SpecialtyChem Products Corporation - Executive Summary |
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SpecialtyChem Products Corporation Risk Management Plan Executive Summary June 21, 1999 Accidental Release Prevention and Emergency Response Policies We at SpecialtyChem Products Corporation (SPC) are strongly committed to employee, public and environmental safety. This commitment is the basis of having a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with all processes at our facility. It is our policy to implement appropriate controls, both engineering and administrative, to prevent possible releases of not only regulated substances, but all potentially hazardous materials. If such a release were to occur, we are prepared to work closely with the local Emergency Response agencies such as the Fire Departments and LEPCs in providing trained emergency response personnel to control and mitigate the effects of the release. Facility Overview SpecialtyChem Products Corporation (SPC) is a custom manufacturer of a wide variety of fine organic chemicals with the end uses of our products many and varied. It offers a broad range of manufacturing flexibility for its customers and produces agricultural and pharmaceutical intermediates as well as materials for the paper, electronics and other industries. Sales are worldwide. SPC has 11,000 square feet of production area divided into three separate units. The first unit is designed to offer a wide range of manufacturing capability and can be modified quickly to suit customer needs. Part of this area houses the site's solids dryer systems. Six different types of dryers are available to allow the best choice for the customer's product. The second unit is a two-part building generally housing SPC's longer-term processes as well as thin film evaporator and product flaking operations. The two Risk Management Plan covered chemicals for this facility, hydrogen chloride and methyl chloride, are both handled in this building. The hydrogen chloride is used in the manufacture of a paper coating material while the methyl chloride is used in the production of a UV inhibitor. The third unit is a facility for small-volume campaigns and limited large-volume work. Although all the equipment has the same functions as the other two units, much of it is smaller in size. SPC's laboratory operations support production. The chemists who staff the Process Development Labs research the safest and most efficient means of producing various chemical products. The Quality Control Laboratory assures that products meet customer expectations. Worst Case Scenarios Hydrogen Chloride In SpecialtyChem's process using hydrogen chloride, the hydrogen chloride is used directly from the shipping container to avoid making multiple transfers. The shipping container is a Department Of Transportation (DOT) approved tube trailer containing multiple tubes, each containing about 3,500 pounds of hydrogen chloride with a total maximum of 21,500 pounds. In the worst case scenario, these tubes rupture under fire or catastrophic damage from such things as an aircraft crash, releasing all 21,500 pounds instantaneously (within 10 minutes) into the atmosphere under weather conditions stability class F. Based on the EPA tables this would extend downwind of the release about 5.7 miles potentially affecting a portion of the population within a circle of about 26,000 persons. The size and configuration of the Tube Trailer do not allow greater than 21,500 pounds in any one trailer. SPC's inventory control procedures limit the incoming trailers to arrive when there is less than = tube of hydrogen chloride on site. The full trailer is staged in a location where the same catastrophic event can not affect both trailers. The full trailers for charging are staged in a protected area of the plant adjacent to the building where the material will be charged. The staging area is barricaded to avoid inadvertent striking from material handling equipment. Methyl Chloride SpecialtyChem receives methyl chloride from bulk trucks, which are off loaded directly into our methyl chloride bulk tank system. Inventory control requires that less than 20,000 pounds remain in inventory before a shipment is received. The maximum load on a bulk truck of methyl chloride is 40,000 pounds resulting in a maximum on-site inventory of 60,000 pounds. The bulk tank is designed for pressure storage with extra thick walled construction and double weld seams. Due to the evaporative nature of this material, no dike or containment walls exist at this tank. The worst case scenario is the release of the contents of the full tank (60,000 pounds) over ten minutes. It would take a major catastrophic event such as an airplane crash on its approach to the local airport to cause that release. The tank is located in a protected area of the plant adjacent to the building it feeds. The material is charged from the bulk tank to a pressure rated "day tank" for each reaction. The contents of the day tank are then metered into the reaction at a controlled rate. This reduces the amount of material that could be potentially released in the event there were a problem with the feed rate or system to the reactor. A rupture disk which discharges through a re-seating pressure release valve to a containment tank protects the "day tank". Alternative Case Scenarios Hydrogen Chloride The hydrogen chloride is charged to the reactor vessel through an overhead line from the tube trailer. Only one tube is opened at a time and each tube is protected by an internal high flow shutoff a check valve. The overhead line is further protected by a needle valve at the beginning of the line and it's own high flow cut off check valve. The line has minimal flanges to reduce the possibility of flange gasket failure but these flanges have been determined to be the weakest link in the system. In the event of a gask et failure and the flow was small enough not to trip the high flow protection device it has been determined up to 81 pounds may be released over three hours creating a potential radius of effect of 0.07 miles. This extends off the plant boundaries into the Menominee River where fishing is a popular sport. To reduce the chance even further, the operating procedures require a visual inspection of the feed line every 30 minutes during the charging period of 4 to 6 hours per