Hydrite Chemical Co. - Oshkosh - Executive Summary |
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Hydrite Chemical Co. operates as a distributor and manufacturer of inorganic chemicals used in a variety of industries from food processing to waste water treatment. We at Hydrite Chemical are strongly committed to employee and public safety and environmental responsibility. It is our policy to control our processes to prevent the accidental release of harmful or noxious materials that could endanger or irritate our employees, plant visitors, or neighbors. This commitment is integrated into our design standards, equipment installation and maintenance practices, operating procedures and training programs. Hydrite Chemical has developed and trained written emergency response procedures in the event of an accidental release from any of our processes. These written plans have been provided to the local emergency response agencies including local emergency response personnel, hospitals, state and federal agencies. Hydrite uses four chemicals regulated by the Occupational Safety and He alth Administration (OSHA), Process Safety Management Program and the Environmental Protection Agency Risk Management Program. These chemicals are Sulfur Dioxide, Anhydrous Ammonia, Aqueous Ammonia, and Chlorine. The on-site storage capacity is 170,000 pounds of Sulfur Dioxide bulk and 66,000 pounds Sulfur Dioxide in the warehouse; 160,000 pounds of Anhydrous Ammonia bulk; 400,000 Aqueous Ammonia bulk and 230,000 Aqueous Ammonia in the warehouse; 360,000 pounds of Chlorine in bulk interconnected rail cars and 590,000 pounds of Chlorine in the warehouse. Sulfur Dioxide, Anhydrous Ammonia, and Chlorine are stored as a liquid under pressure. Aqueous Ammonia is stored as a liquid. Regulated materials are received from various suppliers and stored in containers including drums, tote tanks, tank trucks, rail car, bulk storage tanks and compressed gas cylinders. These containers meet DOT specifications. All storage and ancillary equipment is designed to comply with National Standards i ncluding the American Society of Mechanical Engineers (ASME), the Fertilizer Institute, National Fire Protection Association (NFPA), Chlorine Institute, and OSHA. Hydrite Chemical has multiple release prevention programs integrated into all phases of operation from design through maintenance. Each chemical is reviewed for physical hazards, health hazards, environmental hazards and process hazards. All processes are subject to the OSHA PSM program and as such, undergo a Process Hazard Analysis (PHA). Written operating procedures have been developed and are reviewed on a regular basis. Employee training procedures have been developed and are implemented ensuring the employees understand the hazards of the chemical, know how to operate the equipment, know how to shut down the process and how to respond to a release. Pre-start up safety reviews are performed prior to operation of new equipment or receipt of new chemicals. Equipment maintenance procedures have been developed and impl emented, including routine inspections and scheduled maintenance. Hydrite Chemical believes that every incident has the potential for serious impact and conducts Incident Investigations to determine root cause and corrective action for all releases. A review of the previous five year accident history indicates two releases of regulated materials that impacted the community. Worst case scenario for each regulated substance is based on the total loss of the maximum quantity stored in each vessel. Release is assumed to occur over a 10 minute period with weather conditions as defined by EPA in the Offsite Consequence Analysis Guidance. Hydrite has elected to use the ALOHA modeling package to keep our scenarios comparable with the local emergency response providers. A limitation built into the ALOHA modeling package truncates all releases at a maximum impact zone of 6 miles, so the worst case scenario was modeled using RMP*Comp. The worst case scenario for Chlorine has the greatest impact zone and does have off-site impacts. Alternate release scenarios are based on events that can reasonably be expected to occur. The Chlorine and Sulfur Dioxide in the warehouse are stored in compressed gas cylinders which each contain 2000 pounds. To mitigate the consequences of a release during a fire, the cylinders have fusible plugs. The alternate scenario used is the failure of a fuseable plug allowing the material to release unitl emergency response can be completed. The alternate scenarios for bulk Chlorine and bulk Sulfur Dioxide assume a failure in the piping system, allowing the material in the line to be released. Both systems have excess flow valves which are considered in mitigating the release quantity. Aqueous Ammonia assumes a relief valve failure which would release 100 pounds of ammonia vapor. All scenarios consider emergency response as a mitigating factor, with a response time of 15 minutes. Weather conditions used were as specified in the EPA Offsit e Consequence Analysis Guidance. Modeling was conducted using ALOHA for the Sulfur Dioxide, Anhydrous Ammonia and Chlorine. The Aqueous Ammonia scenario was modeled using ALOHA, using ammonia gas release. All alternate scenarios have off-site impacts. Hydrite Chemical has developed and maintains an Emergency Response Plan (Contingency Plan). This Plan is integrated into the Local Emergency Planning Committees' (LEPC's) county wide plan. The Plan is reviewed and updated as required. Emergency Responders receive formal training on the Plan annually. The Plan includes: 7 Actions facility personnel must take in the event of fire, explosion or release 7 Arrangements with the local and state governments in the event of an accident 7 Names, addresses and telephone numbers of all emergency responders 7 Necessary emergency equipment and how it is to be implemented 7 Resources available at the plant for use in responding such as chemical resistant suits, self-contained breathing apparatus, two way radios for communication, gas monitors, and repair kits for leaking cylinders and tanks. Hydrite Chemical is strongly committed to employee and public safety and environmental responsibility and continually works to improve processes or procedures that advance our goal of zero releases. |