DX SYSTEMS COMPANY - Executive Summary
Executive Summary |
1. Accidental Release Prevention and Emergency Response Policies
DX Systems Company (DXS) is strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to comply with all applicable federal, state, and local regulations as well as implement appropriate controls to prevent possible releases of regulated substances.
Our emergency response program includes procedures for notification of the local fire department; notification of any potentially affected neighbors; and notification of local, state and federal agencies. Safety is an essential part of our operations, the safety devices built-in to the design of this facility, the safe handling procedures that we use, and the extensive training of our pers
2. The Stationary Source and the Regulated Substances Handled
DXS is a 52-year-old company whose primary activities encompass distributing and repackaging inorganic chemicals and compressed gases as well as manufacturing water treatment products. For example, chlorine is used to produce sodium hypochlorite commonly know as household bleach. We are headquartered in Houston, Texas and operate more than 20 plants across the United States.
We have this regulated substance at our facility: Chlorine. DXS transfers this material from a railcar into a bulk transporter for use by our customers.
The maximum inventory of this substance at this facility is:
Chlorine - 214,000 lbs.
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To perform the required offsite consequence analysis for our facility, we have used EPA's RMP Guidance for Wastewater
Treatment Plants Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from Chlorine repackaging. The scenario involves releasing the entire contents of a railcar in a gaseous form over 10 minutes. This release would reach the toxic endpoint (0.0087 mg/l or 3 ppm) and public receptors.
One alternative release scenario has been submitted for each toxic substance present in Program 3 processes.
The alternative release scenario for Chlorine is the failure of a 1/2" hose on the filling station in the repackaging process. This would release material in a gaseous form over 15 minutes. It is assumed to be controlled by active mitigation measures that include emergency shutdown systems. This release would reach the toxic endpoint (0.0087 mg/l or 3 ppm) and public receptors.
4. The General Accidental Release
Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
DXS maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is the What if/Checklist (combined). The studies are undertaken by a
team of qualified personnel with expertise in engineering and process operations and are revalidated every 5 years as required or as necessary. Any findings related to the hazard analysis are addressed in a timely manner.
For the purposes of safely conducting activities within our covered processes, DXS maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, and normal shutdown. The information is regularly reviewed and is readily accessible to operators involved in the processes.
DXS has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed.
DXS carries out highly docume
nted maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified personnel carry out maintenance operations with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at DXS to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in est
ablished processes are conducted as a regular practice at DXS. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
DXS conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
DXS promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
DXS truly believes that process
safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. DXS has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-year Accident History
DXS has had an excellent record of preventing accidental releases over the
last 5 years. Due to our stringent release prevention policies, there have been no accidental releases during this period.
6. Emergency Response Plan
DXS carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.
The San Joaquin County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.
7. Planned Changes to Improve Safety
DXS continues to participate in the
Chlorine Institute, and continues to improve our operations.
8. Certification Statement
The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete.
Name: Wayne Penick
Title: Manager - Safety, Health, and Environmental Services Department
Date signed: ________________________________________________