Pelron - Executive Summary |
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Executive Summary This Risk Management Plan (RMP) has been created to fulfill the requirements of the Clean Air Act (CAA) 112(r). Under 112(r), there are categories of facilities: Program 1, Program 2, and Program 3. These categories of facilities are based on the potential for offsite public exposure from a worst-case accidental release, accident history, and the facility compliance status under the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standards. The major components of this RMP include a Hazard Assessment, a Management Program, a Prevention Plan, and an Emergency Response Program. The Hazard Assessment includes a Worst Case Analysis, several Alternative Release Scenarios, and a 5-year Accident History. The Prevention Program consists of safety information, hazard reviews, operating procedures, training, maintenance procedures, incident investigations, and compliance audits. The Pelron Plant is located at 7847 West 47th Street in Chicago Illinois. The facility's operation involves the manufacturing of feed stock products for the urethane plastics industry. This includes the manufacturing and packaging of various custom feed stocks leaving the plant in 5 to 55-gallon containers. The manufacturing process utilizes raw chemicals primarily consisting of ethylene oxide, propylene oxide, formaldehyde, allyl alcohol and dimethylamine. Raw materials for the process are received via tank truck and tank car. Packaging materials are received by dray truck. Liquid raw materials are stored in tanks on the plant property both inside and outside. Packaged raw materials are stored on pallets in pallet racks until they are required in the manufacturing process. The products are manufactured in a batch process in reaction vessels of various sizes. Finished products are stored in the tanks within the warehouse or in the vessels until they are packaged. The finished products are packages a variety of styles and they are stored in the warehouse pallet racks until shipped to the various customers. Finished products are also loaded into bulk trucks and delivered to customers. The Pelron plant currently operates in compliance with Illinois State Air Permit. The Pelron Plant is also subject to Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II filing for toxic chemicals. The five chemicals stored at the Pelron Plant in quantities over the threshold values are Ethylene Oxide, Propylene Oxide, Formaldehyde, Allyl Alcohol and Dimethylamine. They are brought in as raw materials and are essential in the production of various products. These materials are received in bulk either via rail car or tanker truck. Each is added at various times during the process at various temperatures and pressures. Hazard Analysis Worst Case Scenario Toxic Gas The worst case scenario for the Pelron Plant has been determined to be an unloading or storage accident. Ethylene Oxide (EO) is delivered to the plant via r ail car. The EO is stored in a 10,000- gallon storage tank on site. The plant takes delivery of a 20,000-gallon rail car when the onsite storage tank has approximately 1500 gallons remaining. For modeling purposes, it is assumed that the railcar tank is somehow emptied such that that the entire quantity of EO is released. For worst case, it is assumed that the EO is released into the atmosphere in a ten minute time period. EPA's Degadis computer model was used to model the toxic endpoint. Assumptions in the model are: 1) Wind Speed = 1.5 m/s 2) Stability Class = F 3) Air Temperature = 77 degrees Fahrenheit Using the model, the toxic endpoint was estimated to occur at a distance of 4500 meters (2.80 miles) from the center of the facility. Estimated population in that radius is 124,345 people. The population was estimated using Environmental Data Resources, Inc. (EDR)'s Offsite Receptor Report. This report also helped locate environmental and public receptors in the area. Flammable Gas Dimethylamine is delivered to the plant via rail car. In this situation, it is assumed that the contents of the rail car is spilled resulting in a release of 180,000 pounds of dimethylamine in 10 minutes. The conditions are assumed to be: 1) Wind Speed = 1.5 m/s 2) Stability Class = F 3) Air Temperature = 77 degrees Fahrenheit The resulting 1 PSI overpressure is estimated to be a 0.40 mile from the plant. The estimated population within this area is 1445. Alternative Release Scenarios Ethylene Oxide An unloading accident was assumed for this scenario. In this situation, it is assumed that there is a break in a line from the rail car to the onsite storage tank. The EO is pumped at a rate of 50-60 gallons per minute and it was assumed that it would take 2 minutes for the transfer pumps to be turned off and the valves shut. No mitigation measures were used. Other assumptions in the release scenario are: 1) Wind Speed = 3.0 m/s 2) Stability Class = D 3) Air Temperature = 77 degrees Fahrenheit The toxic endpoint was estimated to occur at a distance of 0.3 miles from the center of the facility. Estimated population in that radius is 820. Propylene Oxide It was assumed that a valve or transfer hose malfunctions during unloading and 120 gallons of propylene oxide were released onto the ground. The release rate of the chemical is 60 gallons per minute. No mitigation measures were used. Other assumptions in the release scenario are: 1) Wind Speed = 3.0 m/s 2) Stability Class = D 3) Air Temperature = 77 degrees Fahrenheit The toxic endpoint was estimated to occur at a distance of 0.1 miles from the center of the facility. Estimated population in that radius is 90. Formaldehyde This alternate scenario is based on an actual release scenario. 7500 pounds of 37% formaldehyde had been placed in a reaction vessel for reacting. Another 7500 pounds of dimethylamine is placed in the reaction vessel. This reaction must b e cooled and in this accidental release situation, cooling did not accord due to a frozen water value on the tank. As a result, the pressure is exceeded in the reaction vessel and the pressure release value releases. The release rate of the chemical is 750 ponds per minute. No mitigation measures were used. Other assumptions in the release scenario are: 1) Wind Speed = 3.0 m/s 2) Stability Class = D 3) Air Temperature = 77 degrees Fahrenheit The toxic endpoint was estimated to occur at a distance of 0.1 miles from the center of the facility. Estimated population in that radius is 90. Allyl Alcohol Transfer rates from the truck to storage tanks are about 60 gallons per minute. Assuming a 2 minutes response time to a broken and 150 feet of line are lost in the spill, 1750 pounds of the chemical was assumed spilled. The release rate of the chemical is 350 pounds per minute with the entire event took place in 5 minutes. No mitigation measures were used. Other assumptio ns in the release scenario are: 1) Wind Speed = 3.0 m/s 2) Stability Class = D 3) Air Temperature = 77 degrees Fahrenheit The toxic endpoint was estimated to occur at a distance of 0.2 miles from the center of the facility. Estimated population in that radius is 360. D9imethylamine (Flammable gas) As with the formaldehyde, this alternate scenario is based on an actual release scenario. 7500 pounds of 37% formaldehyde had been placed in a reaction vessel for reacting. Another 7500 pounds of dimethylamine is placed in the reaction vessel. This reaction must be cooled and in this accidental release situation, cooling did not accord due to a frozen water value on the tank. As a result, the pressure inside the reaction vessel is exceeded resulting in the pressure release value releasing. The release rate of the chemical is 750 pounds per minute. No mitigation measures were used. Other assumptions in the release scenario are: 1) Wind Speed = 3.0 m/s 2) Stability Cla ss = D 3) Air Temperature = 77 degrees Fahrenheit The endpoint of 1 PSI overpressure was estimated to occur at a distance of 0.1 miles from the center of the facility. Estimated population in that radius is 90. The Pelron Plant has had an accidental release of dimethylamine and formaldehyde in the past five years. Two individuals at surrounding facilities appeared to have been affected and received medical treatment. |