Diaz Chemical Corporation - Executive Summary |
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General Executive Summary for Diaz Chemical Corporation 1. Accidental Release Prevention and Emergency Response Policies We at Diaz Chemical Corporation 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. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass organic chemical intermediates manufacturing. We have one regulated substance present at our facility. This substance is Bromine, which is reacted with aromatic raw materials (benzene, fluorobenzene, etc.). The maximum inventory of Bromine at our facility is 75000 lb. 3. The Worst Case Release Scenario(s) and the Al ternative 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 the EPA's RMP Comp. 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 bromine unloading. In this scenario 37000 lb. of Bromine is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 700 minutes. The release rate has been limited to 5% of the maximum rate of the source by a system of administrative controls. Passive mitigation systems such as an enclosure are also taken into account to calculate the scenario. These mitigation systems have the effect of reducing the release rate of the bromine, and also the total quantity released before other active response measures can be undertaken. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 4.5 miles is obtained corresponding to a toxic endpoint of 0.0065 mg/L. The alternative release scenario for Bromine involves a release from a bromine cylinder puncture. The scenario involves the release of 2500 lb. of bromine. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 800 minutes. Passive mitigation controls such as dike(s), drain(s), sumps(s) and enclosure(s) are taken into account to calculate the scenario, having the effect of reducing the amount of bromine available to evaporate (reducing liquid contact with the atmosphere). The release is also assumed to be controlled by sprinkler system(s), scrubber(s) and neutralization. These active mitigation systems have the effect of blanketing the liquid, forming a barrier, which prevents eva poration until the bromine can be neutralized. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0065 mg/L of Bromine is 0.2 miles. 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. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Diaz Chemical Corporation maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. The hazard information is communicated to the LEPC and local hospital. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The meth odology used to carry out these analyses is What If/Checklist (combined). 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. The most recent PHA for bromine, the only RMP substance at the facility, was performed in 1994. Operating Procedures For the purposes of safely conducting activities within our covered processes, Diaz Chemical Corporation 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 Diaz Chemical Corporation has a comprehensive training program in place to ensure that employ ees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years, as part of our PSM program, and more frequently as needed. Mechanical Integrity Diaz Chemical Corporation carries out 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 systems, 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 Diaz Chemical Corporation to manage changes in process chemicals, technology, equipment and procedu res. The most recent review/revision of management of change procedures was performed in August, 1997. 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 established processes are conducted as a regular practice at Diaz Chemical Corporation. The most recent review was performed in May, 1999. 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 Diaz Chemical Corporation conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted in May, 1998. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Diaz Chemical Corporation 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 five years. Employee Participation Diaz Chemical Corporation 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. Contrac tors 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. Diaz Chemical Corporation 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 Diaz Chemical Corporation has had an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there have been no accidental releases of regulated substances during this period. 6. Emergency Response Plan Diaz Chemical Corporation has developed a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency respons e 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 elements of the plan are tested on an annual basis by performing both table top, and actual emergency response drills. Orleans County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Refinement of truck unloading procedures, upgrading of bromine feed equipment, and improvements to our mechanical integrity program are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by the end of December, 1999. |