ALL-PURE CHEMICAL - SPOKANE PLANT - Executive Summary

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   Introduction: 
All-Pure Chemical Company (APC) is committed to the safety and well being of its employees and the public.  As a member of the Chlorine Institute, the Spokane Local Emergency Planning Committee and the Chemical Manufacturers Association active in the Responsible Care Program activities we strive to demonstrate our concern for the safety and welfare of our employees and the neighboring community.  Our policy is to implement reasonable measures to prevent a release of hazardous material from occurring, to provide early detection of a release in the unlikely event that one would occur, and to have in place a contingency plan to respond promptly, yet safely to such a release. 
 
   Regulated Substances: 
This Risk Management Plan has been prepared to address the handling of the following regulated substances at the APC facility located at 3818 North Market Street, Spokane, Washington: 
 
       Chlorine 
       Sulfur Dioxide 
 
   Chlorine is received in ton containers and 150-lb. cylinders an 
d is stored for supply to customers.  No re-packaging takes place at the Spokane Distribution Center.  Customers, in treating drinking water, wastewater, swimming pool water and industrial water to eliminate and/or prevent growth of harmful organisms in the water use chlorine. 
 
   Sulfur dioxide is received in ton containers and 150 lb. cylinders and is stored for supply to customers. No repackaging takes place. Sulfur dioxide is also used in water treatment. 
 
   Worst Case & Alternate Scenarios  
   The worst case release for both chlorine and sulfur dioxide that was modeled was the release of the entire contents of the largest vessel in a period of ten minutes. The alternate releasefor both chlorine and sulfur dioxide  that was modeled was a release which would result from a 1/16 pinhole in the fusible plug of a chlorine or sulfur dioxide container. All scenarios have offsite impacts. No credit for measures to prevent and/or mitigate the aforementioned releases was taken in modeling the re 
leases. 
    
   Accidental Release Prevention Program 
   APC has a comprehensive release prevention program meeting RMP Prevention Program and OSHA Process Safety Management (PSM) requirements.  The chlorine containers themselves and our material handling equipment are fully compliant with Chlorine Institute and Industry specifications and practices.  Procedural safeguards include Standard Operating Procedures and our Preventive Maintenance Programs that ensure continued safe operation through regular inspections.  
 
   Five Year Release History 
A review of the facilities hazardous material handling record has shown there were no reportable quantity, or smaller quantity releases that would have off-site consequence in the last five years. 
 
Emergency Response 
   APC has a comprehensive emergency response program, which includes the installation of detection alarm systems to mitigate a release. In the unlikely event that a release cannot be controlled completely with these systems, APC has an Emerge 
ncy Response Team trained and equipped to respond safely to a release in accordance with a written Emergency Response Plan. APC has worked closely with the Spokane LEPC in developing its Emergency Response Plan. 
 
   Safety Improvements 
APC undertook a major upgrade of the facility in 1998, which resulted in the installation of a detection alarm system. APC performed a new Process Hazard Analysis in 1999 as part of the development of the Risk Management Program. The following additional steps have been made or are planned to improve safety: 
 
   -    Installation of an additional detection device. 
-    Revision of procedures to incorporate additional safety requirements. 
 
Y2K Sensitivity 
 
Since we dont process or repackage any product at the Spokane Distribution Center, no concerns are identified.  The facility will be closed and all processes secured on December 31st and January 1st in any event.  We will conduct a pre-startup safety review prior to our next business day.
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