USFilter Operating Services - Executive Summary |
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USFilter Executive Summary 1. Accidental Release Prevention and Emergency Response Policies At this USFilter facility we use Sulfur Dioxide, which is considered a toxic gas by the EPA. Safety of the community and employee is our first priority. We strictly follow all federal and state regulations including: the Occupational Safety and Health Administration's (OSHA) Process Safety Management (29 CFR 1910.119), Sara Title III, Emergency Action and Fire Prevention Plan (29 CFR 1910.38) and the Respirator Protection Plan. (29 CFR 1910.134) Through safety training, testing, response drills, procedure reviews, safety device checks and preventative maintenance, USFilter strives to provide the safest plant possible to both the community and the employees. Our Emergency Response Program includes mutual aid response with Occidental Chemical (OxyChem). All the USFilter operators and OxyChem's Emergency Response team are 40 hr Hazmat certified and participate in yearly response drills. Th e emergency response plan includes notification to OxyChem security, Wilmington Hazmat team and the Castle Hayne Fire Department. 2. The Facility and the Regulated Substance Handled At this USFilter facility, we purify Sodium Sulfate for Occidental Chemical. In the purification process, Sulfur Dioxide is used to reduce Hexavalent chrome to Trivalent chrome. The liquid Sulfur Dioxide is received by truck every 2-4 months, with a maximum on-site storage capacity of 83,000 lbs. The storage tank is located in its own building with dual gas detectors and an automatic ventilation system. The liquid SO2 is transferred to the SO2 evaporator, heated to a gas, and fed to the process via vacuum injection. 3. Worst Case and Alternative Release Scenarios Worst Case Scenarios - Complete failure of the full Sulfur Dioxide storage tank would result in the release of 83,000 lbs of Sulfur Dioxide gas. Using the EPA's RMP * Comp modeling program, the distance to toxic endpoint is 7.3 miles. Com plete tank failure is highly unlikely as the tank is protected with relief valves and a brick building. Also, as the liquid SO2 evaporates to a gas and escapes, the bulk liquid temperature drops, reducing the release rate to near zero before the tank is empty. Alternative case Scenarios - The alternate case assumes the tank is over filled. The 3" pressure relief valve opens for 10 minutes. Using the EPA's RMP * Comp modeling program, the distance to toxic endpoint is 0.3 miles and the quantity released is 3,480 lbs. While this release extends beyond the USFilter boundaries, there are no public receptors within the 0.3 mile radius. OxyChem and Martin Marietta are the property owners within the radius. The emergency response plan includes notifying both companies of a release. 4. The General Accidental Release Prevention Program and Chemical Specific Prevention Steps This plant falls under OSHA's Process Safety Management. Compliance with PSM includes: a comprehensive mechanic al integrity plan, initial hazop study, detailed procedures, procedure revision review and approval, Management of change, and training procedures, testing and documentation. Highlights of our Release Prevention program include: weekly safety equipment/interlock checks, daily process checks and documentation, rupture disc failure and alarms prior to any gas release, pressure relief valve testing and certification, UT thickness testing, yearly refresher testing and SCBA drills, pressure and levels available locally and remotely at the control room and pressure and temperature interlocks designed to minimize release. 5. Five Year Accident History Since start-up in June of 1997, this plant has not had an SO2 release. 6. Emergency Response Program (ERP) Our emergency response program includes the two USFilter operators donning sealed, chemical resistant (level B) suits with mutual aid back-up from OxyChem's Emergency Response Team. The ERP describes 6 typical emergencies, which ca n occur during loading or operation and a suggested response for each. Non-essential personnel from both OxyChem and USFilter are instructed to shelter-in-place. The USFilter control room includes an emergency HVAC shutdown switch. The USFilter lead operator notifies OxyChem security, Castle Hayne fire, Wilmington Hazmat (both via 911) and Martin Marietta of the emergency. OxyChem then sounds their emergency siren, instructing all personnel and visitors to report to their assigned zone for a head count. OxyChem's Emergency Response team and USFilter operators are 40 hr. Hazmat certified and participate in a typical drill once per year. The Castle Hayne Fire Dept. visited the sight in June of 1997. 7. Planned Changes to Improve Safety The plant was constructed in 1997 and was designed and constructed per the American Society of Mechanical Engineers (ASME), state and local codes. Two documented changes have been made to the process piping to improve safety. Refresher trainin g and Mutual Aid drills will continue. Strict adherence to the comprehensive mechanical integrity, operating procedure and safety checks will be maintained, insuring as safe a process as possible. |