Riverdale Chemical Company - Executive Summary |
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All of the information submitted to the USEPA is accurate as of June 1, 1999. Accidental release prevention and emergency response policies at the stationary source. Riverdale Chemical Company is committed to providing a safe, healthy and environmentally conscious work-place for its employees and neighbors. Riverdale coordinates all of the emergency response activities with the Cook County LEPC, and Chicago Heights Fire Department. The stationary source and regulated substances handled. Riverdale manufacturers water-based herbicides consisting of one main process area where the herbicides are produced and a designated dimethylamine (DMA) tank location. The herbicides are produced in batch processes. Riverdale has 1 regulated substance, dimethylamine (DMA), at the facility. The DMA is stored as a 60% (by weight) aqueous solution. The maximum inventories of the regulated substance is summarized below: 60 % DMA - 44,000 pounds Worst case release scenario(s) and alternative rel ease scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario. The RMP Rule requires the development of scenarios for the accidental release of toxic and flammable substances. Riverdale reviewed Process Hazards Analysis, Environmental Release (RQ) Reports, Incident Reports, and Five Year Accident History to identify and model these release scenarios. EPA's Offsite Consequence Analysis Guidance dated May 24, 1996 was utilized to model the release scenarios. Riverdale has identified one worst case scenario and several alternative case scenarios (only one is included in RMP Submit). The flammable worst case scenario for the Riverdale facility involves the instantaneous failure of the DMA storage tank located on the south side of the site. 100% of the DMA inside the tanks is assumed to form a vapor cloud within the upper and lower flammability limits, and the cloud is assumed to detonate. As a conservative assumption, 10 percent of the flammable vapor in the cloud is assumed to participate in the explosion. This scenario results in off-site impacts to residences, schools, and industrial areas. There were no administrative controls or passive mitigation considered for this scenario. The flammable alternative case scenario for the Riverdale facility involves the catastophic failure of the DMA storage tank fill piping. 100% of the DMA inside the tanks is assumed to form a vapor cloud within the upper and lower flammability limits, and the cloud is assumed to detonate. As a conservative assumption, 3 percent of the flammable vapor in the cloud is assumed to participate in the explosion. This scenario results in off-site impacts to residences and industrial areas. There were no administrative controls or passive mitigation considered for this scenario. General accidental release prevention program and chemical specific prevention steps. Riverdale has implemented programs to comply with the acci dental release prevention requirements outlined by EPA. Process Safety Information Riverdale maintains a compilation of current and accurate written safety information. This includes information pertaining to hazards of regulated substances, the technology of the process and the equipment in the process. Process Hazard Analysis Riverdale has performed initial process hazard analysis to comply with 29 CFR 1910.119(e) and these hazard analysis apply to processes covered by RMP. The Riverdale Site utilizes the What-if Method to identify hazards of the process, to identify previous incidents that may result in a release of a regulated substance, to ensure proper detection systems are in place, to consider consequences of failure of administrative and engineering controls, to identify human factors that may contribute to the release of a regulated substance and to evaluate safety and health effects of possible releases of regulated substances. Operating Procedures Riverdale has writte n operating procedures that provide instructions for safely operating covered processes. These operating procedures are available to employees who work in the processes. The procedures are reviewed annually and modified whenever needed to accommodate operational and process changes. Training Riverdale provides initial training as well as refresher training to employees who operate the processes. Training documentation provides records of when training was received and whether or not the training was understood. Mechanical Integrity Riverdale has written procedures for maintaining the mechanical integrity of process equipment. Maintenance employees receive training for maintenance activities. Periodic inspection and testing are performed on process equipment, and records are kept to document this inspection and testing. Management of Change Riverdale has a written procedure established to document and manage changes to process chemicals, technology, equipment and procedures. Em ployees are notified of and provided training for changes to the process. Pre-Startup Review Riverdale performs pre-startup reviews for changes in a process that require modification to process safety information. Compliance Audit Riverdale will evaluate compliance with the provisions of 40 CFR part 68 every three years. Incident Investigation Riverdale conducts an incident investigation for every incident that resulted in or could have resulted in a catastrophic release of a regulated substance. Employee Participation Riverdale has a written employee participation plan that allows input from employees on the development and analysis of process safety management. PHA's and all other RMP information are available to employees. Hot Work Permit Riverdale has a procedure for the issuance of hot work permits for hot work done on a covered process. Contractors Riverdale hires contractors to perform maintenance and various other activities at their facility. Riverdale reviews contracto rs' safety performance and programs and informs contractors of known potential hazards related to working at their site. Riverdale maintains a program to control entrance, presence and exit from covered process areas. Contractor performance is evaluated annually. 5 Year Accident History There have been no accidental releases at the Riverdale Chemical Company that qualifies for the 5-Year Accident History. Emergency Response Program. Riverdale does not have a formal written emergency response program but coordinates all of their response actions with the Chicago Heights Fire Department. Riverdale does have a written Fire Safety and Emergency Evacuation Plan. Planned changes to improve safety. At this time, there are no changes planned to enhance the safety of the Riverdale facility, but there is an on-going commitment to implement changes, when identified, that will improve the safety of its employees and neighbors. |