Trent Tube - Executive Summary |
|
1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: The Trent Tube, Carrollton, Georgia facility utilizes Hydrofluoric Acid, 70% by weight (HF), as a pickling agent for stainless steel tube. Trent Tube is committed to ensuring that HF is stored and handled in a safe manner. We have conducted hazard reviews of the process to ensure that the installation is in compliance with Federal, state and local codes, standards, and generally accepted good engineering practice. We have reviewed HF maintenance and operating procedures to enhance safety. Employees and contractors who are involved in storing and handling HF have been trained in safe storage and handling procedures. In case of an accidental release of HF, it is Trent Tube's policy to notify the City of Carrollton Emergency Services so that they can respond to the emergency. Trent Tube has procedures in place to notify the appropriate emergency services in case of an accidental release. 2. FACILITY DESCRIPT ION AND THE REGULATED SUBSTANCES HANDLED: The primary purpose of Trent Tube's Carrollton, Georgia facility is to manufacture stainless steel tube of varying diameters and lengths. Stainless steel sheet stock is formed, rolled and welded into tubing. In order to pickle the finished tube, lengths of tubing are dipped into a solution of HF (2%-5%), Nitric Acid and water. After pickling, the tubing is inspected, rinsed and bundled for shipping. There are two HF (70% by weight) storage tanks outside the building of 6,500 gallon and 5,000 gallon capacity. Both tanks are inside a containment dike that can hold entire contents of each tank. The RMP regulated substance at the Carrollton, Georgia facility is Hydrofluoric Acid (70% by weight). 3. THE WORST-CASE AND ALTERNATE RELEASE SCENARIOS: The Worst-Case Release Scenario for HF is mandated in the RMP rule (40 CFR 68.25) to be the instantaneous release of the entire contents of the largest single storage vessel, to form a liquid p ool. There is a containment dike that will contain the entire contents of the largest spill, therefore, evaporation occurs over the surface area of the containment dike. The Environmental Protection Agency's Off-site Consequence Analysis Guidance (OCAG), formulas and tables were used to determine a rate of evaporation of the spilled pool. The OCAG provided atmospheric, topographic and process parameters in order to estimate the distance that the evaporated pool of HF liquid would disperse to the surroundings. The dispersion distance specified by the RMP rule is the distance to the ERPG-2 (Emergency Response Planning Guideline -2). The ERPG-2 is a number estimated by the American Industrial Hygiene Association to be the concentration of HF that is believed nearly all individuals could be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair their ability to take protective action. The worst case ERPG- 2 distance was determined to be a circle, centered on the northwest HF storage tank (6,200 galloons capacity), with a radius of 0.80 miles. There are public receptors within this area. The second HF storage tank has a maximum capacity of 5,000 gallons, however, we have written administrative controls that limit the quantity stored in this tank to 4,500 gallons. The Worst-Case Release Scenario for this tank was calculated using the same methods as above, and produces an impact distance of 0.60 miles. Off-site impacts for this tank are identical to those above. The Alternate Release Scenario for HF is one that is more likely to occur than the Worst-Case Release Scenario. The distance to the endpoint (ERPG-2) is computed using more typical atmospheric conditions. A number of alternate release scenarios were considered. The scenario chosen for analysis was a failure of an HF transfer hose or fitting during the delivery of HF to a storage tank. There are two trained delivery person nel in attendance at all times during delivery. These persons are equipped with personal protective equipment and could reach critical shut off valves within 20 seconds time. HF would be spilled on the ground both from the storage tank and delivery truck. The distance to the ERPG-2 endpoint was computed using the OCAG and dispersion data supplied by Allied Signal. The distance was calculated to be a circle with a radius of 0.20 miles. There are public receptors within this distance. The ARS for the second, 5,000 gallon tank is identical to the ARS calculated above and includes the same off-site receptors. 4. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS: This facility is in compliance with the USEPA's Accidental Release Prevention Rule (40 CFR 68). The HF equipment was installed according to guidelines provided by the Hydrogen Fluoride Industry Practices Institute. HF delivery hoses are wire reinforced, inspected before and after each use and replaced annually. 5. THE FIVE YEAR ACCIDENT HISTORY The Trent Tube, Carrollton, Georgia site has not experienced a release of Hydrofluoric Acid in the last five years that caused deaths, injuries, property or environmental damage, evacuations, or sheltering in place. 6. THE EMERGENCY RESPONSE PROGRAM In the event of an emergency involving Hydrofluoric Acid, it is Trent Tube's policy to notify the City of Carrollton Fire Department and let them respond to the emergency. We have discussed this policy with the fire department. 7. PLANNED CHANGES TO IMPROVE SAFETY None at this time. |