PVS CHEMICALS, INC. (ILLINOIS) - Executive Summary |
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1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At PVS Chemicals (IL), we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certification that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility produces Sulfuric Acid, Oleum, Sulfur Dioxide, and Sulfur Trioxide using a variety of chemicals and processing operations. In our process, we produce the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxics Oleum - 966,000 lbs. storage, used as a finished product and in the manufacture of sulfur dioxide Sulfur Dioxide - 1,572,000 lbs. storage, used as a finished product Sulfur Trioxide - 783,525 lbs. storage, used as a finished product Our accidental release prevention programs an d our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 3.0 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario and alternative release scenarios. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals The failure of one storage tank containing 288,000 pounds of sulfur dioxide released over a ten-minute period. The release would potentially impact public and environmental receptors. This scenario does not allow consideration of various process controls such as automatic shutoffs that would limit the duration of the release. Another mitigating system not considered is the Chicago Code required co ntainment dikes that would reduce the surface area of the spill and dramatically reduce the impact distance. Alternative Release Scenarios - Regulated Toxic Chemicals 1. A truck loading hose rupture releasing 667 pounds of oleum over a 1/2 minute period before loader/operator activates the emergency shutdown system that turns off the loading pump and closes the loading valve to prevent further release. The release would potentially impact public and environmental receptors. 2. A truck loading hose rupture releasing 800 pounds of sulfur dioxide over a 1/2 minute period before loader/operator activates the emergency shutdown system that turns off the loading pump and closes the loading valve to prevent further release. The truck being loaded is also equipped with an excess flow valve which would close automatically or be activated by the driver, whichever occurs first. The area of the spill would also be contained within a berm which surrounds the loading area and truck/trai ler. The release would potentially impact public and environmental receptors. 3. A truck loading hose rupture releasing 1190 pounds of sulfur trioxide over a 1/2 minute period before loader/operator activates the emergency shutdown system that turns off the loading pump and closes the loading valve to prevent further release. The release would potentially impact public and environmental receptors. In all of the above alternative release scenarios, 1/2 minute is the maximum estimated response time since loader/operators and drivers must remain within 25 feet of the loading system as required by both DOT regulations and PVS mandatory operating procedures. Loading hoses undergo an extensive inspection process that involves routine, periodic testing and/or replacement. We are using the above scenario information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 4.0 GENERAL ACCIDENTAL RELEASE PR EVENTION PROGRAM & CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of sucessful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup safety review * Compliance audits * Incident investigation * Employee participation * Hot work permits * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: * Operators trained and tested in operating procedures for all chemical processes * Process controls to monitor and maintain chemical processes within specific parameters * Mitigation systems to mimimize potential releases * Monitoring systems including television cameras to alert personnel to potential releases These elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5.0 FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. PVS Chemicals (IL) has not had any accidental chemical releases involving offsite consequences or on-site injuries or damage from materials covered under EPA's RMP rule during the past five years. 6.0 EMERGENCY RESPONSE PROGRAM We maintain a comprehensive contingency plan which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordina te our plan with the community emergency response plan. 7.0 PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: * Area monitors for Sulfur Dioxide detection * Continuous improvement program to evaluate chemical safety and release prevention systems 8.0 CERTIFICATION For certification of this plan as required by EPA's RMP rule, see the certification statement accompanying the diskette. 9.0 RMP DATA ELEMENTS The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: * Registration * Offsite consequence analysis * Five-year accident history * Program 3 prevention programs * Emergency response program |