Henkel Surface Technologies, Warren - Executive Summary |
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1. Accidental release prevention and emergency response policies It is the policy of the facility to adhere to federal, state, and local rules and regulations. The facility engages its employees in ongoing training about their responsibilities in implementing compliance programs. The emergency response program is based upon Henkel's published policy statement that it will adhere to the codes of the Responsible Care initiative developed by the Chemical Manufacturers Association (CMA). Henkel Corporation is a member of the CMA. 2. The stationary source and regulated substance handled The Warren facility stores, blends and ships products containing inorganic acids. The products are used by industry for metal preparation, surface treatments, and the cleaning and treating of metal surfaces in the automobile, coil, general line and container industries as cleaners, conversion coaters and rinses.The facility stores hydrofluoric acid (70% aqueous) in a bulk tank. 3. The worst-case rel ease scenario and the alternative release scenario including administrative controls and mitigation measures The facility's worst-case scenario is the release of the contents of the tank when filled to the maximum allowed under written administrative controls (113,400 lbs of acid; approxiimately 11,180 gallons). The release would occur into a diked containment area with sump inside a building designed to hold the tank and associated release control measures.The dike and sump will limit the areal spread of an evaporating pool.The building will reduce the pool's emission rate by a factor of ten. The USEPA RMP rule does not allow us to consider the effect of our water deluge system when determining the distance to endpoint. According to USEPA "Guidance on the Application of Refined Dispersion Models for Hazardous/Toxic Air Release" and modeling performed using SLAB, a model developed by the Lawrence Liveromore National Laboratories under the auspices of the US Department of Energy, the distance to endpoint is on the facility property. The alternative release scenario is the release of the contents of a pipe exterior to the building (<5 gallons of acid; approximately <50 pounds). It would collect in a sump in a diked area (the truck well). The distance to endpoint is on the facility property. 4. The general accidental release prevention program and chemical-specific prevention steps The facility complies with the USEPA's accidental release prevention rule and with applicable state and local codes and regulations. The HF acid tank has been dewsigned, installed and maintained in compliance with ANSI standards and state and local law. Facility personnel have been trained in accordance with safe handling procedures developed by Allied Signal, the supplier of hydrofluoric acid (70% aqueous) to the facility. Handling of the material by by the facility does not occur until after the delivery truck has backed up to the loading dock, the transfer hose has been attached b y the delivery truck operators, inspection by the operators has occured, and the load has been accepted by the facility. Delivery truck operators are trained by the supplier. Transfer and pumping operations (loading tank and later transferring to mixing vessels) are attended at all times by facility personnel and follow a written standard operating procedure (SOP). 5. Five-year accident history We have not had an accident involving HF that caused deaths, injuries, property or environmental damage, evacuations or sheltering in place. 6. The emergency response program The facility's emergency response program is based upon Henkel Corporation guidelines consistent with Responsible Care? codes developed by the Chemical Manufacturers Association. In the event of an emergency involving the HF acid tank, it is our policy to notify the Waren Fire Depratment and request that they respond to the emergency. We have discussed this policy with the fire deprtment; the Fire Marshall has inspect ed our tank. 7. Planned changes to improve safety The facility trains its personnel on a regular basis. Safety training is modified based upon revised federal, state and local rules and regulations. The safety of plant systems is upgraded continuously as new equipment is installed. |