ULRICH CHEMICAL, INC. - Executive Summary
1. ACCIDENTIAL RELEASE PREVENTION & EMERGENCY RESPONSE POLICIES: We at Ulrich Chemical, Inc. are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidential release prevention program in place that covers areas such as design, installation, operating procedures, maintenance and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely corrdinated with the Jefferson County Local Emergency Planning Committee and the Louisville Fire Department which provides highly trained emergency response personnel to control and mitigate the effects of the release. |
2. THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED: Ulrich's primary activities encompass chemical repackaging, warehousing and distribution. Currently, there are 2 regulated subs
tances present at this facility. These substances are Chlorine and Sulfur Dioxide. At this time, the maximum inventory for Chlorine is 27,850 lbs. and Sulfur Dioxide is 29,250 lbs.. However, due to the nature of our industry, maximum inventory volumes will fluctuate upon customer demand.
3. WORST CASE RELEASE SCENARIO(s) & ALTERNATIVE RELEASE SCENARIO(s): To perform the required offsite consequence analysis for this facility, we have used EPA's RMP*Comp program. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from chlorine. The scenario involves a release of 2000 lbs. of chlorine, in a gaseous form over 10 minutes. Passive mitigation controls such as enclosures have been taken into account in calculating this scenario. Under worst case weather conditions, namely Class F atmospheric stability and 1.5 m/s windspeed, the maximum distanc
e of 0.9 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/l.
The alternative release scenario for chlorine involves a release from a storage container. The scenario involves a gaseous release of 200 lbs. over 60 minutes. Passive mitigation controls such as enclosures have been taken into account in calculating this scenario. The release is also assumed to be controlled by active mitigation measures that include utilization of the chlorine salvage cylinder or emergency A or B kit to mitigate the release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087mg/l is <0.1 miles.
The alternative release scenario for sulfur dioxide involves a release from a storage container. The scenario involves a gaseous release of 200 lbs. over 60 minutes. Passive mitigation controls such as enclosures have been taken into account in calculating this scenario. The release is also assumed to be controlled by active mitigation measures th
at include utilization of sulfur dioxide gasket and the chlorine emergency A or B kit to mitigate the release. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078mg/l is <0.1 miles.
4. THE GENERAL ACCIDENTIAL RELEASE PREVENTION PROGRAM: Our facility has taken all the necessary steps to comply with the accidential release prevention requirements as set forth under 40 CFR Part 68. Chlorine and sulfur dioxide are both subject to OSHA's PSM standard as set forth under 29 CFR 1910.119. The following sections briefly describe the elements of our release prevention program that are in place at this facility.
a). Process Safety Information: Ulrich Chemical, Inc. maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all regulated processes.
b). Process Hazard Analysis: This facility conducts comprehensive studies to ensure that hazards as
sociated with our processes are identified and controlled efficiently. The methodology used to carry out these analysis are the Faulty Tree Analysis and What If techniques. The studies are completed by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every 2 years or prior to the implementation of a process change. Any findings related to the hazard analysis are addressed in a timely manner.
c). Operating Procedures: For the purpose of safely conducting activities within our covered processes, Ulrich Chemical, Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved with the processes.
d). Training: Ulrich Chemi
cal, Inc. has a comprehensive training program in place to ensure that employees involved in operating regulated processes are completely competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every 3 years or more frequently as needed.
e). Mechanical Integrity: Ulrich Chemical, Inc. carries out maintenance checks on process equipment to ensure proper functions. Process equipment examined by the checks include product storage containers and intermediate bulk containers. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training to ensure maintenance is performed correctly. Any equipment deficiencies identified by the maintenance checks are corrected in a safe
and timely manner.
f). Management of Change: Written procedures are in place at Ulrich Chemical, Inc. to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job task are affected by a modification in process conditions are promptly made aware of and trained to deal with the modification.
g). Pre-startup Reviews: Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Ulrich Chemical, Inc.. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
h). Compliance Audits: Ulrich Chemical, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any
corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
i). Incident Investigation: Ulrich Chemical, Inc. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
j). Employee Participation: Ulrich Chemical, Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, in particular, information resulting from process hazard analysis.
s: On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, an evaluation of safety performance of the contractor is carried out. Ulrich Chemical, Inc. has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the applicable procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-Year Accident History: Ulrich Chemical, Inc. has had an excellent record of preventing accidential releases over the last 5 years. Due to our stringent release prevention policies, there have been no accidential release's during this period.
6. Emergency Response Plan: Ulrich Chemical, Inc. has developed an written emergency response plan to deal with the potential for accidential release's of hazardous materials. The plan includes all aspects of emergency
response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response plan.
Jefferson County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.
7. Planned Changes To Improve Safety: At this time, no changes are required at this facility.