J.H. Products, Inc. - Executive Summary
A. Accidental Release Prevention and Emergency Response Policies |
J.H. Products is committed to safety and the prevention of accidental releases of hazardous substances to the environment. The use of Chlorine in the manufacturing of Phosgene is operated and maintained in a safe and responsible manner. We have implemented release prevention programs and emergency response policies in order to preserve and protect the health of employees. These programs and policies also serve as protection of human health and the environment of the communities surrounding J.H. Products.
B. Stationary Source and Regulated Substances
Our Lockport facility uses chlorine (Cl2) to manufacture phosgene (COCl2), thus requiring regulation under the RMP Rule. Cl2 is purchased in 55-ton railroad cars and is combined with carbon monoxide (CO) in the process to make COCl2. The COCl2 produced is stored in 1-ton DOT-51 cylinders. Some Cl2 is also transferred directly to 1,600-lb DOT-51 cylinders. COCl2 and
Cl2 are the only toxic chemicals regulated under the RMP Rule by Part 68 that J.H. Products has on-site as part of a process. J.H. Products has no flammable substances regulated by Part 68.
C. Offsite Consequence Analysis Scenarios
It is a requirement of the RMP to model releases of our toxic substances as part of a hazard assessment. This hazard assessment must include one (1) worst-case release scenario and one (1) alternative release scenario for each substance involved in a process covered by the RMP Rule, regardless of the likeliness of the release.
The following brief summaries of each of these scenarios give the results of the modeling done using the EPA RMP Offsite Consequence Analysis Guidance, and further give passive and active mitigation techniques that are in place to limit the feasibility of such a release to occur.
As mentioned above, J.H. Products has two (2) toxic substances covered by the RMP Rule: COCl2 and Cl2
Worst-case Release Scenario - COCl2
t-case scenario for a release of phosgene is a complete failure of the 1-ton cylinder, therefore releasing 2,000 pounds in 10 minutes. The liquefied phosgene, at its vapor pressure and ambient temperature is assumed to immediately evaporate and be released to the atmosphere as a toxic gas. Passive mitigation is considered because the release would take place indoors. Therefore, we multiply the release rate by 0.55 to account for the enclosure. The scenario assumes rural conditions, F stability and a wind speed of 1.5 meters per second. The toxic endpoint of 0.00081mg COCl2 per liter of air reached a radius of 15.0 miles. Public receptors affected by this release are residences, several schools, two hospitals, the county jail, public parks, and numerous area businesses.
Worst-case Release Scenario -Cl2
The worst-case scenario for a release of chlorine is a complete failure of the 55-ton railroad car, thus releasing approximately 110,000 pounds of Cl2. The chlorine liquid is ass
umed to instantaneously evaporate and be released as a toxic gas. The release rate to the atmosphere was calculated to be 11,000 pounds per minute with no mitigation measures in place to limit the release. Assuming rural conditions, F stability data and a wind speed of 1.5 meters per second, the impacted radius from the site to chlorine's toxic endpoint of 0.0087 mg/L is greater than 25 miles. The public receptors located within this release radius include the majority of the City of Lockport and its surroundings including numerous residences, schools, hospitals, public parks and recreation areas, the county jail, businesses and major industrial sites.
Alternative Release Scenario - COCl2
The alternate case or more-likely scenario for a release of phosgene is valve failure on the cylinder that would allow a maximum possible release of 2,000 pounds in 1 hour. The properties of phosgene are the same as above, however the plug valve on the cylinder can only release the entire content
s of the cylinder in an hour as the maximum release. We further apply passive mitigation by multiplying the release rate by a factor of 0.55 because the release would occur inside the production building (enclosure). For the same toxic endpoint, the phosgene release will reach a radius of 9.3 miles, assuming rural conditions, F stability data and a wind speed of 1.5 meters per second. The public receptors located within this release radius include numerous residences, hospitals, schools, the county jail, pubic parks and recreation areas, businesses and major industrial sites.
