Uniroyal Chemical Company, Inc - Executive Summary

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                                    EXECUTIVE SUMMARY FOR RISK MANAGEMENT PLAN 
In June of 1996, the U.S. Environmental Protection Agency (EPA) issued regulations requiring all industries handling regulated chemicals above threshold amounts to develop, submit, and make available to the public plans to manage the use and handling of these chemicals. This plan known as the Risk Management Plan has three components. These are listed below with a brief explanation of the requirements. 
Hazard Assessment 
Hazard Assessment describes the potential off-site consequences of a worst case scenario as well as alternate or more likely scenarios involving accidental release of regulated chemicals. This assessment consists of an estimate of potential release quantities and its potential off-site impact on people and the environment. 
Prevention Program 
This section describes Uniroyal Chemical's prog 
ram to identify and prevent accidental releases of regulated chemicals. The program includes several key elements involving: hazard identification, process safety information, training, operating instructions, employee participation, mechanical integrity, management of change, inspections, and work permits. 
Emergency Response Plan 
This section describes actions to be taken in response to an accidental release to protect the employees, the public and the environment. The plan covers procedures for public notification and coordination with community response agencies. 
Uniroyal Chemical Company, Inc.(Uniroyal Chemical ) manufactures specialty organic chemicals and conducts research and product development activities at its 87-acre complex, located on 280 Elm Street, Naugatuck, Connecticut. The facility is bounded by the Naugatuck River on the east, Cherry Street on the west, and the Naugatuck Water Pollution Control Facility on the south. 
Uniroyal Chemical prod 
uces as many as 75 different products at this location which are primarily used as additives in a variety of different applications such as in the manufacture of tires, plastics, petroleum oils and in agriculture. Our products are broadly divided into three categories; Rubber Chemicals including anti-oxidants, accelerators, bonding agents and waxes; Specialty Chemicals including lube oil additives, curatives and polymerization inhibitors; Agricultural Chemicals including miticides.   
At present, 250 full-time employees work at the Naugatuck facility and an additional 600 employees work at the corporate headquarters in Middlebury and the agricultural research station in Bethany. Uniroyal Chemical is a division of Crompton and Knowles Corporation, a $1.8 billion multi-national manufacturer of specialty chemicals, polymers and polymer processing equipment.  
Uniroyal Chemical uses over 120 different raw materials at the Naugatuck facility. Of these, twelve (12) are RMP regulated chemical 
s and three (3) are stored in tanks in quantities above the RMP regulated Threshold Quantities (TQ), requiring Uniroyal Chemical to prepare the Risk Management Plan.  These chemicals are Ethyl Chloride, Carbon Disulfide and Phosphorus Trichloride.    
II. Accidental Release Prevention and Emergency Response Policies 
Uniroyal Chemical considers the health and safety of the public, its employees, and customers and the protection of the environment to be of primary importance in the conduct of its business.  Uniroyal Chemical will meet all applicable laws, regulations, permits and internal requirements. Uniroyal Chemical follows the Environmental, Health and Safety (EHS) Policy adopted by the corporation. Uniroyal Chemical is also committed to the Responsible Care initiative of the Chemical Manufacturers Association. This voluntary initiative guides us to operate our facility in a manner that protects the environment, the health and safety of our employees, and the public. It also guide 
s us to seek public input regarding our products and our operations. With the commitment of every employee at this location to the EHS Policy and to the following Responsible Care Principles, continuous improvement in our environmental, health and safety performance will be achieved. 
7 Make continuous progress toward producing our products while causing no accidents, injuries or harm to the environment; 
7 Publicly report global health, safety and environmental performance; 
7 Lead our company in ethical ways that increasingly benefit society, the economy and the environment; 
7 Seek and incorporate public input regarding our products and operations; 
7 Provide chemicals that can be manufactured, transported, used and disposed of safely; 
7 Make health, safety, the environment and resource conservation critical considerations for all new and existing products and  processes; 
7 Provide information on health or environmental risks and pursue protective measures for employees, the public and  
other key stakeholders; 
7 Work with customers, carriers, suppliers, distributors and contractors to foster the safe use, transport and disposal of chemicals; 
7 Operate our facilities in a manner that protects the environment and the health and safety of our employees and the public; 
7 Support education and research on the health, safety and environmental effects of our products and processes; 
7 Work with others to resolve problems associated with past handling and disposal practices; 
7 Lead in the development of responsible laws, regulations and standards that safeguard the community, workplace and environment; and 
7 Encourage and assist others to adhere to these principals and practices. 
Uniroyal Chemical and the Naugatuck community have had a long and mutually beneficial relationship.  Uniroyal Chemical's roots started in this community in 1904, when it was known as Naugituck Chemical.  Uniroyal Chemical has enjoyed the support of the Naugatuck people and many Uniroyal Chemical empl 
oyees and retirees live in the Borough. 
