VANDEMARK GROUP - Executive Summary |
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Introduction: The VanDeMark Group is covered under the RMP rule due to the presence of phosgene and chlorine above the applicability thresholds. The VanDeMark Group consists for three (3) companies; VanDeMark Chemical, Vanchem and Vanchlor. All companies are located on the same contiguous property located at 1 North Transit Road in Lockport, New York. VanDeMark Chemical produces phosgene. Vanchem produces phosgene derivatives. Vanchlor produces anhydrous aluminum chloride. The VanDeMark Group is a member of the Synthetic Organic Chemical Manufacturers Association (SOCMA) the Chemical Manufacturers Association (CMA) Phosgene Safety Panel, and participates in the CMA Responsible Care Program. Toxic worst case scenario The VanDeMark Group will report a toxic worst case release scenario. The toxic worst case scenario for the VanDeMark Group is the failure of a 90 ton chlorine rail car. All 180,000# of chlorine are released equally as a gas over a 10 minute period. This worst case scenar io was developed based upon the EPA guideline for estimating a worst case scenario. It is not based upon past history at this facility or in the chlorine industry. The chlorine rail car design and engineering controls and procedures in place at the VanDeMark Group make this type of an incident highly improbable. Toxic alternate release scenario The VanDeMark Group will have 2 alternate release scenario's, one for phosgene and one for chlorine. The alternate release scenario for phosgene is the failure of a transfer hose. The maximum rate of phosgene passing through the hose is 14# / minute. The duration of the release would be 10 minutes. 10 minutes is the maximum amount of time needed to shut off the flow of phosgene. The release would result in a 0.20 mile distance to the toxic endpoint as calculated using "CHARM" dispersion modeling software. The weather conditions are assumed to be the average temperature in the building where the spill would occur which is a climate controlle d room. The transfer hose that is being used for this alternate release scenario has never had a failure of this type in the over 35 years in use at the facility. The chlorine alternate release scenario is based upon an actual incident that occurred (See accident history). The alternate scenario is a pipe / transfer hose failure on the chlorine rail car unloading siding. 90 pounds per minute of liquid chlorine is released for 5 minutes before the flow of chlorine is stopped. This results in a 450# release of chlorine. The release would result in a 0.75 mile distance to the toxic endpoint as calculated using "CHARM" dispersion modeling software and actual weather conditions the day of the incident. The incident occurred when both the VanDeMark Group operator and a Conrail employee failed to notice that the rail car being removed from the rail siding was still connected to the process piping. This resulted in the transfer hose and pipe to fail releasing chlorine as described above. Si gnificant changes have been made to the procedures to inspect and release chlorine rail cars in the future. Additionally, engineering controls will be installed to allow for immediate automatic or manual remote closure of chlorine lines in the event of a similar incident. Flammable release scenario The VanDeMark Group does not have any flammable chemicals on site that are covered by the RMP rule. As such, no flammable worst case or alternate release scenario's have been reported. 5 year accident history The 5 year accident history for the VanDeMark Group includes one incident. On March 12th, 1998 a chlorine release occurred as described in the alternate release scenario for chlorine above. The incident lasted only 5 minutes. Due to the damage to the chlorine pipeline, a shelter in place was implemented in the down wind area for approximately 6.5 hours until there was no threat of subsequent releases from the damaged pipeline. The sheltered area included DeWitt Clinton School. Wo rk on stabilizing the pipeline was halted to allow for the release of the students. The students were bussed to the Lockport High school and released. There were no injuries to either company personnel, Conrail personnel, surrounding industries, residents, or emergency response officials. Two City of Lockport police officers who were stationed at a road block approximately 1/4 mile downwind complained of slight irritation of the throat. Both officers were evaluated at Lockport Hospital and released. Changes as a result of this incident are discussed above. The response to this incident went extremely well due to the preplanning efforts of the VanDeMark Group and the City of Lockport. This exact scenario was previously rehearsed the previous year. The response including community notification, sheltering in place of residents and DeWitt Clinton School, and evacuating students all went according to the preplan. Prevention program 3 The VanDeMark group has a fully implemented prevention program in place to prevent accidental releases of chemicals (VanDeMark Group Safety & Health Program). The VanDeMark Group safety programs are designed to meet or exceed OSHA process safety standards, CMA Responsible Care Codes, and industry standards. The safety program includes: HAZARD REVIEWS, PRE-START UP SAFETY REVIEWS, EMERGENCY RESPONSE, AND ENGINEERING CONTROLS INCLUDING: (SCRUBBING SYSTEMS, EMERGENCY BACK UP POWER, ENCLOSURES ON PHOSGENE PRODUCTION FACILITIES, REDUNDANT CRITICAL EQUIPMENT, MANUAL AND AUTOMATED EMERGENCY SHUTOFFS & INTERLOCKS, ALARM SYSTEMS, INTERNAL AND FENCE LINE MONITORS FOR, PHOSGENE, CHLORINE, CARBON MONOXIDE, AND FLAMMABLE GASSES.) Emergency response The VanDeMark Group emergency response plan has been fully integrated into the City of Lockport and the Niagara County emergency response plans. The plans are tested each year and coordinated with the City of Lockport & Niagara County. The VanDeMark Group is a member of both the City of Lockport & Niag ara County Emergency Response Planning committees. The VanDeMark Group maintains a fully staffed hazardous materials emergency response team and has agreements with OHM, the Niagara area CHLOREP team (Chlorine emergency response team) and the Niagara County Hazmat team to provide supplemental support as needed. Means of notification, sheltering, and evacuation of area residents has been developed, communicated to the community, and rehearsed. |