Polychemie, Inc. - Executive Summary

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                       EXECUTIVE SUMMARY 
This Risk Management Plan (RMP) has been prepared to meet the requirements of the Risk 
Management Program Rule.   
As part of complying with the Risk Management Program Rule, Polychemie, Inc. (Polychemie) 
has reviewed and enhanced previously existing accidental release procedures and emergency 
response policies.  These policies include: 
   *   an emergency response sequence 
   *   emergency response to fires, explosions, and environmental releases 
   *   notification and reporting to regulatory agencies in the event of a reportable 
   *   emergency response to hurricanes, floods, and bomb threats 
   *   spill prevention control and countermeasure (SPCC) plan 
   *   identification and training of an emergency response team 
   *   emergency coordinator and regulatory call lists 
   *   emergency equipment list and location 
   *   sensitive materials storage list 
   *   material profiles and material safety data sheets fo 
r major raw materials on site.  
There is one substance at the Polychemie facility that is currently regulated by the Chemical 
Accident Prevention Provisions defined at 40 CFR Part 68.  This substance is used in various 
processes throughout the facility to produce water treatment polymers.  Specifically, the facility 
produces diallyl dimethyl ammonium chloride (DADMAC).  Substances that are used by 
Polychemie that are regulated as either toxic substances or flammable substances by 40 CFR Part 
68 are as follows: 
Toxic Substances: 
         No substances currently subject to RMP. 
Flammable Substances: 
    Dimethylamine: Dimethylamine is used in the DADMAC process as a reactant. 
    Dimethylamine is received and stored in anhydrous form. The maximum amount of 
    anhydrous dimethylamine stored on-site is approximately 380,000 pounds. 
Worst-case Scenarios: 
As required by the Risk Management Program Rule, worst case and alternative release scenarios 
were evaluated and are discussed 
in this RMP.  As required, a  worst case scenario is presented in 
the RMP for the one flammable substance.  An alternative scenario was also prepared for the  
flammable substance since the worst-case endpoint was located off site.  The endpoint represents 
the distance at which the effects from a released substance do not pose potential serious risk to 
the public.   
For the worst case scenario, EPA has defined a worst-case release as the release of the largest 
quantity of a regulated substance from a vessel or process line failure that results in the greatest 
distance to a specified endpoint.  For the worst-case analysis, the possible causes of the 
worst-case release or the probability that such a release might occur are not considered.  The 
release is simply assumed to take place and the greatest amount held in a vessel is suddenly 
released.  The results of the worst case scenario analysis were as follows: 
    Flammable Substances: A dimethylamine storage tank was assumed to fail a 
    subsequently produce an instantaneous release of the entire tank contents that results in a 
    vapor cloud explosion.  No passive mitigation controls were considered in limiting the 
    release impacts.  The distance to the explosion endpoint was estimated to be less than 
    0.43 miles. 
Alternative Release Scenarios: 
Alternative release scenarios are more realistic scenarios that result in endpoints that affect public 
receptors. For dimethylamine, the alternative release scenario assumed that dimethylamine was 
released as a result of the uncoupling or rupture of a hose during unloading operations. The 
alternative release scenario was assumed to occur over a 1-minute time period. With the 
exception of considering that these transfer operations are monitored by personnel at all times, no 
other mitigating controls were assumed to limit the release.  The results of the alternative release 
scenario analysis were as follows: 
         Flammable Substance: 
Dimethylamine - <0.06 miles 
Prevention Program: 
To address potential accidental releases, an accidental release prevention program along with 
chemical specific prevention steps has been developed. The key parts to the program are:   
    *    Written operating procedures and emergency shutdown procedures. 
    *    Engineering controls to include that all valves fail in the safe position on loss of motive 
           power.  Safe position is "closed" in most cases. 
    *    Emergency responders trained in the plant. 
    *    Contract emergency responders on 24-hour call. 
Additionally, the facility has programs to address the OSHA Process Safety Management (PSM) 
requirements for dimethylamine. 
Emergency Response Program: 
The facility also has an emergency response program (ERP) in association with the  
implementation  of the Risk Management Program.  The ERP will be coordinated with the local 
fire department.  As part of community involvement efforts, the facility's management  
coordinated an emergency response drill with the local fire department, police department, and 
ambulance service which will take place in May 1999. 
As part of preparing the RMP, the facility's five year accident history was reviewed. Since 
Polychemie is a new facility, no accidental releases from covered processes have occurred that 
resulted in deaths, injuries, or significant property damage on-site or off-site; or resulted in off- 
site evacuations or sheltering in place.  
Safety Improvement: 
Polychemie is committed to continuous improvement of safety.  Planned changes and policies to 
promote this improvement include continuous review and update of the facility's ERP, continued 
management of the plant Safety Work Order System, and yearly emergency drills with the 
community to determine and improve upon deficiencies.
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