Surpass Chemical Company, Inc. Bridge Street Plant - Executive Summary |
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1. Accidental release prevention and emergency response policies; At Surpass Chemical Company's Bridge Street facility we handle chlorine, which is considered hazardous by EPA. Chlorine at our facility is used to manufacture liquid sodium hypochlorite bleach and is consumed directly from the rail tank car. Hypochlorite bleach is well known as an easier to use and safer to handle form of chlorine. It is widely used for disinfecting municipal and private water supplies, for household laundry bleach and for many other commercial uses. The same germicidal and highly reactive properties that make chlorine, and other products made from it, so valuable as a commodity and important to public health, also make it necessary to observe certain safety precautions. Chlorine safety depends upon the safety devices inherent in the design of this facility, the safe handling procedures that we follow, and the training of our personnel. Safe handling of chlorine is necessary to prevent unnecessary huma n exposure, to reduce the threat to our own personal health as well as that of our co-workers, and to reduce the threat to nearby members of our community. It is our policy to handle chlorine safely and to adhere to all applicable Federal and state rules and regulations governing its handling and use. Our emergency response program is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities. The emergency response plan includes procedures for notification of the local fire authority and notification of any potentially affected neighbors. 2. The stationary source and regulated substances handled; The primary purpose of Surpass Chemical's Bridge Street facility is to manufacture, blend, package and distribute chemicals to water treatment facilities and general industry. The regulated substance handled at this manufacturing/distribution facility is chlorine. The maximum total inventory of chlorine stored at this plant is 360,000 pounds. Norma l inventory levels are 180,000 pounds or less. Chlorine is received on site in rail tank cars and is used as a raw material in the manufacture of liquid sodium hypochlorite bleach. This facility has equipment for the safe unloading of rail tank cars into the liquid sodium hypochlorite bleach process. 3. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distance for each reported scenario; Worst-Case Scenario - The EPA requires us to consider as a worst-case scenario the release of the entire contents of a full rail tank car containing 180,000 lbs of chlorine. It is assumed that the entire contents of a 90 ton rail tank car of chlorine is released as a liquid spill and vaporized into its heavier than air gaseous state, in a 10 minute time frame. The distance to the endpoint of 0.0087 mg/L (3 ppm) as determined by RM P* Comp. (software which is provided by EPA) would extend past the facility's boundary. We believe this scenario to be impossible unless caused by an outside influence beyond our control. Alternate Release Scenario - A rare but more logical release scenario as concluded from the many scenarios we considered in our what-if process hazard analysis, would be a crack in the threaded end of the 1" removable car connection pipe nipple. This would result in the release of 50 lbs of chlorine in a combination of its gaseous and liquid form. The distance to the endpoint of 0.0087 mg/L (3 ppm), using average annual wind conditions (winds out of the south at 10 mi/hr), has the potential to extend past the facility's boundary as determined by RMP* Comp. software. 4. The general accidental release program and the specific prevention steps; This distribution facility is covered by OSHA's Process Safety Management Regulations (PSM) and EPA's Accidental Release Prevention Rule (RMP) and complies with all applicable federal, state, and local codes and regulations. Access to the site is restricted to authorized employees, authorized management personnel and authorized contractors. The sodium Hypochlorite manufactured at this facility is an EPA registered pesticide under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and has UL Approval. This facility is operated in accordance with recommendations from the Chlorine Institute. 5. Five-year accident history This facility has not had an accidental release of chlorine in the past 5 years. 6. The emergency response program This facilities emergency response program is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities. We have discussed this program with the County Local Emergency Planning Committee (LEPC) and the City Fire Department. Representatives of the City of Albany Fire Department visited and observed a mock emergency response drill at this facility on May 28, 1998. 7. Planned changes to improve safety This facility was constructed in 1979 and is in compliance with Chlorine Institute guidelines. A newly developed automated chlorine rail tank car shut-off has been ordered and will be installed before the end of the year. We continue to participate in the Chlorine Institute programs, and continue to improve and operate our facility in accordance with the National Association of Chemical Distributors (NACD) Responsible Distribution Program (RDP) and the OSHA Process Safety Management (PSM) regulations. |