Safety Kleen (Baton Rouge), Inc. - Executive Summary |
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EXECUTIVE SUMMARY The accidental release prevention and emergency response policies at your facility: This facility complies with the stringent RCRA Part B permitting requirements for a hazardous waste treatment, storage, and disposal facility. Extensive onsite capability exists for emergency response, to include: fire brigade, spill response team, rescue team, and confined space rescue. If a release in excess of a reportable quantity were to occur, it is our policy to notify the National Response Center, the Louisiana Department of Environmental Quality, and a third party private service that ensures all other possible notifications are made. A description of your facility and the regulated substances handled. This facility is a commercial hazardous waste treatment, storage, and disposal facility. Typically, mixtures of hazardous wastes are received by tank truck or drum. They are then either blended with compatible other waste streams or temporarily stored until forwarded to ot her hazardous waste management facilities for further disposition. All waste steams are characterized and extreme care is taken to ensure compatibility among mixed wastes. In general, waste streams are quite dilute and do not normally exceed RMP management thresholds. However, to ensure no situation could occur when mixture components could result in triggering RMP thresholds, a review was conducted of the sites historical waste steam database. The chemicals with at least a potential to exceed RMP thresholds included chloroform and formaldehyde. Thionyl chloride was also included, not because of an RMP requirement, but because it is on the Louisiana listing of General Duty chemicals. In addition, hydrochloric acid, which is use in wastewater treatment, exceeds RMP thresholds and is part of the facility Risk Management Program. Although, Safety-Kleen evaluated the impact of thionyl chloride releases, it is not addressed further in this RMP specific submittal. The worst-case rele ase scenario and alternative release scenario. The worst-case scenario for formaldehyde and chloroform is a release of the highest possible concentration of each chemical in a waste mixture from one of the facility's largest aboveground waste storage tanks (i.e., 23,000 gallons). For formaldehyde the highest possible concentration is 25% and that for chloroform is 10%. This event is unlikely to ever occur and is presented here as required by the Risk Management Program regulations. The worst-case scenario assumes that the entire quantity of the 23,000-gallon tank is completely released over a period of 10 minutes, resulting in a gaseous release of either formaldehyde or chloroform. According to EPA's Offsite Consequence Analysis look-up tables, the distance to the toxic endpoint for formaldehyde is 0.43 miles and for chloroform is 0.31 miles. The facility is located in a mixed rural/industrial area and the formaldehyde release could affect approximately 1100 persons while the chl oroform could affect 550. For the wastewater treatment chemical (hydrochloric acid), the worst-case release is assumed to be the entire contents of the 6,500-gallon storage tank of 37% acid solution over a 10 minute period. The toxic endpoint for this release is 0.74 miles and approximately 2200 individuals could be affected. The alternative release scenario is a more realistic accident, and for the purposes of operations at the Safety-Kleen facility is considered to be the spilling of the entire contents of a 55-gallon drum of waste or hydrochloric acid solution. The toxic endpoints for formaldehyde, chloroform, and hydrochloric acid are respectively 0.19 miles, 0.10 miles, and 0.10 miles. The affected individuals are respectively 210, 20, and 28. The general accidental release prevention program and chemical-specific prevention steps. This facility complies with EPA's accident prevention rule, stringent hazardous waste management facility rules, and all applicable state and l ocal codes and regulations. Safety-Kleen is very proactive regarding safety. Contingency plans are in place to prevent accidents, as well as respond to accidents, should they occur. Safety-Kleen's safety and hazard prevention program include the following: 7 Risk Management Program 7 RCRA facility contingency Plan 7 Spill, Prevention, Control, and Countermeasures (SPCC) Plan 7 Hazard Communication 7 Lockout/Tagout 7 Confined Space Entry 7 Fall Protection To prepare for an emergency, plant operators have been trained in respiratory protection, emergency action, and fire prevention. The operators have many years of experience safely handling waste materials and wastewater treatment chemicals. They receive updated training regarding operations and safety on a regular basis. Five-year accident history. Within the past five years, the Safety-Kleen facility has had no accidents that caused deaths, injuries, property or environmental damage, evacuations, or sheltering in place. The e mergency response program. In the event of an emergency involving waste management or the use of hydrochloric acid, the significant onsite response capability will be activated. Included are the facility fire brigade and emergency response team. Given the limited potential for a large release, Safety-Kleen does not anticipate an emergency that could not be handled with its own assets. This ensures the most rapid possible response. Planned changes to improve safety. Safety-Kleen has continually sought to improve the safety of its operations. Currently, there are no specific projects to further reduce risks. The lack of accidents at the facility and the relatively short endpoints for conservatively identified worst-case scenarios are indicative of the lack of the potential for a significant release. |