Secodyne, Incorporated - Dolton, Illinois - 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, Secodyne, Inc. (Secodyne) has 
reviewed and enhanced previously existing accidental release procedures and emergency 
response policies.  A formal Emergency Action Plan has been developed and implemented that 
includes the following: 
    Emergency Notification and Communication Procedures 
         Fire / Explosion 
         Bomb Threat 
         Severe Weather Conditions and Natural Phenomenon 
         Environmental Chemical Spill / Release 
         Power and /or Equipment Failure 
         Interruption or Failure of Fire Protection Equipment 
         Civil Disturbance 
    Emergency Action Plan Responsibilities 
         Emergency Action Coordinator 
         Site Operating Personnel 
    Fire and Hazard Area Identification 
         Site Plot  
Plan / Map 
    Emergency Evacuation Exits and Points of Assembly 
         Rescue Procedures 
    Emergency Procedures 
         Electrical Power Failure 
         City Water Failure 
         Hazardous Material Spill Response 
              Decontamination Procedures 
              First Responder Operations Level Spill Containment and Disposal 
              Public and Private Spill Containment and Disposal Services including 
                   CHEMTREC / CHEMNET 
         Bomb Threat 
         Crowd Control 
         Public Disturbance 
         Hurricane, Tornado, Flood, Earthquake, Severe Storms 
    Fire and Hazardous Material Spill Emergency Pre-Plan 
         Cooperative Community Efforts, Drills, Tours (LEPC) 
         Material Safety Data Sheets for Chemical Substances 
         Emergency Procedures and Equipment 
         Life Safety  
    Emergency Equipment, Supplies and Material List (Inventory) 
Emergency Action Plan 
         Incipient Fire Fighting 
    First Responder Operations Level Spill Containment and Disposal 
There are two substances at the Secodyne facility that are regulated by the Chemical Accident 
Prevention Provisions defined at 40 CFR Part 68.  These substances are used in various 
processes throughout the facility to produce water treatment polymers. Substances that are used 
by Secodyne that are regulated as either toxic substances or flammable substances by 40 CFR 
Part 68 are as follows: 
Toxic Substances: 
         Formaldehyde: Formaldehyde is received and stored as a 37 percent solution in water.  
    The maximum amount of 37 percent formaldehyde stored on-site is 62,000 pounds 
    (23,000 pounds pure formaldehyde). 
Flammable Substances: 
         Dimethylamine: Dimethylamine is received and stored as a 60 percent solution in water. 
    The maximum amount of 60 percent dimethylamine stored on-site is approximately 
    50,000 pounds (30,000 pounds pu 
re dimethylamine). 
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, worst case scenarios are presented in 
the RMP for one toxic substance and one flammable substance.  Alternative scenarios were 
prepared for each of the toxic substances with worst case endpoints located offsite and for one 
flammable substance.  The endpoint represents the distance at which a released substance must 
travel before it disperses sufficiently to no longer pose a hazard 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: 
         Toxic Substances: The formaldehyde storage tank was assumed to fail and subsequently 
    produce an instantaneous release of the entire tank contents.  The release was assumed to 
    evaporate over a 10-minute time period. Since the tank is enclosed by a building and 
    diked, these passive mitigation controls were considered in limiting the release impacts.  
    The distance to the toxic endpoint was estimated to be less than 0.06 miles. The release 
    rate according to OCA Guidance was calculated to be 0.012 pounds per minute.  
    However, a release rate of 0.2 pounds per minute was entered into the RMP Submit 
    document since this is the lowest value that can be entered into the program. 
         Flammable Substances: The dimethylamine storage tank was assumed to fail and 
    subsequently  produce an instant 
aneous 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 
    0.23 miles. 
Alternative Release Scenarios: 
Alternative release scenarios are more realistic scenarios that result in endpoints that affect public 
receptors.  For formaldehyde the release was assumed to occur as a result of the uncoupling or 
rupture of a  transfer hose during unloading operations.  For flammable materials, the alternative 
release scenario assumed that dimethylamine was released as a result of the uncoupling or 
rupture of a hose during unloading operations. The durations for releasing these materials from a 
vessel/pipe for the alternative release scenarios were assumed to occur over a 45-second time 
period since the unloading operations are supervised.  With the exception of considering that 
these transfer operations are mo 
nitored by personnel at all times, no other mitigating controls 
were assumed to limit the releases. The results of the alternative release scenario analysis were as 
         Toxic Substances: 
                   Formaldehyde, 37 percent - 0.06 miles 
         Flammable Substance: 
                   Dimethylamine - 0.06 miles 
Prevention Program: 
To address potential accidental releases, an accidental release prevention program along with 
chemical specific prevention steps have been developed. The key parts to the program are:  
    Formal Company Risk Management Procedure that includes: 
         Management Systems Responsibilities 
         Risk Management Plan Coordinating Review Team 
         Risk Management Plan Changes and Updating 
         Recordkeeping Requirements 
         Communication and Coordination of Risk Management Information 
    DOT Hazardous Material Training 
    Contractor Performance Selection Process 
    Operating Procedure 

    Emergency Procedures 
    New Employee Environmental Health and Safety Orientation Training Program 
    Process Safety Program Auditing 
    24-hour Emergency Communications 
Additionally, the facility has programs to address the OSHA Process Safety Management (PSM) 
requirements for the chemicals formaldehyde and dimethylamine, such as: 
    Mechanical Integrity - Preventive Maintenance of Equipment 
    Pre-startup Safety Reviews 
    Management of Change 
    Process Hazard Analysis 
    Incident Investigation 
Emergency Response Program: 
The facility also has an emergency response program (ERP) that has been enhanced as part of 
implementing the Risk Management Program.  The ERP has historically been coordinated with 
the Dolton Fire Department and the County dispatcher (i.e., 911).  
As part of preparing the RMP, the facility's five year accident history was reviewed. No 
accidental releases from covered processes have occurred that resulted in deaths, injuries, or 
cant property damage on-site or off-site; or resulted in off-site evacuations or sheltering in 
Safety Improvement: 
Secodyne is committed to continuous improvement of safety.  Planned changes and policies to 
promote this improvement include updating and implementing safe work practices such as: 
confined space entry permits; hot work permits; pipe entry permits; lock-out tag-out procedures; 
and hazard communication procedures.
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