As part of an effort to have a dialog with the community in an organized and regular manner, Uniroyal Chemical in 1996 started a Community Advisory Panel (CAP). With members from a broad cross-section of the community and Uniroyal Chemical's Naugatuck facility, the CAP has met regularly and discussed various topics of mutual interest including environmental protection. Uniroyal Chemical reviewed the RMP rule as well as its Risk Management Plan with the CAP several times and obtained their valuable input. Uniroyal Chemical also met with the Local Emergency Planning Commission (LEPC) and reviewed the Plan. Uniroyal Chemical arranged for a public meeting to review its RMP with the public, invited the press and placed several advertisements in the local newspapers announcing the public meeting. Uniroyal Chemical prepared a brochure describing the RMP, provided details of off-site consequences, and described Uniroyal Chemical's prevention program and 
the emergency response plan. Uniroyal Chemical met with the public, press and the Town leaders on June 15, 1999 and explained the RMP and answered questions. Copies of this brochure were distributed to the public at the meeting. 
As described earlier, Uniroyal Chemical uses over 120 different raw materials at the Naugatuck facility. Of these, twelve (12) are RMP regulated chemicals** and three (3) are stored in tanks in quantities above the RMP regulated Threshold Quantities (TQ), requiring Uniroyal Chemical to prepare the Risk Management Plan.  These chemicals (shown with asterisks) are Ethyl Chloride, Carbon Disulfide and Phosphorus Trichloride. The twelve RMP chemicals handled at the Naugatuck facility are:     
7 Acetaldehyde 
7 Dimethylamine 
7 Ethyl Chloride* 
7 Isopropylamine 
7 Methane/ Propane 
7 Methylamine 
7 Carbon Disulfide* 
7 Chlorine 
7 Formaldehyde 
7 Hydrochloric acid/ Hydrogen Chloride (anhydrous) 
7 Phosphorus Trichloride* 
7 Propylene Oxide 
** T 
he RMP regulates a total of 140 chemicals. 
Uniroyal Chemical has instituted administrative controls to limit the maximum inventory of all the RMP chemicals handled at this location. Measures have been put in place (through operating procedure, verification of inventory before ordering materials, training of personnel, verification before material is loaded into the storage tanks, etc.) to ensure that the maximum inventory of nine of the twelve chemicals is limited to less than their respective TQs.  The maximum inventory of the remaining three RMP chemicals are also limited to reduce the distance of potential off-site impact caused by a hypothetical accidental release of these chemicals. 
The following is a summary of the results of the Hazard Assessment and Consequence Analysis calculated for hypothetical release incidents involving ethyl chloride (flammable substance) and carbon disulfide (toxic). Uniroyal Chemical used EPA's RMPComp accidental re 
lease model to evaluate the consequence of a worst-case release. An example of a worst-case scenario would be where an accident resulted in the instantaneous release of all the contents of a tank.  An alternate scenario would consist of an incident where a process pipeline gasket or pipe was leaking for 10 minutes before being stopped and repaired. 
Carbon disulfide( CS2) is stored in a 12,000gallon stainless steel storage tank. Up to 126,000 pounds of carbon disulfide could be stored in this tank. As described above, Uniroyal Chemical is limiting the maximum on-site inventory of CS2 to 80,000 pounds. The CS2 storage tank is located underwater inside a concrete dike and the CS2 itself is stored under a water blanket within the storage tank. Any transfer of CS2 from the storage tank to the process area is achieved by the displacement of CS2 with water. These storage and transfer conditions prevent any releases of CS2 into the dike from contacting the outside environment. CS2 is heavier  
than water and any releases of the material from the submerged storage tank and the associated piping would result in the containment water being displaced by the released CS2. The released CS2 would sink to the bottom of the containment dike and be recovered by vacuuming or pumping, with minimal actual emissions to the environment. 
While it is very unlikely that the storage tank would rupture and release all its contents at once, and it is even more unlikely that all the water in the dike (the CS2 storage tank is located underwater) would be drained and not be available to blanket any spilled CS2, Uniroyal Chemical is required to consider this scenario by the regulations and evaluate its consequences. In the unlikely event of such a release, the entire contents of the CS2 storage tank will be contained with in the concrete dike. Additionally, the dike serves to limit the exposed surface area of the spilled material, thus reducing the rate of CS2 release to the environment.  The conse 
quences of a Worst-case and an Alternative Scenario involving a release of CS2 are presented in Table-1. Each of the release scenarios described above (both worst-case and alternative) would result in off-site impacts. 
