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EXECUTIVE SUMMARY - IMC Chemicals, Inc. (IMCC), Trona Facility P-20 Plant 
1.  Accidental Release Prevention and Emergency Response Policies 
IMC Chemicals, Inc. (IMCC), Trona Facility P-20 Plant 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  
and 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 Source(s) and Regulated S 
ubstance(s) Handled 
At the Trona P-20 Plant, three portable pressurized chlorine storage cylinders and associated piping are used for batch addition of chlorine to the process.  Also, a 37% solution of formaldehyde is used in the formation of P-20 (a proprietary organic material) to extract borate compounds from the Searles Lake brines.  This formaldehyde solution is stored in an aboveground storage vessel.  Chlorine and formaldehyde are the only regulated toxic substances that exceed their threshold planning quantities in this process. 
3.  Worst Case Release Scenario(s) and Alternative Release Scenario(s) 
The worst case release scenario is loss of the entire contents of the aboveground storage tank containing a 37% solution of formaldehyde into the surrounding diked area.  Calculations for this scenario were based on EPA's Offsite Consequence Analysis guidance document.  These calculations establish that the distance to the toxic endpoint of 0.012 mg/L had offsite impacts.  A worst 
case release scenario was also calculated for chlorine at the plant; however, the formaldehyde worst case generated the furthest distance to the toxic endpoint. 
The alternative case for chlorine giving the furthest distance to the toxic endpoint involves a release from one of the portable storage cylinders due to a shearing of a one-inch valve connected to the cylinder.  The entire contents of one cylinder were assumed to be released as a gas.  In this case, a commercial plume dispersion model, BREEZE DEGADIS +, version 3.0.1, was used to calculate the distance to the 0.0087 mg/L toxic endpoint using standard RMP alternative case parameters. The results obtained from this model showed that the distance to the toxic endpoint had offsite impacts. 
The alternative case for formaldehyde giving the furthest distance to the toxic endpoint involves a break in the two-inch pipe connected to the aboveground storage tank; resulting in a liquid release into the surrounding diked area.  The EPA' 
s Offsite Consequence Analysis guidance document was used to calculate the distance to the 0.012 mg/L toxic endpoint using standard RMP alternative case parameters. These calculations show that the distance to the toxic endpoint has 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 according to nationally recognized industry codes and standards and regulatory requirements.  Chlorine and formaldehyde are regulated as highly hazardous chemicals under Cal-OSHA's Process Safety Management (PSM) standards.  Based on the quantities of these materials at IMCC, IMCC is subject to Cal-OSHA PSM requirements and thus satisfies the eligibility requirements for a program 3 prevention program under EPA's RMP.  IMCC fac 
ilities 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 is 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 their 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 proces 
ses, 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 operation.  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 corrective 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.  
An air monitoring sy 
stem has been strategically located in the Trona P-20 Plant 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 0.5 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.  In addition, the portable chlorine storage containers are secured in place against movement by metal securing straps meeting seismic 4 standards. 
The formaldehyde storage tank is located within a concreted diked area and secured to the concrete pad it rests on in a manner to meet seismic 4 standards.  This diked area is a secondary containment used to contain any formaldehyde released from the tank or piping and keeps an accidental release within a confined area.  The formaldehyde 
is transported to the tank by a vendor and placed into the tank following a specified procedure, under controlled conditions and under the supervision of an IMCC employee.  Should an accidental release occur, trained emergency response personnel would respond to the release. 
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 Trona P-20 Plant 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 th 
e public. 
To ensure proper functioning, our emergency response equipment is periodically inspected 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 bo 
th 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, monthly employee safety meetings provide the opportunity for each person to make recommendations on ways to improve EHS within all of our facilities.
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