Hill Brothers Chemical Co. - City of Industry - Executive Summary |
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Hill Brothers Chemical Company (HBCC) developed this document to meet the requirements for a Program 3, Risk Management Plan (RMP) under the Accidental Release Prevention Program, Clean Air Act Amendments of 1990 for the following processes at its facility on 15017 Clark Ave., City of Industry, California: 7 Anhydrous Ammonia Repackaging, Storage and Distribution; and 7 Chlorine Cylinder Storage and Distribution. This RMP was prepared in accordance with the following Federal and State requirements: 7 US Environmental Protection Agency (USEPA) requirements in 40 Code of Federal Regulations (CFR) Part 68 7 OSHA Process Safety Management (PSM) requirements in 29 CFR 1910.119 7 California Accidental Release Prevention Program (CalARP) requirements in Title 19, California Code of Regulations (CCR), Division 2, Chapter 4.5. HBC prepared this RMP in conjunction with EMCON located in Irvine, California. HBCC closely coordinated the development of this document with the California Administe ring Agency (AA) for the City of Industry facility, the Los Angeles County Fire Department. On the basis of discussions with the AA, HBCC updated its December 1997 Risk Management and Prevention Program (RMPP) document to meet current RMP requirements. This RMP is submitted to both the AA and the USEPA, however, external events analyses related to seismic activity are only required by CalARP and are not submitted to the USEPA. Technical documentation for the off-site consequence analyses, seismic analyses and updates, the update of the Process Hazard Assessment, and required procedures and records are retained on file at HBCCs facility in City of Industry and corporate offices at 1675 North Main Street, Orange, California 92867. The City of Industry facility was founded in the mid-1950s as a distribution and repackaging center for chemicals. Anhydrous ammonia and chlorine are the regulated substances above Federal thresholds at this facility. Regulated substances above State t hresholds will be addressed in this RMP when written notice is received from the Administering Agency in California. HBCC Accidental Release Prevention & Emergency Response Policies HBCCs policy is to conduct all operations in a safe and conscientious manner to prevent accidental releases of any hazardous material, including substances regulated through the Federal Accidental Release Prevention Program and CalARP. HBCC trains is employees at this facility to properly handle and store hazardous materials to minimize the possibility of adversely affecting its worker's health, the workplace, the public, and the environment. HBCC's Accidental Release Prevention policy is implemented through the management system contained in its RMP. HBCCs emergency response policy is contained in its current written Hazardous Materials Business Plan. HBCC considers the City of Industry facility to be a "non-responding" facility under 40 CFR 68.90 and Section 2765.1 of CalARP. A designated Emerge ncy Coordinator (EC) and an alternate EC initiate emergency notifications and evacuations. All employees are trained in their appropriate role in emergency response and proper procedures for awareness level response. The City of Industry facility maintains a cooperative relationship with the Fire Department to ensure a full understanding of normal storage practices and emergency response and evacuation procedures related to regulated substances. The Fire Department, located within a 1/2 mile, is used for initial emergency response. HBCC contracts with a qualified hazardous materials management company for secondary response and proper disposition of hazardous materials and wastes generated during an incident. General Description of Stationary Source and Regulated Substances HBCC's City of Industry facility was established in the mid-1950's as a distribution and repackaging center for chemicals. The facility stores, repackages, and distributes anhydrous ammonia. The facility al so stores and distributes 150-pound chlorine cylinders to customers. Other chemicals stored or managed at the facility are outside of the scope of the Federal RMP program. The NAICS code for the anhydrous ammonia repackaging process is 325188 All other Basic Inorganic Chemical Manufacturing. The NAICS code for the chlorine warehouse process is 42269 Other Chemical and Allied Products Wholesalers. The site covers an area of approximately 180,000 square feet with two main warehouses, and office building and storage tanks in the yard. The facility is bounded on the south by Clark Avenue and day care and restaurant facilities, on the north by a Metrolink railway, and on the west and east by commercial and light industrial facilities. Anhydrous Ammonia Bulk shipments of anhydrous ammonia are off-loaded to a bulk storage tank from HBC-owned tank trucks or from supplier tank trucks. The anhydrous ammonia system is configured to fill individual cylinders of varying capacity (50 lb, 1 00 lb, and 150 lb) as dictated by customer needs. Additionally smaller tank vehicles are filled for transport to customer sites. Anhydrous ammonia is also used in the neutralization of plant wastewater before discharge to the city sewer. All uses of anhydrous ammonia on-site are at ambient temperature with system pressures varying accordingly. The presence of tanker trucks does not increase the amount of anhydrous on-site. The anhydrous ammonia process flow is presented in the Process Technology section of HBCC's Prevention Program. Anhydrous ammonia is an inorganic