Ethyl Chloride (EC) is stored under pressure in a steel tank capable of storing 15,000 gallons (112,500 lbs). As described earlier, Uniroyal Chemical is limiting (through administrative controls) the maximum on-site inventory of EC to 70,000 pounds. The EC tank is located with in a concrete dike and the tank system is provided with a water deluge system, which would be automatically deployed if a fire were to occur. The consequences of a Worst-case and an Alternative Scenario involving a release of EC are presented in Table-1. While the quantities involved in a hypothetical worst-case and the alternative release scenarios are the same, the off-site consequence of the releases are very different. This is due to the different atmospheric conditions such as wind speed and  
stability that are applied in the model, as specified by the EPA. 
                                             Release                                                                        Distance  
Chemical                                Scenario                Quantity                                         of Concern 
Carbon                                  Worst-Case            7600gallons(80,000 lbs)                0.9 mi (4,750ft) 
Disulfide                                Alternative              150 gallons(1,575 lbs)                   0.1 mi (530 ft) 
Ethyl                                      Worst-Case            9300gallons(70,000 lbs)                0.25 mi (1,320 ft) 
Chloride                                 Alternative              9300gallons(70,000 lbs)                0.08 mi (425 ft) 
The Phosphorus Trichloride( PCl3) is stored in a specially lined steel tank capable of stor 
ing 8,200 gallons (106,600 lbs).  As described earlier, Uniroyal Chemical is limiting (through administrative controls) the maximum on-site inventory of PCl3 to 80,000 pounds.  The PCl3 tank is located with in a concrete dike. The containment area is capable of containing the entire contents of the tank and serves to limit the exposed surface area of the pool of any spilled material, thus reducing the release rate to the environment.  In addition to the containment dike, the tank, containment dike and the majority of the associated piping are fully enclosed by an air-tight structure that further reduces the release rate of Phosphorous Trichloride to the environment by over 95% for both worst-case and alternative release scenarios. With the construction of the enclosing structure the off-site consequence of a potential PCl3 release has been significantly reduced.     
As mentioned earlier, the regulations require that the worst-case scenario be evaluated.  The worst-case scenario is  
based on very conservative EPA-required guidelines and assumptions.  Although it is extremely unlikely that a Worst-Case situation will occur, it serves to draw attention to the chemicals and how associated risks are managed.  The Alternative Release Scenario is developed by the facility and focuses on a more likely situation.  Current safeguards at Uniroyal Chemical are designed to make the chances of experiencing even the "Alternative Release Scenario" unlikely.   This information is, however, useful in developing our prevention and emergency response plans.   
The Uniroyal Chemical facility in Naugatuck has not had an RMP-defined chemical release in the past five years, and has been handling these chemicals safely at this facility for over 40 years. 
Uniroyal Chemical has practiced incident prevention through safe design and safe practice long before the RMP regulations were issued. 
7 In order to reduce the likelihood of an accidental rel 
ease, our equipment, facilities, and processes are carefully designed, installed, operated and maintained.  
7 To ensure safe operation of the plant we rely upon our employees who are knowledgeable, well trained and equipped.    
7 Process Hazard Analysis (PHA) reviews are conducted on an ongoing basis and specifically before the start-up of a new process. 
7 Our employees are trained in process safety information, operating instructions, internal safety-permit requirements, and management of change (MOC) procedures. This ensures that all employees are well informed and understand their duties. 
7 Our mechanical integrity program includes regular inspections and testing of equipment. This includes visual internal and external inspections, mechanical testing such as pressure testing, ultrasonic and magnetic testing, and preventive maintenance activities such as scheduled safety valve check-up and pump replacements. 
The Uniroyal Chemical facility in Naugatuc 
k has not had an RMP-defined chemical release in the past five years, and has been handling these chemicals safely at this facility for over 40 years. 
Uniroyal Chemical is well prepared for emergencies.  Over the years, we have established a proven Emergency Response Program with a strong partnership with the Naugatuck Emergency Response Service Organizations. 
7 A detailed Emergency Response Plan is in place.  The Plan is reviewed and revised regularly to keep current. 
7 Designated emergency response coordinators are trained and authorized to oversee response activities and coordinate with outside agencies. 
7 An on-site Emergency Response Team consisting of well-equipped, knowledgeable and trained Uniroyal Chemical employees is in place, ready to respond immediately to accidental releases and other incidents. 
7 We maintain a strong partnership with the Naugatuck Fire Department and conduct joint exercises and facility tours. 
In the event of an accidental release, we would control and contain the release in a manner that prevents injury to our employees, the public and the environment.  We would keep the fire department informed and request assistance as required. We would also provide notification to all pertinent agencies.  
Any notification to the public will be made through the Local Emergency Planning Commission (LEPC) / Fire Department. Unless instructed otherwise, in an emergency: 
- Stay indoors and await notification from LEPC 
- Close the windows and shut-off air conditioners to minimize potential exposure 
- Wear full shirts and pants (cover as much skin as practicable).
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