HVC Inc. - Executive Summary |
|
General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at HVC Inc. 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 Chemical Distribution. We have 5 regulated substances present at our facility. These substances include Ammonia (anhydrous), Chlorine, Ammonia (aqueous), Sulfur dioxide (anhydrous) and Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid]. In addition to the distribution, anhydrous ammonia is used for th e manufacture of ammoonium hydroxide, chlorine is for the manufacturing of bleach and sulfur dioxide is used in the treatment of wastewater on-site. . The maximum inventory of Ammonia (anhydrous) at our facility is 401000.00 lb. while Chlorine, Ammonia (aqueous), Sulfur dioxide (anhydrous) and Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] are present at our facility in quantities of 312000.00 lb., 75609.00 lb., 6000.00 lb. and 1400.00 lb. respectively. 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 2 and 3 toxic substances as a class involves a catastrophic release from a Chlorine railcar. In this scenario 180000 lb. of Chlorine 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 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. The above scenario is mandated by EPA's RMP regulation and is not a realistic portrayal of the worst case release. The alternative release scenario for Sulfur dioxide (anhydrous) involves a release from Sulfur dioxide storage. The scenario involves the release of 2000 lb. of . Sulfur dioxide 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 8.33 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 2.0 miles. The alternative release scenario for Chlorine involves a release from Chlorine transfer. The scenario involves the release of 2000 lb. of . Chlorine 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 0.12 minutes. The release is also assumed to be controlled by emergency shutdown system(s) and On-site response team. These active mitigation systems have the effect of minimizing the release and would likley reduce the amount released well below the amount used in the calculation of this alternative release scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 2.0 miles. The alternative release scenario for Ammonia (conc 20% or greater) involves a release from Anhydrous ammonia transfer. The scenario involves the release of 9639.41 lb. of . Aqua ammonia 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 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, having the effect of slowing the release of ammonia into the atmosphere and providing containment of the spill. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (conc 20% or greater) is 0.31 miles. The alternative release scenario for Ammonia (anhydrous) involves a release from Anhydrous ammonia transfer. The scenario involves the release of 1000 lb. of . Ammonia 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 0.41 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.19 miles. The alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or g reater) [Hydrofluoric acid] involves a release from Hydrofluoric acid storage. The scenario involves the release of 700 lb. of . 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 10 minutes. Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario, having the effect of reducing the release of vapor once the product is released and minimizing the total quantity released. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 0.06 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 HVC Inc. maintains a detailed record of safety information that describes the chemical hazards, operating 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 "what-if". 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 every three years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 01/29/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, HVC Inc. maintains written operating procedures. These procedures a ddress 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 HVC Inc. 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 two years and more frequently as needed. Mechanical Integrity HVC Inc. 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. Maintenance operations are carried out by qualified personnel with previous training in maintenance prac tices. 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 HVC Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 11/17/1998. 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 HVC Inc.. The most recent review was performed on 05/04/1999. 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 HVC Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 05/04/1999. 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 HVC Inc. 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 HVC Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident preve ntion 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. HVC Inc. 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 HVC Inc. has a very stringent internal spill release reporting process in order to ensure that any release of the regulated substances are reproted. This stringent reporting ensures that all releases are investigated an d actions necessary to prevent future releases are taken.. Due to our stringent release prevention policies, the number of accidental releases has been reduced to a minimum. There have been 13 accidental releases of regulated substances from our facility within the last 5 years. There were eleven chlorine releases, with the largest being 5 pounds. There were two releases of ammonium hydroxide, the largest being 140 pounds. None the above releases resulted in any off-site injuries or on-site lost workday injuries. 6. Emergency Response Plan HVC Inc. carries 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 serv iced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Butler 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 HVC Inc. is continously reviewing the processes for improvements that will reduce the risk of our operations to the community and our workforce. Additional gas monitoring alarms, improved on-site response equipment and additional employee training are a few of the improvements we expect to complete in the next year. |