosion is 0.25 miles. Safeguards and administrative controls to prevent or minimize this Worst Case Scenario include: 7 Continual camera monitoring of the processes/storage areas where this material would be stored and/or processed. 7 Con tainment dikes/sumps. 7 Grounding equipment and procedures during the transfer of or unloading of waste. 7 Tankers are unloaded with a nitrogen pad in place. 7 Tankers have the following safety devices: - Safety relief/vacuum breaker devices. - Internal and external unloading valves. - Isolated shutoff valve located near the front of the trailers. - Maintenance & integrity testing: Annual pressure testing of the tankers; testing of relief valve/vacuum breakers, etc. 7 Nitrogen pressure safety devices: regulators, relief valves, and low pressure alarm. 7 Processes are heavily monitored, alarmed in some cases, interlocked to automatically shut down if a problem occurs using complex computer controls. 7 Quarterly pressure testing of hoses. 7 Venting devices are connected to the incinerator ensuring destruction. 7 Daily visual inspection of hoses and containment areas. Mitigation measures include: 7 Fire water monitors to mitigate a fire or diffuse a vapor r elease. 7 Foam capability utilizing the fire water monitors or the site fire truck to utilize foam on a puddle of spilled liquid to minimize the vapor release. 7 Spill response equipment and supplies. 7 An Emergency Response Team on all shifts to respond to fires and/or chemical releases. The facility's process safety management program includes the following elements: 7 Profiling of waste to identify special hazards and/or handling procedures. 7 Process Hazard Analysis to identify and address potential hazards before they occur. 7 Risk Assessment to estimate and reduce the likelihood and impact of potential accident scenarios. 7 Pre-startup reviews on all equipment that has undergone a change in procedures or equipment. 7 Standard Operating Procedures that are kept current, used for training and are reviewed annually to ensure that they are accurate and being followed. 7 Management of Change procedures to ensure that all changes to equipment, procedures and chemicals are analyzed for potential hazards prior to implementation so that the hazards can be controlled. 7 Hot Work Permit procedure to ensure that hot work is controlled to minimize potential for fire and/or explosion. 7 Preventive Maintenance (PM)/Mechanical Integrity Program to inspect and test equipment to ensure mechanical integrity and prevent equipment failure. 7 Operator and Mechanic Training Programs to ensure that only qualified persons operate and maintain hazardous chemical operations. 7 Contractor Safety Program to ensure that unsafe contractors are not permitted to work at this facility and to ensure that contractors are aware of the plant hazards and safety procedures; and are trained to safely perform their job. 7 Incident Investigation Program to identify the root causes of incidents and prevent recurrence. 7 Annual compliance audits to verify that procedures are being followed and to institute corrective actions if necessary. 3.2 ALTERNATE CASE SCENA RIOS (The EPA's RMP Offsite Consequence Guidance Analysis Document, which includes several equations and lookup tables, was used to calculate the endpoint distances). 3.2.1 Alternate Case Scenarios for Toxic Substances 3.2.1.1 Acrylonitrile The alternate release scenario for acrylonitrile is the release of the entire contents of a 55 gallon barrel drum (i.e., spill, puncture, etc.). The response to the spill includes using absorbent material that is estimated to be 50 percent effective in mitigating the air release of acrylonitrile. The spill is completely mitigated within 20 minutes. The distance of the plume to its regulated endpoint was calculated to a distance of 0.07 miles. In addition to the safeguards, administrative controls, mitigation and management processes identified in section 3.1.1 above, additional safeguards include: 7 Material handling training including certification to operate forklift trucks. 7 Material handling equipment (drum dollys, drum tippers, pallet mo vers, etc) 3.2.1.2 Hydrogen Fluoride The alternate release scenario for hydrogen fluoride is a < inch leak in the unloading hose of a tank trailer containing a maximum concentration of 10 percent hydrogen fluoride (HF). The duration of the release is 10 minutes, until a remote valve is used to shut off the flow. The distance from the source of the plume to its' endpoint is 0.81 miles. In addition to the safeguards, administrative controls, mitigation and management processes identified in section 3.1.1 above, additional safeguards include: 7 Designated hoses for unloading this waste are pressure tested before each use 7 Placards are placed around and on the tanker to highlight its' presence on site. Also during unloading operations, warning signs are placed at the main gate to alert all personnel travelling through the gate that HF is being unloaded. 7 A Safety Watch, in full turn out gear, is provided at all times when the Tank Farm Operator is connecting or disconnecting the unloading hose from the Tank Trailer. 7 Special Teflon gaskets are used for the hose connections and the dome gasket. 7 Specific training on the processing of HF waste at the Direct Burn Station which includes the safe operations, inspections, normal shut down, emergency shut down steps, hazard communication, emergency procedures, incident reporting, medical procedures for HF exposures; and other related tasks given to employees. 7 Additional mitigation capacities include adding calcium hydroxide (a neutralizer) to any contained spill or leak. This will neutralize the liquid which should then be vacuumed and processed as waste water. 3.2.2. ALTERNATE CASE SCENARIOS FOR FLAMMABLE SUBSTANCES 3.2.2.1 Flammable Mixture The alternate case scenario for the flammable mixture (contains three regulated flammables: 2-Butene-cis; 1,3-Butadiene and Vinyl Chloride) is a < inch leak in the unloading hose of a tank trailer. The duration of the release is 10 minutes, until a remote valve is used to shut off the flow. The distance to the from the source of the explosion to its' endpoint is less than 0.06 miles. Safeguards, administrative controls, mitigation measures and process safety management controls that would help prevent or minimize potential incidents with this substance are listed above in section 3.1.2. 4.0 GENERAL ACCIDENT RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS The general release prevention programs are listed above in section 3.0 Worst Case Scenarios & Alternate Case Scenarios under each specified scenario for each specific chemical. 5.0 FIVE-YEAR ACCIDENT HISTORY In the last five years, there have been no incidents at this facility that would be classified as a RMP incident. 6.0 EMERGENCY RESPONSE PROGRAM The facility has a comprehensive Emergency Response Plan that describes procedures to be taken in the event of an emergency including a release or spill. All Operators are trained annually in emergency pro cedures in their departments, including emergency shutdown. The plant maintains a specially trained Emergency Response Team for all shifts to respond to fires and/or chemical releases. There is one Emergency Medical Technician on each shift to provide immediate response to any injured person. Injuries and incidents beyond the facility's capability would require assistance from public emergency responders. All employees are basically trained in basic emergency recognition & actions, alarms, sheltering, headcount and evacuating procedures. Emergency Response drills are conducted annually to test the emergency response plan and identify areas for improvement. 7.0 FACILITY IMPROVEMENTS S-K(BP) will continue to evaluate the regulated processes under the New Jersey Toxic Catastrophe Prevention Act , the New Jersey Spill Compensation and Control Act, the Occupational Safety and Health Administration Process Safety Management Standard for Highly Hazardous Chemicals, and the Environmental Pr otection Agency Accidental Release Prevention Requirements Risk management Program to ensure the safe operation through Prevention Programs and Emergency Response Programs. S-K(BP) will continue to work with the community emergency management coordinator, local fire departments, community officials and the County Office of emergency Management to coordinate training, drills and information. |