Attleboro Refining Company, Inc. - Executive Summary |
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a. Attleboro Refining Company (ARC) accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. All applicable procedures of the USEPA Prevention Program are adhered to. ARC response policy involves the preparation of a facility specific response plan in compliance with EPA Emergency Response Program requirements. b. ARC handles chlorine in one ton cylinders as part of the Miler Chlorination process. The maximum amount of chlorine handled by the facility is two(2)-one ton cylinders. The facility is manned 24 hours per day. Additionally, ARC handles bulk 37.5% Hydrochloric Acid Solution. A 6,400 gallon tank is used for storage of 37.5% Hydrochloric Acid solution. The Hydrochloric Acid solution is used as a chemical reactant in the Aqua Regia metal dissolution process. c. The chlorine offsite consequence analysis includes consideration of two chlorine release scenarios, identified as "worst case release" and "alternative scenario". The first scenario is defined by EPA, which states that "the owner or operator shall assume that the ... maximum quantity in the largest vessel... os released as a gas over 10 minutes," due to an unspecified failure. The alternative scenario is defined as"more likely to occur than the worst-case release scenario". d. The ARC accidental release prevention program is based on the following key elements: + High level of operator training + Preventive maintenance program + State-of-the-art process/safety equipment + Accurate and effective operating procedures, written with the participation of the operators + Hazard review of equipment/procedures + Auditing/inspection program Chemical-specific prevention steps include availability of self-contained breathing apparatus (SCBA), worn by the operators during connection/disconnection of chlorine supply, awareness of the hazardous/toxic properties of chlorine, and presence of chlorine detectors. e. No accidental releases of chlorine have occurred at this facility in the past five years. f. The facility has an emergency response program, which has been coordinated (reviewed) by the City of Attleboro Fire Department, which is a member of the Local Emergency Response Planning Committee (LEPC). This program includes an emergency response decision tree and notification plan. Emergency response drills and drill evaluation are conducted every year; emergency operation and response procedures are also reviewed at that time. |