toxic gas, liquefied under pressure and stored at ambient temperature at the facility. It is a stable, colorless gas or liquid with an extremely pungent odor. It is a strong irritant to eyes, skin, mucous membranes, and the respiratory system. The National Fire Protection Association ranks the health hazards of ammonia as high. Anhydrous ammonia has a very high auto-ignition temperature and is difficult to ignite. Nonetheless, heat and ignition sources should be avoided. Chlorine HBC serves only as a distribution point for pre-packaged 150-lb chlorine cylinders. These cylinders are received at the northeast corner of the warehouse loading dock. Cylinders are restrained by chains and are stored outdoors beneath the warehouse canopy. They remain in storage for less than two weeks before being loaded onto trucks for delivery to customers. The chlorine is shipped in cylinders compliant with DOT requirements. Chlorine is a stable greenish-yellow gas or clear, amber colored liquid with a suffocating, pungent, irritating odor. The National Fire Protection Association ranks the health hazards of this substance as high. Chlorine is non-flammable but many metals ignite in the presence of chlorine. This substance should be stored away from heat and ignition sources. Off-Site Consequence Analyses Results HBCC assessed the quantity of regulated substances in the warehouse processes by review ing storage capacities, production information, and Tier 2 reports submitted annually under the Emergency Planning and Community Right-to-Know Act (EPCRA). Next, release scenarios were identified that reach a toxic endpoint off-site. An endpoint is a concentration of the regulated substance listed by the Federal government to establish population zones that would be vulnerable to impacts from an accidental release of the substance. HBCC used USEPAs RMP*Comp model as the method for determining distance to an endpoint and, in the worst-case scenario, for identifying which release from the facility would result in the greatest distance to a receptor. The model results in very conservative distances to endpoints. Worst-Case Release Scenario The worst-case release scenario uses the largest quantity of a regulated substance from a single vessel failure that results in the greatest distance to a toxic endpoint. As a result, HBCC selected a release of the anhydrous ammonia bulk storage tank as its worst-case, using the required default values for release duration, wind speed, and atmospheric stability class. Scenario: Anhydrous Ammonia (gas) release from bulk storage tank with no passive mitigation. Release time is 10 minutes to evacuate all tank contents. Urban topography was selected on the model. RMP*Comp calculates the distance to a toxic endpoint as 3.4 miles. Sensitive public receptors occur within this distance as noted in RMPSubmit and in the RMP Public Document. Alternative Release Scenario for Anhydrous Ammonia Alternative release scenarios are more credible scenarios that could result in a release affecting endpoints off-site. The alternative release scenario for chlorine was identified after conducting the Process Hazard Assessment (PHA) for this RMP. Scenario: A release of Anhydrous Ammonia results from a rupture of the 1/2-inch hose used to fill cylinders. No passive mitigation is in place but operators shut down manual valve within one minut e. Active mitigation is estimated to reduce the release rate by 25%. Urban topography was selected on the model. RMP*Comp computes the distance to the toxic endpoint as 0.2 miles. Sensitive public receptors occur within this distance as noted in RMPSubmit and in the RMP Public Document. As a result of the hose rupture, the cylinder may back flow vapor which would freeze and seal off valve. Estimated that a maximum of 10 pounds would be lost in addition to what comes out of the pipe for a release duration of one minute. Alternative Release Scenario for Chlorine Cylinders Scenario: The valve on a 150-pound chlorine cylinder does not seat properly and leaks while in storage at the warehouse. There is no passive mitigation available. HBCC personnel contact the Fire Department and its qualified hazardous materials management contractor upon discovery of any chlorine release. Facility personnel evacuate to a safe staging area upwind of the release. The Fire Department responds w ithin ten minutes, but a 30-minute release is assumed due to the precautions necessary to control the leaking cylinder. This release scenario affects no other cylinders. Urban topography is selected in the model. RMP*Comp standard wind speed and temperatures are applied. RMP*Comp calculates the distance to the toxic endpoint as <0.1 miles. Sensitive receptors occur within this distance as noted in RMPSubmit and as listed in the Public Document for this RMP. Summary of the General Accidental Release Prevention Program & Chemical Specific Prevention Steps HBCC's release prevention program complies with Federal ARP, CalARP and PSM requirements. HBCC's prevention program emphasizes risk management thorough use of equipment rated for ammonia service; training for its employees in hazard communication; proper operating procedures for the repackaging of anhydrous ammonia; level, pressure and temperature limits for process equipment and storage tanks; implementation of programs to mai ntain the mechanical integrity of equipment; internal auditing and inspection programs; procedures to address change within the parameters of this RMP; and awareness level emergency response. HBCC's standard operating procedures include routine observation of equipment condition during