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   The All-Pure Chemical Company (APC) is committed to the safety and well being of its employees, neighboring community, and the environment. APC is an active member of the Chlorine Institute, an industry group that develops technology for the safe handling and management of Chlorine, and participates in the Chemical Manufacturers Association Responsible Care initiative. Responsible Care is the industrys effort to reach out and dialogue with the public regarding our environmental, health and safety programs and to receive input from the community  on issues of concern. Our products include chlorine, sodium hypochlorite (bleach), sodium hydroxide (caustic) and sulfur dioxide.  These chemicals provide important benefits in critical applications such as water purification and household disinfectants.  APC's 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 26700 South Banta Road, Tracy, Ca.: 
       Sulfur Dioxide 
   Chlorine is received as a liquid in 90-ton rail cars and repackaged into ton containers and 150 lb. cylinders. It is also used in the manufacture of sodium hypochlorite (bleach). Both chlorine and bleach are used by customers in treating drinking water, wastewater, swimming pool water and industrial water to eliminate and/or prevent growth of harmful organisms in the water. 
   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 Environmental Protection Agency (EPA) has defined the Worst Ca 
se Scenario as the hypothetical rupture and full release of  all contents of the facilities largest storage vessel in 10 minutes, assuming all safeguards have failed, during extremely stable weather conditions.  Our scenario would involve a full 90-ton rail car of chlorine.The EPA has also specified in the RMP rule that each facility must define a specific Alternate or Realistic Scenario that could also have off site impact, based on plant operations. The Realistic Scenarios may be modeled using the actual active and passive mitigation systems that are in place if they are capable of withstanding the event that triggered the release, during typical weather conditions. The realistic scenario selected and modeled for chlorine was the release that would result from a 1/16 pinhole in a pipe containing chlorine or in the fusible plug of a ton container of chlorine.The realistic scenario selected and modeled for sulfur dioxide was the release that would  result from a 1/16 pinhole in a fus 
ible plug of a ton container of sulfur dioxide. All scenarios modeled have offsite impacts. No credit for measures in place to prevent and/or mitigate such a release were taken.. 
   Accidental Release Prevention Program 
   APC has a comprehensive release prevention program meeting RMP Prevention Program and OSHA Process Safety Management (PSM) requirements. We have in place, physical safeguards to prevent a release of chlorine or sulfur dioxide.  We also follow best industry practices for the design and construction of equipment, piping and instrumentation. Our process design includes expansion bottles and/or rupture disks and pressure switches to safeguard against hydrostatic overpressure of equipment and piping. 
   Five year release History 
   A review of the facilities hazardous material handling record for the last 5 years shows that there have been no reportable quantity releases, or smaller quantity releases that would have off-site consequences. 
   Emergency Response 
   APC has a compre 
hensive emergency response program that includes the installation of detection, alarm, shutdown, containment and scrubbing systems to halt and/or mitigate a release. In the unlikely event that a release cannot be controlled completely with these systems, APC has an Emergency 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 San Joaquin Office of Emergency Services in developing its Emergency Response Plan. 
   Safety Improvements 
   APC has over the years undertaken the installation of various detection, alarm and shutdown systems. 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 additional automatic shutdown devices. 
   -  Implementation of various seismic upgrades. 
   - Revision of procedures to incorporate additional safety req 
Y2k Sensitivity 
We are aware and sensitive to the year 2000 software issue.  We have a plan in place to conduct an assessment. However, as an additional precaution, the facility will be closed and all processes secured on December 31st and January 1st and we will conduct a pre-startup safety review prior to our next operating day.
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