General Chemical Corporation - Executive Summary

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Executive Summary 
This Risk Management Plan (RMP) is submitted by General Chemical Corporation's Richmond Works in compliance with the requirements of section 112(r)(7) of the Clean Air Act (CAA) and was prepared in accordance with United States Environmental Protection Agency (USEPA) regulations contained in 40 CFR Part 68, Accidental Release Prevention Provisions. 
The Accidental Release Prevention program requires the owner of a stationary source having listed substances present in quantities greater than the corresponding threshold quantities to develop and implement a risk management program. The program must consist of a hazard assessment, a release prevention program and an emergency response program.  Additionally, the operator must describe the site's risk management program in a risk management plan (RMP). However, the regulation provides for 3 different programs of compliance dependent upon the eligibility criteria of covered processes including, but not limited to, the po 
tential impact of chemical releases as identified in the hazard assessment.  For example, chemical processes which meet the criteria for program level 1 and program level 2 have very minimal requirements for release prevention programs and emergency response as compared to those for program level 3.   
At General Chemical's Richmond Works, one listed chemical, Oleum, is managed on-site in quantities greater than the threshold quantity under the program level 3 criteria. No chemicals are managed on-site under program level 1 or program level 2 criteria. As identified in this plan, Richmond Works is in compliance with the requirements of 40 CFR Part 68 for management of Oleum. 
This RMP describes Richmond Work's risk management program which includes a hazard assessment, release prevention program and emergency response program. The hazard assessment includes one worst case release scenario and one alternative case release scenario. The hazard assessment was conducted in accordance with  
40 CFR Part 68, Subpart B (68.20-68.42), as well as the USEPA's Off-site Consequence Analysis Guidance Document.  The release prevention and emergency response programs at this site were developed based on requirements of the CAA's Accidental Release Prevention Provisions and the California Accidental Release Prevention Regulations.  
This RMP was prepared in accordance with 40 CFR Part 68, Subpart G (68.150-68.190), which provides a format for a written RMP.  The required elements of an RMP, as defined by the USEPA, are listed below along with the section in which they are located in this RMP.  All information identified in the attached registration form is current as of April 30, 1999. 
* Section 1.0 - Accidental Release Prevention and Emergency Response Policies 
* Section 2.0 - Description of Stationary Source and Regulated Substances  
* Section 3.0 - Hazard Assessment 
* Section 4.0 - General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
* Section  
5.0 - Five Year Accident History 
* Section 6.0 - Emergency Response Program  
* Section 7.0 - Planned Changes to Improve Safety 
1.0    Accidental Release Prevention and Emergency Response Policies 
General Chemical Corporation recognizes that the responsible management of health, safety and the environment in and around its facilities is one of its highest corporate priorities and a key element in its successful business strategy. General Chemical Corporation is committed to implementing policies and procedures which ensure that its operations are conducted in compliance with applicable laws and regulations.  Achieving responsible health, safety and environmental management will be accomplished by: operating our facilities safely and prudently; efficiently using energy and materials; seeking ways to minimize or reuse wastes; and otherwise complying fully with all applicable local, state, and federal laws and regulations.  Our policy is to implement reasonable controls to prevent and/or mi 
tigate foreseeable releases of regulated substances. However, if a release does occur, Richmond Works has prepared employees in conjunction with local emergency response groups, to respond to a release. 
2.0 Description of Stationary Source and Regulated Substances  
General Chemical's Richmond Works produces Sulfuric Acid and Electronic Grade Sulfuric Acid. Oleum is produced as an intermediate chemical in a state-of-the-art facility that was installed in 1997.  As one of the most advanced plants of its kind, it produces ultra-high-purity Electronic Grade Sulfuric Acid having overall ionic contaminant levels of less than 400 parts per trillion.  Sulfuric Acid and Electronic Grade Sulfuric Acid are used in many applications including pharmaceuticals, batteries, and plastics.  A major use of the acid produced at this facility is in the production of gasoline at a neighboring refinery.  The maximum quantity of Oleum on-site is 72,000 pounds. 
3.0    Hazard Assessment 
USEPA's Accidental Rele 
ase Prevention Provisions require that General Chemical provide information about the worst case release scenario and alternative case release scenario for Oleum handled at its Richmond Works.  The following are brief summaries of these scenarios. 
3.1    Worst Case Release Scenario 
The worst case release scenario as defined by the USEPA is a hypothetical accident for one of the chemicals at a site.  It assumes that all safety systems in the facility simultaneously fail and that all of the chemical in the largest container holding it at a site is released in a very short time. USEPA designated table defines the distance the material will travel until it disperses so much that it is no longer hazardous.   
The worst case release scenario at General Chemical's Richmond Works assumes that a process vessel containing Oleum fails. The USEPA requires us to assume that all safety and release prevention systems simultaneously fail, except for the secondary containment currently installed around  
the Oleum process vessel, and the contents are released in 10 minutes.  The USEPA designated table states that the material released would travel 4.0 miles before it reaches a non-hazardous concentration.  
3.2    Alternative Case Release Scenario 
The alternative case release scenario is a more credible hypothetical, site-specific chemical release. It takes into account safety and release prevention systems and procedures used at the plant to control releases. It is more realistic than the worst case release scenario; it is calculated based on the DEGADIS air dispersion modeling program, and is used to plan a facility's emergency response to accidents. 
The alternative case release scenario for Oleum at Richmond Works assumes Oleum would be lost due to failure of a transfer line during the transfer process.  It takes into account plant safety systems designed to limit a release.  The DEGADIS modeling program has determined that the material released would travel 0.52 miles before reachin 
g a non-hazardous concentration.  
