Polychemie, Inc. - Executive Summary
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:
No substances currently subject to RMP.
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.
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
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
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:
Dimethylamine - <0.06 miles
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.
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.