Davis Pipe Inc. - Executive Summary |
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General Executive Summary Stainless Steel Pipe Pickling Davis Pipe Inc. Blountville, TN 1. Accidental Release Prevention and Emergency Response Policies We at Davis Pipe 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. The pickling process at Davis Pipe was constructed in 1989 to Resource Conservation and Recovery Act Design Standards for a Hazardous Waste Storage Area. The pickling area is completely secondarily contained to handle a total release of all the chemicals. A Hypalon liner with collection system provides tertiary containment. A 57,000 cfm scrubber system removes the acid gas fumes from the proce ss. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Fabrication of Stainless Steel Pipe and Tubing. We have 2 regulated substances present at our facility. These substances include Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] and Nitric acid. The acids are mixed with water to make a 7% hydrofluoric and 10% nitric pickling liquor. The maximum inventory of Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] at our facility is 8235.01 lb. while Nitric acid is present at our facility in a maximum quantity of 6589.30 lb.. The hydrofluoric exceeds the threshold quantity of 1000 pounds of greater than 50% concentration, due to up to 10 drums of 70% onsite at a time for makeup. The hydrofluoric acid could be ordered in less than 50% concentration and the plant not be regulated under 40 CFR 68. This causes a greater risk to employees due to more frequent addition of acid. 3. The Worst Case Release Scenari o(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario This EPA program only regulates hydrofluoric acid above 50% and nitric acid above 80%. Over 50% of the hydrofluoric acid onsite is in four pickling vats but it is at a concentration of 7%, which is exempt. To evaluate the worst case scenarios, we have used the EPA's OCA Guidance Reference Tables or Equations. For alternative release scenario analyses we have employed. The following paragraphs provide details of the chosen scenarios. Pickling Stainless Steel Pipe at Davis Pipe qualifies as a program level 1 process. In the worst case scenario for this process 3622 lb. of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is released. The acid is stored in a maximum of 10 drums. It is rare that all ten drums are present an one time. The drums are stored in a contained treatment building with a 57,000 cfm scrubber. The scrubber keeps the building below ambient temperature so a temperature of 800 F was used. 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. The worst case scenario has all 10 drums being ruptured. This is nearly impossible. The passive mitigation provided by the secondary containment of the building has been taken into account to calculate the scenario. The 57,000 cfm scrubber has not been taken into account in the scenario. These mitigation systems have the effect of containing the spill to allow for neutralization. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.19 miles is obtained corresponding to a toxic endpoint of 0.016 mg/L. This distance is less than the distance to the nearest public receptor (0.32 miles by USGS Topographic Map) An Alternate Scenario is not required for a Program 1 Facility. 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 Hazardous Waste Storage Area with Tertiary Containment. The system also has a continuous 57,000 cfm scrubber to remove any acid gasses. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Davis Pipe Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Operating Procedures For the purposes of safely conducting activities within our covered process, Davis Pipe Inc. maintains written operating procedures. These procedures address various modes of operation s uch as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, and normal shutdown. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Davis Pipe 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 year and more frequently as needed. The most recent training was January 28, 1999 Mechanical Integrity Davis Pipe Inc. carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; storage tanks, piping systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as nee ded. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Incident Investigation Davis Pipe 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 Davis Pipe 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 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. Davis Pipe 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 Davis Pipe Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Davis Pipe Inc. carries a written emergency response plan (Hazardous Waste Contingency Plan for New Pickling Building) to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response includi ng 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 plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Sullivan County Integrated Emergency Response Council is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. |