Alternative Release Scenario - Cl2
The alternate case or more-likely scenario for a release of chlorine is a valve failure on the storage cylinder being filled directly from the railcar that would allow a maximum possible release of 1,600 pounds in 1 hour. The properties of chlorine are the same as above, however the plug valve on the cylinder can only release the entire contents of the cylinder in an hour a
s a maximum release rate. For the same toxic endpoint and taking into account the passive mitigation as above, the chlorine release will reach a radius of 2.7 miles. The public receptors located within this release radius include residences, parks and recreation areas, the county jail, some area businesses and major industrial sites.
D. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps
Our prevention program follows the standard set forth by the Occupational Safety and Health Administration's (OSHA) Process Safety Management under standard 29 CFR 1910.119, and takes a proactive approach to preventing accidental releases of regulated substances that pose a danger to human health and the environment. Our program includes the following steps and programs that lead to successful accident prevention:
- Process safety information
- Process hazard analysis
- Operating procedures
- Mechanical Integrity
- Management of change
- Compliance audits
- Incident investigation
- Employee participation
- Hot work permit
As part of our general prevention program, we have integrated chemical-specific prevention steps that help minimize the possibility of any leak of a hazardous substance that poses a potential danger both onsite and/or offsite. These steps greatly reduce risk:
Inspections - Regular inspections are performed on all process equipment to assure that the probability of failure is minimal. Through constant maintenance and careful monitoring of all operations and equipment, J.H. Products can prevent potential harm to employees and the surrounding environment by discovering an accident before it happens.
Personnel - J.H. Products maintains high standards for its employees in their ability to monitor and operate the onsite processes. Extensive training and experience in plant operations makes our employees our most important asset in maintaining safety onsite a
nd preventing accidents.
Technology - J.H. Products uses advanced technology in its processes to automate and control precise process conditions. Further, this technology also monitors deviations in these process conditions that include leaks or that could produce a leak. Any deviations that could potentially result in a release are immediately corrected if possible or otherwise shutdown. We also have a monitoring system that detects a release of either COCl2 or Cl2 in the process area, and sounds an alarm to alert employees.
Emergency Response - It is a vital part of Risk Management to minimize the effect that any release of a regulated substance could have on human health and the environment. We maintain an extensive response program for accidents onsite that pose a potential harm to employees and to offsite public receptors, including local residences. Our program keys in on stopping the release, getting the right people to the scene quickly, and notifying offsite public rece
ptors that could possibly be affected. This plan is coordinated with the Lockport Fire Department, Public Dispatch (911), and the Niagara County LEPC.
These steps all coincide to manage the use of hazardous substances and prevent releases. Our facility is committed to its programs that minimize the potential for any accidents and releases of a hazardous substance. We strive to improve safety onsite at all times and operate at or above our own high standards for safety.
E. Five-year Accident History
We are required by the RMP Rule to report all accidental chemical releases of regulated substances that meet or exceed the reportable quantity and keep them on-file as part of this Risk Management Plan. Further, we are required to keep on-file all accidental chemical releases that have occurred in the last 5 years.
As a result of J.H. Products' programs on safety and accidental release prevention, we have had no reportable releases in the past 5 years, as of June 20, 1994 involving s
ubstances covered under Part 68.
If such a release should ever occur, following the implementation of emergency response program procedures, a formal investigation will be conducted to identify and correct the cause(s) of the incident.
F. Emergency Response Program
In the event of an emergency situation, J.H. Products maintains a written emergency response plan to respond in an orderly, efficient and safe manner. Our emergency response plan provides key background, planning and training for the handling of and responding to releases of regulated substances. The plan also defines procedures for proper notification of off-site public receptors in an emergency situation. Procedures for notification of local authorities with which our plan is coordinated are also given in the plan. The main objective involved in the implementation of this plan is the protection of workers, the public and the environment during emergency situations.
G. Planned Changes to Improve Safety
s conducts Process Hazard Analyses (PHA's) that develop a list of suggestions for the improvement of process safety. These PHA's are performed every 5 years or when a process is changed, whichever comes first. The list of suggestions produced from the PHA is used to help improve safety for the employees, the pubic and the environment by reducing the risk of potential releases of regulated substances and emergency situations.