Cominco American, Inc. - Executive Summary

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Program Level 2. 
1.1   Accidental Release Prevention and Emergency Response Policies 
We at Cominco American, Inc. and our operator, Accu Chem Conversion, Inc., are strongly committed to employee, public and environmental safety.  This commitment is inherent to a comprehensive accidental 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 coordinated with Los Angeles County Fire Department, which provides highly trained emergency response personnel to control, and mitigate the effects of the release. 
Our Landlord, Admiral Transportation, Inc., also located at 300 N. Baldwin Park Blvd., City of  Industry, California, is aware of the sulfur dioxide (anhydrous) transload operation.  Dur 
ing actual transfers, Admiral Transportation, Inc. conducts none of their business activities on the back dock area, and the warehouse door at the rear of their #3 Building is closed.  In the event of a release of sulfur dioxide, they have been advised to call 911 immediately. Mr. Carl E. Erb, President of Admiral Transportation, Inc. will receive a copy of this Risk Management Plan (RMP) for review. 
1.2   The Stationary Source and the Regulated Substances Handled 
Our facility's primary activities encompass that of a Railcar Transload Facility.  We have one (1) regulated substance present at our facility.  This substance is Sulfur dioxide (anhydrous).  The regulated substance at our facility is transloaded or transferred from railcar tanker to tanker trucks for local distribution.  A tanker truck gas compressor is used to compress sulfur dioxide vapor to push liquid out of the railcar for unloading.  The liquid and vapor lines are purged by nitrogen before disconnecting the tanker tr 
uck from the railcar. The maximum number of railcar-to-tanker loading operations occurring at any one time would be one (1).  Once delivered to the distribution point, the distributor and/or his customers use the Sulfur dioxide (anhydrous). 
The maximum inventory of Sulfur dioxide (anhydrous) for the transload process at our facility is 300,000 pounds. 
1.3   The Worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario 
To evaluate the worst case scenarios and the alternative release scenario analyses, we have used RMP*Comp Ver. 1.06.  The following paragraphs provide details of the chosen scenarios. 
1.3.1 The Worst Case Release Scenario  
The Worst-Case Release Scenario submitted for Program 2 toxic substances as a class involves a catastrophic release from Railcar Transloading/Transfer.  The scenario involves the release of 300,000 pounds of Sulfur dioxide (anhydrous) 
in a gaseous form over 10 minutes.  Passive mitigation controls such as automatic shut-off valves are also taken into account to calculate the scenario.  Under worst case weather conditions, namely Class F atmospheric stability and 1.5 meters/second (3.4 miles/hour) wind speed, the maximum distance of 19 miles is obtained corresponding to a toxic endpoint of 0.0078 mg/L. 
1.3.2  Alternative Release Scenario 
An alternative release scenario has been submitted for the toxic substance present in Program 2.  The alternative release scenario for Sulfur dioxide (anhydrous) involves a release from Railcar-to-tanker truck transloading.  There is no warehouse storage in the Railcar Transloading/Transfer process.  The scenario involves the release of 300 pounds of Sulfur dioxide (anhydrous) in a gaseous form over 120 minutes.  Passive mitigation controls such as automatic shut-off valves are taken into account to calculate the scenario.   Active mitigation measures that included emergency shutd 
own systems.  Under neutral weather conditions, Wind speed:  3 meters/second (6.7 miles/hour), Stability class D, Air temperature 77 degrees F.  The maximum distance to the toxic endpoint of 0.0078/ mg/L is <0.1 miles; report as 1 mile. 
1.4   The Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements of 40 CFR part 68 of the EPA.  This facility was designed and constructed in accordance with Uniform Building Code (UBC), American Institute of Steel Construction (AISC), American Society of Mechanical Engineers/National Standards Institute (ASME/ANSI), and Department of Transportation (DOT) MC331 Standards. 
The following sections briefly describe the elements of our release prevention program that are in place at our stationary source. 
1.4.1  Process Safety Information 
Cominco American, Inc. and its operator, Accu Chem Conversion, Inc. maintains a det 
ailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with the sulfur dioxide transloading procedures.  