4.0 General Accidental Release Prevention Programs and Chemical - Specific Prevention Steps  
General Chemical maintains a comprehensive release prevention program designed to prevent accidental releases and ensure safe operations of our processes.  The accidental release prevention program implemented at Richmond Works includes procedures and practices which address each of the required elements of the risk management program including: 
* Process Safety Information - Information relating to the hazards of the chemical(s), process technology and equipment information is maintained to ensure proper operation. 
* Mechanical Integrity - Equipment is routinely inspected and maintenance activities are managed in a manner to maintain the integrity of the equipment. 
* Process Hazard Analysis - Processes are routinely analyzed to identify and correct potential hazards, as well as increase the safety of the operating conditions. 
* Standard Operating Procedu 
res - Detailed procedures are in place identifying actions necessary for multiple phases of operation, operating limits and safety considerations. 
* Employee Participation - Employees at all levels are involved in key roles of the release prevention program.   
* Training - Employees in the operating process are trained in detail to ensure proper operation of the plant. 
* Management of Change - Process parameters are maintained through a management of change system which documents the changes as well as evaluates changes for safety. 
* Pre-startup Safety Review - Significant changes to the processes are evaluated in detail in order to verify that the proper procedures for engineering, operations, emergency response and overall safety are addressed prior to start-up. 
* Incident Investigation - All incidents are investigated to ensure proper modifications are made to reduce or eliminate the potential for re-occurrence. 
* Safe Works Practices - Standard safety practices are in place t 
o help insure worker safety including lockout/tagout procedures, control of entry into process areas, line breaking procedures, confined space entry procedures and hot work procedures. 
* Contractor Safety - Contractors are evaluated and trained prior to performing work on-site to reduce the potential of an incident.  
* Compliance Audits - Audits are performed at a minimum of three-year intervals to verify procedures and practices are adequate and are being followed. 
* Emergency Response - Plans are made with the community emergency response groups as well as onsite emergency response teams to ensure procedures are in place in case an emergency situation occurs. 
In addition to this general accidental release prevention program, General Chemical's Richmond Works has taken additional chemical-specific prevention steps designed to perform the following:  
* quickly detect a release of Oleum;  
* contain or control a release of Oleum; 
* and/or, reduce the consequences of a release of Ol 
The following types of safety features are used in various processes: 
Release Detection 
* Process temperature and pressure controls; 
* Operator surveillance of all process areas; 
* Oleum process equipment level alarms; and  
* Area monitoring for early detection of an Oleum release. 
Release Containment and Control 
* Pressure relief devices on storage units and process vessels; 
* Secondary containment for Oleum process vessel; 
* Oleum produced in small quantities to reduce the impact of a potential release; and 
* Automatic and manual shutdown systems on process equipment. 
Release Mitigation 
* Emergency shutdown procedures; 
* Trained emergency response personnel; 
* Notification procedures for plant personnel and local officials; 
* Personal protective equipment for emergency response personnel; and 
* Emergency Response plans prepared with local emergency response officials. 
5.0    Five Year Accident History 
Due to proactive actions taken to prevent accidents and the st 
rong safety culture developed by General Chemical's Richmond Works, there have been no incidents in the past 5 years that meet the reporting requirements for the USEPA's Accidental Release Prevention Provisions. 
However, Richmond Works has chosen to include an incident that occurred at our site on July 26, 1993. This incident, and the resulting procedural and technological changes are described below: 
Accident Description 
On July 26, 1993, approximately 3.9 tons of sulfur trioxide was released to the atmosphere from a railcar during off-loading.  The pressurized air and sulfur trioxide in the vapor space escaped through a safety rupture disc installed in the dome on top of the car, and poured through the opening for approximately three hours until the disc was replaced.  The Contra Costa County Health Service Department activated the Community Alert Network.  Castro Street and neighboring streets were closed to vehicular traffic until the release was stopped. 
Underlying Causes 
release was caused by a sudden increase of pressure in the vapor space inside the railcar.   
Measures taken to avoid reoccurrence 
The facility no longer stores Oleum in railcars. The facility has chosen to eliminate the storage and transport of Oleum by implementation of the Oleum Risk Reduction Project.  The Project consists of manufacturing Electronic Grade Sulfuric Acid on-site instead of storing and shipping Oleum to General Chemical's Bay Point Works (approximately 30 miles east). 
6.0       Emergency Response Program 
General Chemical's Richmond Works maintains an emergency response plan, which addresses all of the various federal, state and local regulatory requirements for emergency response planning.  Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations.  Furthermore, we coordinate our plan with the administering agency - Contra Costa Health Services Hazardous Materials Divis 
ion.  In addition, the facility is a member of Contra Costa County CAER Group, Inc., which is comprised of local government officials, local emergency response officials, industry representatives and community representatives.  Richmond Works, Contra Costa Health Services and the local fire departments have coordinated communication to notify the public quickly, if necessary, as well as facilitate quick response to an incident. In addition to periodic CAER meetings, Richmond Works conducts periodic emergency response drills that involve emergency response organizations.     
7.0 Planned Changes to Improve Safety 
Richmond Works performs periodic process hazard analyses to evaluate and to strive continuously to improve health, safety and environmental performance as technical developments, scientific understanding, consumer and community needs, and regulatory requirements evolve and change, some of which result in process modifications.  For example, the following improvements are curre 
ntly planned for Richmond Works: 
* Enhanced process interlocks 
* Seismic improvements to re-enforce process structures 
8.0    Certification 
The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
                                            Plant Manager 

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