day. The warning properties of hydrogen chloride are evident at very low levels and the persons fishing would have substantial time to leave the area before hazardous levels are present. The full trailers for charging are staged in a protected area of the plant adjacent to the building where the material will be charged. The staging area is barricaded to avoid inadvertent striking from material handling equipment. Water is readily available to provide a water curtain in the event a leak is discovered reducing th e amount that may get off site. Methyl Chloride Methyl chloride is charged to the process through the use of a "day tank" or staging pressure vessel. This vessel holds enough material for one reaction. This reduces the amount of potential release in the event of an upset condition. The "day tank" is protected by a rupture disk and then a re-seating pressure release valve. The tank vents back to the bulk tank when filling. In the event the vent line were not completely open the day tank could overpressurize and rupture the burst disk. The pressure release valve would in turn open, relieve the pressure and then re-seat in about 3 seconds releasing about 25 pounds. The material would flow to the pressure containment tank and release the contents to the atmosphere through a controlled point. This would have a potential range of effect of 0.06 mile radius potentially affecting the public recreation area of the Menominee River where fishing is a popular sport. Administrative cont rols in the operating procedures are in place to minimize the potential for venting line plugging or reduction. General Accidental Release Prevention Program Due to the nature of constantly changing production capabilities of the custom chemical manufacturing business, a broad range of Federal, State and local regulations governs SPC. All the major OSHA regulations including Process Safety Management, Hazardous Waste Operations and Emergency Response, Right-To- Know are integral to our efforts to minimize the potential for any chemical incident, not just the "covered" chemicals. We also fall under the Environmental Protection Agency's standards for air, water and land protection by compliance with such regulations as the Clean Air Act, RCRA, TSCA and FIFRA to name a few. This site has an employee population of ~135 with a staff of five full time health, environmental and safety professionals to coordinate efforts in those areas. Detailed programs are in place to address the needs of process safety, employee safety, employee health, environmental protection, facility and equipment loss and downtime and much more. Key to the process safety efforts, covering both OSHA and EPA requirements and more, is our formal six part program conducted on all processes before any are begun. This program consists of: 1. Hazard Assessment Profiles (HAP) consisting of a detailed review of all chemical hazards specific to the process, 2. Development of Custom Chemical Checklists (CCC) which consists of a documented detailed review of the hazards compared with regulatory requirements, 3. Process Hazard Analysis (PHA) usually consisting of a 'What If' method of analysis, 4. Thorough training programs for all operators and maintenance personnel on the operation of the process, it's hazards and methods of minimizing the potential for upset conditions, 5. Pre Start-Up Walk Throughs to be sure all is in order before any chemicals are introduced to the process During this process, efforts are made to minimize inventory requirements, minimize waste generated, maximize product conversion efficiency and enhance employee and environmental safety. Engineering controls are integral to the operation and are enhanced where ever economically feasible and provides a direct benefit to the efficiency or safety of the operation. Departments consisting of full time Process Engineers and Process Development Chemists oversee all processes to ensure safe operations. 5 Year Accident History There have been no reportable incidents over the last 5 years but there were two incidents each of less than one pound noted. The first was bad valve packing on the hydrogen chloride tube trailer. When the tube valve was opened a wisp if hydrogen chloride vapor was noted and the valve quickly shut off and the tube marked out of service. The other event also involved hydrogen chloride when a wisp was noted coming from a pinhole leak in the charge line. The line had just been monitored so the event was known to be less than 5 minutes. Based on the diameter of the pinhole it was determined less than 0.1 pound was released. Emergency Response Program SPC is located on the border of two states and as such believes we have a responsibility to both to ensure their safety from upset conditions should they occur at our operations. We are active members of both states' (Counties) Local Emergency Planning Committees. We also work closely with the two Fire Departments both for training as well as drilling purposes. The City and County have detailed emergency notification systems and our internal Contingency Plan clearly outlines our means of communicating with these organizations. We have both a detailed Contingency Plan detailing our response mechanisms for any type of situation and an Off-Site Plan filed with the State detailing our capabilities for off site assistance. An on-site spill response team is trained and equipped to handle most spills or releases requiring up to level B protection. The City Fire Department serves as a back-up with their Level B response Team. Tours and training are frequent with the local Emergency Responders. Planned Changes to Improve Safety SPC is constantly evolving new and better ways to enhance our safety programs. We are currently undergoing a large project of behavioral safety management with the development and implementation of a detailed Structured Safety Program approach to safety and health. This program is extremely detailed and because it is behavior based will take up to 18 months to fully integrate into our business culture. New techniques are also being introduced in how we conduct our process hazard analyses to be sure we do not miss any small aspect that may cause a potential problem. Safety, whether employee safety, environmental safety or process safety is integral to the way SpecialtyChem Products does business. There is no other way. |