NIACET CORPORATION - Executive Summary

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Niacet is committed to operating its Niagara Falls, New York facility in a safe and responsible manner. Our long term history of no off site releases  of RMP regulated chemicals speaks for itself. This is due to the layers of safeguards in place to prevent the release of hazardous substances. In the unlikely event of a chemical release, comprehensive emergency  response plans are in place to bring any situation to a safe resolution. Niacet regularly meets with local emergency responders, and conducts on going training of employees and off site responders to be prepared in the unlikely event of an emergency situation. 
 
                                 Components of Niacet's Risk Management Plan 
Hazard Assessment: 
 
Each industry is required to determine its worst case release scenario for listed toxic or flammable substances which may affect the community. Any alternate or more likely release scenario must also be includud. The hazard assessment must include an estimate of potential rel 
ease quantities including the distance affected and potential effects on people and the environment. A five year accidental release history is also included in the assessments. 
 
Toxic Substances  Chlorine: 
 
The worst case release scenario for chlorine at Niacet is the release of the contents of a full liquid chlorine car over a 10 minute period as mandated by RMP guidelines. This scenario assumes that 180,000 lbs of liquid chlorine vaporizes within the 10 minute interval. The worst case release scenario was evaluated by using EPA's Look up tables identified in the Offsite Consequence Analysis Guidance Document. Under the least favorable weather conditions, the chlorine gas would travel a distance greater than 25 miles before the concentration was reduced to below 3 parts per million. It is estimated that 1,100,000 people live within this 25 mile radius. 
 
The alternative case scenario for chlorine is the failure of a 1" pipe at our chlorine vaporizer. We estimate that this failure could 
result in the release of 600 lbs of chlorine over a 20 minute period.This scenario was also evaluated  by EPA's Look up tables identified in the Offsite Consequence Analysis Guidance Document. It is estimated that this release would travel a distance of 0.56 miles before the concentration was reduced to below 3 parts per million. It is estimated that 500 people live within this 0.56 mile radius. 
 
Flammable Substances 
 
The worst case scenario for flammables is fixed by RMP guidelines. For this scenario the entire contents of an ethyl ether tank (83,000 lbs) is presumed to vaporize  and produce a  vapor cloud explosion which is a cloud containing the flammable vapor and air. The end point for this scenario is also fixed at 1 psi overpressure. This scenario was evaluated by EPA's Look up tables identified in the Offsite Consequence Analysis Guidance Document. It is estimated this vapor cloud explosion would produce a 1 psi overpressure up to 0.30 mi from our tank. There are no residences 
in this radius. 
 
The alternative case scenario for flammables is the failure of an ethyl ether liquid transfer line at our tank farm. It is estimated that this failure could result in the release of 8,300 lbs of ethyl ether into our tank farm dike. This scenario was also evaluated by EPA's Offsite Consequence Guidance Document. It is estimated that the radiant heat would travel a distance of 0.06 miles before the endpoint of5 kw/m2 for 40 seconds was reached. There are no residences in this radius. 
 
Accident Prevention 
 
Accident prevention is a key element of Niacet's RMP plan. We take a systematic, proactive approach to preventing accidental release of hazardous chemicals. Niacet's RMP plan includes the adoption of OSHA's accident prevention program. Some key elements include: Operating procedures, Process Safety Information, Process Hazard Analysis, Training, Mechanical Integrity, Incident Investigations, Compliance Audits, Management of Change, Contractors, Pre-Startup Review, and  
Employee Participation. 
 
Planned Changes to Improve Safety 
 
Niacet Corporation maintains a comprehensive safety improvement program. This includes the establishment of a joint Union/Management Safety Committee, reviews of our plant procedures, near misses and incident investigation programs, solicitation of suggestions, and the maintainence of regular departmental  safety meetings.
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