Sloss Industries Corporation, Ariton Facility - Executive Summary

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Sloss Industries Corporation, Ariton Facility 
RMP Executive Summary 
June 9, 1999 
 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Sloss Industries Corporation, Ariton Facility 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 Specialty Chemical Production.  We have 1 regulated substances present at our facility.  This substance is Sulfur trioxide.  Sulfur trioxide is used for STB and KSS production.  Both processes share a common storage tank of Sulfur trioxide. 
 
The maximum inventory of Sulfur  
trioxide at our facility is approximately 45,000 pounds. 
 
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 the EPA's OCA Guidance 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 the Sulfur trioxide storage tank.  In this scenario approximately 45,000 pounds of Sulfur trioxide is released.  The liquid released is assumed to form a 1-cm deep pool from which evaporation takes place.  The entire pool is estimated to evaporate over 2429.56 minutes with no active mitigation efforts by Sloss.  Passive mitigation systems such as the building our storage tank is enclosed in are taken into account to calculat 
e the scenario.  These mitigation systems have the effect of minimizing the release rate from the pool of liquid.  At Class F atmospheric stability and 1.5 m/s windspeed, the maximum impact distance predicted by EPA's models is  2.2 miles.  This corresponds to an exposure endpoint of 0.010 mg/L.  In case of an accidental release, wind direction at the time will determine the travel direction of any vapor material. 
 
The alternative release scenario for Sulfur trioxide involves a release from a transfer hose.  The scenario involves the release of approximately 45 pounds.  Again, the liquid released is assumed to form a 1-cm deep pool from which evaporation takes place.  The entire pool is estimated to have evaporated after 36.28 minutes.  Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, it has the effect of controlling the pool size and reducing the evaporation rate.  The release is also assumed to be controlled by neutralization and an emerge 
ncy shutdown system.  These active mitigation systems have the effect of reducing the time for the material to evaporate thereby minimizing impact.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.010 mg/L of Sulfur trioxide is 0.09 miles.  Wind direction at the time will control drift of any vapor released from the site. 
 
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.  This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition.  The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
 
Process Safety Information 
Sloss Industries Corporation, Ariton Facility maintains a detailed record of safety information that describes the chemical hazards, operatin 
g 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 a "What If" scenario.  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 annually.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update was performed on 03/01/1999. 
 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Sloss Industries Corporation, Ariton Facility 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 turna 
round.  The information is regularly reviewed and is readily accessible to operators involved in the processes. 
 
Training 
Sloss Industries Corporation, Ariton Facility 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 
Sloss Industries Corporation, Ariton Facility 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 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 Sloss Industries Corporation, Ariton Facility to manage changes in process chemicals, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 05/10/1999.  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 Sloss Industries Corporation, Ariton Facility.  The most recent review was performed on May 10, 1999 for existing processes.  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 
Sloss Industries Corporation, Ariton Facility will conduct 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 during June 1999 while this plan was written.  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 
Sloss Industries Corporation, Ariton Facility 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 
Sloss Industries Corporation, Ariton Facility truly believes that process safety management and accide 
nt 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. 
 
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.  Sloss Industries Corporation, Ariton Facility 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 
Sloss Industries Corporation, Ariton Facility has had an ex 
cellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, only one accidental release has occurred during this period.  This release took place on 08/05/1998 and involved less than 20 pounds of Sulfur trioxide.  No deaths or injuries occurred offsite because of this accident.  There was no damage to property offsite.  Onsite, there were no deaths or injuries.  There was no onsite property damage.   
 
6.    Emergency Response Plan 
Sloss Industries Corporation, Ariton Facility has 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 p 
lan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 
 
Dale 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 
Our most recent PHA did not identify any areas of the process, which need corrective actions.  We continually strive to improve our work place and neighborhood.  As necessary changes become evident, w will strive to complete them in a safe, efficient, and timely manner.
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