daily start-up procedures, production procedures, and daily shutdown procedures. Two trained operators are always present during bulk tank filling and off-loading to ensure the safe movement of trucks on the property and the integrity of hoses used for filling. HBCC operators are always present during repackaging operations to observe pressure and temperature gauges on tanks and pipes and to be alert for any releases of pressure relief valves installed on tanks or hydrostats on piping systems. In accordance with DOT requirements, valve assemblies on anhydrous ammonia cylinders are inspected upon each return for refilling. Faulty valves are rebuilt or replaced. The date stamped for hydrostatic t esting of cylinders is checked and each cylinder is repainted for corrosion protection before refilling. HBCC trains their operators carefully before allowing them to take the lead in repackaging operations. A key training method for process operations involves on-the-job supervision over extended time periods, using repeated demonstration of correct process steps in accordance with written procedures. HBCC's Operations Manager (and Emergency Coordinator) for the City of Industry facility has worked there for over 30 years and has substantial experience in dealing safely with anhydrous ammonia and chlorine cylinders. With respect to the chlorine cylinder warehouse process, HBCC's standard operating procedures include routine observation of container integrity during loading and unloading of these cylinders. For example, two people are always present during loading and unloading to ensure safe container handling using forklifts or hand trucks. Cylinders are stored upright, caps on , and strapped or chained in accordance with OSHA requirements for compressed gases. Cylinders are all DOT compliant and they are maintained during every refill by the supplier. Summary of 5-Year Accident History On the basis of a review with the HBC process hazard assessment team during preparation of this RMP, there have been no accidents or accidental releases involving the regulated substances in the last five years at the City of Industry facility. The facility has an excellent safety record. Summary of the Emergency Response Program HBCC's City of Industry facility has a written Hazardous Materials Business Plan (Emergency Response Plan). The plan will be tested through simulated spill/leak/fire emergency response situations at least 3 to 4 times per year. The plan designates an Emergency Coordinator (EC) and an alternate. All employees receive awareness-level emergency response training, first aid, and hazard communication training. HBCC's plan calls for its person nel be alert for releases and other emergencies, notify the Fire Department for response, and evacuate the facility. Anhydrous ammonia releases are detected through the human sense of smell. HBCC will immediately contact the Fire Department for response upon detecting a release. The EC, in conjunction with the Fire Department, will determine whether the release can be promptly and safely controlled and whether off-site populations will be affected. HBCC personnel are instructed to take only safe and reasonable steps to stop minor leaks from ammonia pipes or tanks at the facility. No such leaks have occurred in more than 6 years. Estimated response time is approximately 10 to 30 minutes from detection. Immediately after discovering a release of chlorine, HBCC personnel are instructed to notify the Fire Department for initial response and evacuate the facility to a safe staging location upwind of the release. UNDER NO CIRCUMSTANCES will HBCC personnel attempt to control a leaking chlorine cylinder. No chlorine releases have occurred at the facility In off-hours, HBCC's central alarm system sends a call to an off-site security company. The Security Company notifies both HBCC and/or the Fire Department that a release may have occurred. Estimated response time from the Fire Department is 10 minutes. Response time for HBCC personnel during off-hours is estimated to be 30 to 90 minutes. HBCC contracts with Premiere Chemical Management (1-888-429-8281) for secondary response and proper disposition of hazardous materials and wastes generated during an incident. HBCC will also coordinate with its suppliers regarding the circumstances of any incident involving a chlorine or ammonia cylinder. The facility is believed to be included in the written community emergency response plan and was noted as so in Section 9.1a of RMP*Submit, but this could not be verified by the local community. Planned Changes to Improve Safety HBCC has made a number of changes to impro ve safety at the City of Industry facility during this RMP process. The changes primarily include detailed reviews and updates of formal operating, maintenance, and emergency response procedures to address comments and recommended actions identified through the Process Hazard Assessment conducted for this RMP. Planned changes within the next year include: increasing formal coordination with the Los Angeles County Fire Department; completing emergency response training in accordance with the recently revised plan; improving overall training documentation; conducting quarterly drills to test the emergency response plan as it relates to anhydrous ammonia and chlorine; establishing a schedule for implementation of mechanical integrity testing for bulk storage tanks and piping systems; installing or tightening anchor bolts on anhydrous process equipment specified in the seismic analysis; addressing corrosion protection for equipment specified in the Public Document for this RMP. |