1.4.2  Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The primary methodology used to carry out these analyses results from the Hazard and Operability (HAZOP) Study performed for the equipment and normal operating, startup, shutdown, and emergency procedures for handling sulfur dioxide.  This study was originally developed for a separate facility owned and operated by Cominco.  The operations equipment and procedures are the same.  A team of qualified personnel with expertise in engineering and process operations revalidates the HAZOP Study annually.  Any findings related to the hazard analysis are addressed in a timely manner. 
1.4.3  Operating Procedures 
For the purposes of safely con 
ducting activities within our covered processes, Cominco American, Inc. and its operator, Accu Chem Conversion, 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. 
1.4.4  Training 
Cominco American, Inc. has a comprehensive training program in place to ensure that employees that are operating 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 annually, and more frequently as needed.  Monthly safety meetings are held throughout the year.  Both Cominco 
American, Inc. and its operator, Accu Chem Conversion, Inc, conduct employee training. 
1.4.5  Mechanical Integrity 
Cominco American, Inc. and its operator, Accu Chem Conversion, Inc. carries out highly documented maintenance checks on process equipment to ensure proper functions.  Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
1.4.6  Management of Change 
Written procedures are in place at Cominco American, Inc. and its operator Accu Chem Conversion, Inc. to manage changes in process chemicals, technology, equipment and procedures.  Process operators, mai 
ntenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
1.4.7  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 Cominco American, 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. 
1.4.8  Compliance Audits 
Cominco American, Inc. and its operator, Accu Chem Conversion, 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. 
1.4.9  Incident Investigation 
Cominco American, Inc. and its ope 
rator, Accu Chem Conversion, 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. Reports are retained for a minimum of 5 years. 
1.4.10  Employee Participation 
Cominco American, Inc. and its operator, Accu Chem Conversion, 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 to the RMP rule in particular information resulting from process hazard analyses. 
1.4.11  Contractors 
On occasion, our company hires contractors to conduct specialized maintenance and con 
struction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  Cominco American, Inc. and its operator, Accu Chem Conversion, Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
1.5   Five-year Accident History 
Cominco American, Inc. has had an excellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, there has been only one small accidental release during this period.   
On May 12, 1997 at 2:15 PM, approximately 12 pounds sulfur dioxide leaked during an above ground fill/transfer operation due to incompatibility of seating materials of the pressure relief valves (PRV).  The transfer/fill operation was stopped and then reversed.  The  
safety officer created an evacuation zone.  Took readings to determine air quality.  The sensidyne tube readings were 1-5 ppm before the reverse fill; when completed no readings were found. 
The HazMat specialist confirmed that there was no damage to report.  The PRVs were replaced on the tanks under the supervision of the Health HazMat supervision. 
This resulted in Cominco American changing its policy regarding the replacement of PRV valves.  These valves will be changed during the annual DOT inspections, i.e. external visual and Leak Test. 
1.6   Emergency Response Plan 
Cominco American, Inc. and its operator, Accu Chem Conversion, Inc. has a written emergency response plan to deal with accidental releases 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 p 
roper 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. 
The Los Angeles County Fire Department is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
1.7  Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program.  Some of the major steps we have taken to improve safety at our facility:  Replacement of pressure relief valves (PRV) during the regular annual DOT Inspections, i.e. external visual and Leak Test.  The procedure for hydrostatically testing liquid product transfer hoses was revised on January 29, 1999 to "replace all product hoses after one calendar year of use."  The installation of a windsock to facilitate pe 
rsonnel to escape during an emergency.  These changes have been implemented. 
1.8  Y2K Readiness Disclosure 
Cominco American, Inc. and its operator, Accu Chem Conversion, Inc. has identified Year 2000 impacts, and has evaluated those issues.  We have worked with our suppliers of software, hardware and infrastructure to obtain their plans and schedules for Year 2000-compliant versions of their products. 
We have installed new, state-of-the-art Year 2000-compliant systems.  We are also working with our venders, banks and other critical contacts to ensure that they are prepared for what changes are involved in moving into the 21st century and beyond. 
Safety and the environment will be protected due to the rigid testing and certification processes with which we're working and our Sulfur Dioxide Transload Facility will continue operating without interruption or incident.
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