International Metals & Chemicals Group - Executive Summary |
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General Executive Summary for IMC Group Shelby, North Carolina 1. Accidental Release Prevention and Emergency Response Policies We at International Metals & Chemicals Group (IMC Group) are 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 implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with the Cleveland County LEPC and Emergency Response Department, which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled The facility manufactures materials for use in the electroplating industry. The facility casts copper and tin, cuts nickel and also formulates inorganic metallic salt solutions for the electroplating industry. The operations are located in Shelby, North Carolina and housed in a 160,000 square foot facility. We employ approximately 92 people and operate 24 hours a day five days a week. We have two regulated substances present at our facility used in the production of the inorganic metallic solutions. The first substance is chlorine and the second substance is hydrofluoric acid. The Chlorine process is a Program 3 process because it is covered under OSHA Process Safety Management rules. The maximum inventory of chlorine at our facility is 12,000 lb. The chlorine is stored in one-ton cylinders. Two cylinders are hooked up to the process and up to a maximum of four additional cylinders are on site at any time. The Hydrofluoric Acid (HF) process is a Program 2 process. The maximum inventory is comprised of four 55-gallon drums of 70% HF. Only one drum is used in the process at a time. The maximum quantity of HF is equal to 220 gallons. The HF component in 220-gallons of 70% HF has a weight of approximately 1580 pounds. The HF process is only done periodically. 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 off-site consequence analysis for our facility, we have used equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance and the model EPA Comp. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for the HF involve a rupture of one 55-gallon drum of HF spilling onto the floor of the facility. The release would occur within the facility since loading and transport of the HF is done inside the building. The scenario involves a release of 55-gallons of HF and in accordance with EPA guideli nes, forms a 1-cm liquid pool. No mitigation other than the spill occurring in the building is assumed. Under worst case weather conditions, the maximum distance of 0.2 miles is to the prescribed toxic endpoint of 0.016 mg/l. No residences or environmental receptors are located within this distance. The alternative release scenario for the HF involves a slow leak in the drum while the drum is in the diked containment area. EPA COMP was used to calculate the release rate for a 0.15 square inch hole in the drum under 36 inches of head. Mitigation modeled includes the dike, release in the building and neutralization using soda ash. The calculated distance to the prescribed toxic endpoint is less than 0.1 miles. The worst case scenario for the chlorine involves a rupture in a one-ton cylinder resulting in 2000 pounds release in 10 minutes. No mitigation is assumed. The distance to the prescribed toxic endpoint of 0.0087 mg/l is calculated as 3.0 miles. Use of EPA's Landview I I and the 1990 Census data indicates a residential population of 13,550 within this radius of the site. Additionally, a hospital, several schools and parks are located within this radius. The alternative release scenario involves leakage of a hose connection after connection a cylinder to the system. The leak would be detected within one minute due to standard loading procedures. Assuming a hole area of 0.05 square inches and 150 psi pressure yields a toxic radius of 0.2 miles. No mitigation is assumed and the release duration is conservatively modeled as 5 minutes since connections are checked immediately upon hook-up using ammonium hydroxide, which reacts with chlorine, as an indicator. No residences are located within this radius according to the 1990 Census data. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken the necessary steps to comply with the accidental release prevention requirements set forth under 40 CFR part 68 of the EPA. 4.1 Chlorine Process The Chlorine process at our facility is subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program in place at our Chlorine source. Process Safety Information IMC Group maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with the process. 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 a what-if analysis. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, IMC Group maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training IMC Group 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 year and more frequently as needed. Mechanical Integrity IMC Group carries out highly documented 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 syste ms, controls and pumps. Maintenance operations are carried out by qualified personnel 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 IMC Group 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-startup Reviews Pre-start up safety reviews related to new processes and to modifications in the established process are conducted as a regular practice at IMC Group. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits IMC Group 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. Incident Investigation IMC Group 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. Employee Participation IMC Group 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 emplo yees 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. Contractors 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. IMC Group 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. 4.2 HF Process The HF process is a Program 2 process. The following sections briefly describe the elements of the release prevention program in place at for our HF source. Process Safety Information IMC Group maintains a detailed record of safety information that describes the chemical hazards, operating parame ters and equipment designs associated with the process. Hazard Review Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. Checklists are used to guide the hazard review. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard review are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, IMC Group maintains written operating procedures. These procedures address various modes of operation and are used to train employees and contractors and are used as a reference for actions to take in normal and abnormal operating situations. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training IMC Group has a comprehensive tr aining 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 year and more frequently as needed. Maintenance IMC Group properly maintains each piece of equipment in the covered processes. The maintenance program includes; 1) procedures to guide workers safely in their maintenance tasks, 2) worker training in maintenance procedures, and 3) an inspection and testing program to identify equipment problems before equipment failure occurs. It should be noted that the equipment used in the HF process is generally disposable. Additionally, the HF process is conducted only sporadically for a short period of time and each piece of equipment used is checked prior to use in the process. Compliance Audits IMC Group conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are car ried 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. Incident Investigation IMC Group 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. 5. Five-year Accident History IMC Group has an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period from a covered process. 6. Emergency Response Plan IMC Group coordinates with the Cleveland County LEPC and Emergency Management to deal with accidental releases of hazardous materials. Additionally, IMC Group has an emergency response plan that outlines procedures to follow in the event of an accidental release. 7. Planned Changes to Improve Safety IMC Group is dedicated to safety. IMC Group is currently updating its preventative maintenance procedures for the facility and each covered process. 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: Signature: Title: Date signed: |