Lake River Corporation - Executive Summary |
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The accidental release prevention and emergency response policies at Lake River: Safe workplace practices are considered a condition of employement for all Lake River employees. By upholding the priciples of the Chemical Manufacturing Association (CMA) we exercise Responsible Care facility wide. Our facility and the regulated substance we handle: At our West Warehousing facility, we transfer formaldehdye liquid from tank wagons, into drums. The process is very simple. By utilizing a positive displacement pump and unloading lines, we drum formaldehyde. The Risk Management Provisions of the US EPA Clean Air Act requires facilities handling a regulated substance to list a Worst Case Scenario, and an Alternative Case Scenario to provide nieghboring communities with an off site from a chemical release or accident. Lake River utilized RMP Comp Software to determine the offsite impacts during a Worst Case and an Alternative Case Study. Worst Case Scenario: Utilizing the methodology as described by the US EPA, the off site impact of a complete- instantaneous release of a formaldehyde tank wagon containing 49,000 pounds of formaldehdye would have a circular impact of 0.4 miles. It is important to note the following: The only event that could result in the complete release of a tankwagon of formaldehdye would be that of a tornado or an earthquake. Even during a tornado or an earthquake, the probability of releasing a complete tankwagon load is highly unlikely. US DOT Motor Carrier Classifications require performance testing which should eliminate the shearing or splitting of the shell of a tankwagon. With respect to the RMP rule, we feel that a 0.4 circular impact is accurate. Although Lake River has never had an incident involving formaldehyde, the Lake River Emergency Response Plan requires our Incident Commander to immediately report any substantial release of chemcials to the Local Fire Department, the Local Emergency Planning Committee, and the State Emerge ncy Respsonce Committee. We also have trained responders on site who would take immediate action during the initial phase of a release. Alternative Release Scenario: Since Lake River has never had an incident involving formaldehyde, or any recordable release of a regulated chemical within the last ten years, we looked at the formaldehyde drumming process and conferred with our operators. We came to the conclusion that the most-likely event that could result in a release of formaldehyde would be a line rupture. Utilizing the US EPA RMP Comp Software, and a flow rate of 60 pounds per minute we concluded that a line rupture lasting 1 minute result in the following: 1. A 552 pound release of liquid formaldehyde 2. A release rate to the outside air of .117 pounds per minute 3. An estimated off site circular impact of < 0.1 miles would occur. The 1 minute release time is related to the following: 1. The process is under constant observation. 2. In the event of a release, it would ta ke no more than 1 minute for an operator to stop the release by shutting off the flow valve on the tankwagon. A release impact of <0.1 miles would not impact any off site receptors. The general accidental release prevention program and chemcial-specific prevention steps The formaldehyde drumming process at Lake RIver is a process regulated by the OSHA Process Safety directives. Mechanical Integrity Inspections provide operators with a safety check list. Prior to each drumming campaign, a complete process safety inspection is conducted. All operators understand the physical and chemcial characteristics of the process. Along with the OSHA Process Safety Standard directives, the formaldehyde drumming process is regulated by the US Department of Transportation, the OSHA Hazard Communication directives, and the OSHA Formaldehyde Standard directives. Employees involved with the process must have a thorough understanding of all respective operating procedures. Five year accident his tory: Zero accidents, Zero incidents Emergency Response Plan: The Emergency Reponse Plan is utilized during a release of any chemical at Lake River. Utilizing an Incident Command System, a plant Incident Commander dictates mitgation directives to trained responders, and communicates with local authorities to protect our nieghbors. Annual training is required for all employees. The last training conducted was in December of 1998. With the above listed directives and comments, Lake River respectfully submitts our facilities Risk Management Plan. |