IMC CHEMICALS, INC. - LAKE OPERATIONS - Executive Summary |
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EXECUTIVE SUMMARY - IMC Chemicals, Inc. (IMCC), Lake Chlorine Storage Area 1. Accidental Release Prevention and Emergency Response Policies IMC Chemicals, Inc. (IMCC), Lake Chlorine Storage Area is strongly committed to employee, public and environmental safety and health. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the manufacturing processes at our facilities. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. These goals are achieved through strong leadership, teamwork, effective communications and by striving to continuously improve in all areas of our business. This commitment is also consistent with the corporation's environmental, health and safety policy that provides that: 1) All facilities will be designed, operated and managed to protect the health a nd safety of the employees and the public; 2) All employees will be educated on the applicable environmental, health and safety standards and procedures; 3) Sufficient human and financial resources will be allocated to sustain these goals; 4) Audits will be conducted regularly to verify compliance with this policy. These corporate policies also emphasize the importance of complying with OSHA's Process Safety Management standard, so that all employees and the surrounding community will be adequately protected from potential fire, explosion and/or toxic release hazards associated with catastrophic releases. IMCC is proud to be an active participant in the Chemical Manufacturers Association - Responsible Care program. As a member of CMA, this company is committed to support a continuing effort to improve the industry's responsible management of chemicals. IMCC pledges to manage their business according to the principles of Responsible Care. 2. Stationary Sources(s) and Regulated S ubstance(s) Handled Eight to ten portable pressurized chlorine storage cylinders are stored and handled in the middle of the lakebed (Searles Lake) of the Lake Operations (several miles from public receptors). The cylinders are transported to this location by the chlorine vendor for storage only and are never hooked up for use at this location. From here, IMCC personnel move these cylinders to other processing facilities when they are needed. Chlorine is the only regulated toxic substance that exceeds the threshold planning quantity at this location. 3. Worst Case Release Scenario(s) and Alternative Release Scenario(s) The worst case release scenario is the loss of the entire contents of a single portable chlorine storage cylinder. The entire contents of the horizontal cylinder were assumed to be released in a 10-minute period. Calculations for this scenario were developed using a commercial computer plume dispersion model, BREEZE DEGADIS+, version 3.0.1. The results from thi s model show that the distance to the toxic endpoint of 0.0087 mg/L has offsite impacts. The alternative release scenario for chlorine giving the furthest distance to the toxic endpoint involves a release from a single portable storage cylinder due to a three-quarter-inch valve opening at the bottom of the cylinder. Again, the entire contents of a the horizontal cylinder were assumed to be released. The distance to the toxic endpoint of 0.0087 mg/L was calculated using EPA's Guidance on the Application of Refined Dispersion Models for Hazardous/Toxic Air Releases using standard RMP alternate release scenario parameters and was determined to have offsite impacts. 4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The IMCC Facilities have taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The IMCC covered processes were designed, constructed and are maintained accordi ng to nationally recognized industry codes and standards and regulatory requirements. Chlorine is regulated as a highly hazardous chemical under Cal-OSHA's Process Safety Management (PSM) standards. Based on the quantity of this material at IMCC, IMCC is subject to PSM requirements and thus satisfies the eligibility requirements for a program 3 prevention program under EPA's RMP. IMCC Facilities have fully implemented Cal-OSHA's PSM standard requirements and are using this program as its RMP Prevention Program. The following sections briefly describe the elements of the PSM program that are in place at our facilities: IMCC maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with each covered process. IMCC maintains written operating procedures, which are periodically reviewed and updated as needed. Additionally, all facilities have written ISO documents that support Operations' personnel in t heir efforts to conduct all activities in a safe and responsible manner. Most maintenance procedures are in the form of JSA's and written ISO documents that pertain to very specific tasks. These aid our maintenance personnel in their efforts to conduct all activities in a safe and responsible manner. IMCC has a comprehensive training program to ensure that all employees who operate processes, are trained and competent in the operating procedures associated with each process. Newly hired employees go through an extensive training program that takes over a year to complete and encompasses classroom and computer training and testing, field training and testing, verbal testing, and demonstration type testing. Refresher training occurs on an average of every three years or more often as necessary. Maintenance personnel are hired as trained and qualified "maintenance journeyman." IMCC carries out and documents maintenance checks on process equipment to ensure reliable and safe operati on. Process equipment examined by these checks include: storage tanks, piping and valves, relief systems, electrical systems, instrumentation systems, mobile equipment, detection and monitoring systems. Any equipment deficiencies identified by the maintenance checks or operations personnel are corrected in a timely manner and tracked through a computer-based system. The computer system also notifies maintenance personnel of preventive maintenance tasks. IMCC conducts periodic audits to determine whether provisions set out under the PSM standard are being implemented. Any corrective actions required as a result of the audits are promptly addressed. IMCC promptly investigates all accidents/incidents that result in, or could reasonably result in a catastrophic release of a regulated substance. The IMCC accident/incident policy and procedure were established to provide guidance in identifying and documenting the situation(s) leading to the accident/incident as well as any correcti ve actions necessary to prevent reoccurrence. All records and reports are retained for a minimum of 5 years. IMCC believes that process safety management and accident/incident prevention are a team effort. Employee and management participation in all areas of EHS are encouraged and well publicized in our policies and procedures, training, and meeting requirements. Air monitoring systems have been strategically located in the Lake Chlorine Storage Area for chlorine. These air monitors help warn employees of a leak. The sensor triggers an alarm system when it detects chlorine at a level of 3 PPM or greater. Such a warning allows quick response by the area operator(s) and the HAZWOPER Team should they be needed. Additionally, all areas of the various plants have IMCC employees working on a 24-hour per day basis. This employee presence allows for early detection of a release and quick response. A licensed and certified chlorine trailer and truck are used in the transportation. A n overhead jib crane and lifting device are used to lift the containers onto the chlorine trailer where they are secured in place against movement by metal securing straps. 5. Five-Year Accident History The five-year accident history includes all accidental releases of regulated substances held above threshold quantities in covered processes that resulted in on-site deaths, injuries, or significant property damage, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Since June 21, 1994, the Lake Chlorine Storage Area has had no accidental releases which meet the above criteria. 6. Emergency Response Program IMCC has two very extensive and detailed written emergency response plans. Both plans include all aspects of emergency response including adequate first aid and medical treatment, evacuation notification of LERC/LEPD and the public. To ensure proper functioning, our emergency response equipment is periodically in spected and serviced and the emergency evacuation sirens are tested every Friday at noon. In addition, the plans are updated timely to reflect any pertinent changes within our processes that would require a modified emergency response. Periodic response drills are conducted to check response time and effectiveness of the response team(s). All employees and contractors are trained on these plans. If such a release does occur, our environmental, health and safety (EHS) staff and HAZWOPER trained emergency response personnel are at hand to control and mitigate the effects of the release. IMCC coordinates their EHS efforts with several State and County agencies including the San Bernardino County Fire Agency and Sheriff offices. Mutual responses efforts have been established with the local San Bernardino County (volunteer) Fire Agency that provides additional emergency response expertise to both the community and IMCC facilities. 7. Planned Changes to Improve Safety IMCC plans to hold an emergency response drill that will involve a simulated large chemical release. At this time, local San Bernardino County agencies will be involved in the drill, including the Sheriff's Department, local SBC Fire Department, the local school system and selected members of the community. Of course, the monthly employee safety meeting provided the opportunity for each person to make recommendations on ways to improve EHS within all of our facilities. |