Chemicals Incorporated - Executive Summary

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RMP Executive Summary 
1. Accidental Release Prevention and Emergency Response Policies 
This facility is regulated under 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response and 29 CFR 1920.38, Employee Emergency Plans and Fire Prevention Plans.  Chemicals Incorporated fully complies with these regulations with employee training and written plans.  Additionally, the facility is a member of Mutual Aid Mont Belvieu, the local emergency response group. 
2. Source and Substances Handled 
Primary Activities: Specialty Chemical Toll Manufacturer 
Use of Substances:  Chlorine used to produce chloro-polyisobutylene; Propylene used to produce tri-isopropyl phenol (a mixture of di- and tri- isomers) 
Chlorine Storage:  30,000 lbs (max) - 15 one ton cylinders 
Propylene Storage:  30,000 lbs (max) - bulk storage tank  (on-site for less than 9 weeks per year) 
3. a. Toxic Worst Case Scenario:  Failure of a single one ton cylinder of chlorine with no emergency response resulting in the com 
plete release of contents over a ten minute period.  The 2,000 pounds would form a vapor cloud with a toxic endpoint radius of 3 miles. 
   b. Toxic Alternative Scenario:  Leak from chlorine feed line resulting in a release rate of 1200 pounds per minute.  The feed from the cylinder would be cut off within one minute.  The 1200 pounds would reach a toxic vapor cloud endpoint radius of 1.3 miles. 
   c. Flammable Worst Case Scenario:  Failure of bulk storage containing 30,000 pounds of propylene resulting in a vapor cloud explosion with a 1 psi over pressure endpoint radius of 0.2 miles. 
   d. Flammable Alternative Scenario:  Leak from propylene feed line resulting in a release rate of 2510 pounds per minute.  The leak would be detected and the feed system cut off within 5 minutes, resulting in 12,550 pounds of propylene being released.  The distance to the 1 psi overpressure from the resulting vapor cloud explosion would be 0.1 miles. 
4. General Accidental Release Prevention Progr 
am and Chemical-Specific Prevention Steps 
Chemicals Incorporated has made accident prevention the number one priority at the facility, and accidental chemical release prevention is a major facet of the accident prevention activities at Chemicals Incorporated. 
Key to the prevention program is comprehensive training of both operations and maintenance personnel. 
Only enough propylene is ordered to finish the short campaign.  This results in having propylene on-site for less than three weeks for each campaign.  These campaigns are run only three times per year at the most.  The storage tank is then completely emptied by purging to the flare system.  Propylene feed lines and valves inspected before every batch.  Replacements are made if needed with no turn around delay. 
Maximum chlorine inventory is kept at one truck load of cylinders plus a one day supply.  A chlorine cylinder repair kit is maintained at the site to handle possible leaks from the cylinders.  Trained chlorine repair personn 
el are on every shift.  All chlorine feed lines and valves are inspected before each batch and replaced if needed with no turn around delay. 
5. Five Year Accident History Summary 
There have been no accidents involving propylene in the 4 years that this facility has been producing tri-isopropyl phenol. 
In early 1999 the chlorination unit used to produce chloro-polyisobutylene failed between the heating jacket and the reactor vessel.  This was caused by an undersized relief valve on the jacket.  While there was no release to the environment, the 6100 gallons of material in the reactor had to be transferred to a holding vessel while repairs were made to the reactor.  No injuries resulted from this incident, and the equipment was repaired and back into production within one week. 
6. Emergency Response Program 
Chemicals Incorporated's Emergency Response Program is tailored to the varied processes inherent to a small specialty chemical toll manufacturer.  The plan rests on response trained 
operators and a 24 hour a day emergency coordinator along with two alternate coordinators to handle notifications and request for response from outside agencies such as MAMB, Barber's Hill Fire Department, and ambulance services. 
Special equipment and personal protective gear is on hand for containing chlorine releases.  Training of employees is conducted to repair any possible leaking chlorine cylinders.  Additionally, the chlorine supplier is available 24 hours to assist in handling ruptured cylinders.  Additionally, the facility has installed a 1.2 million gallon fire water reservoir and associated fire suppression equipment for fire fighting service. 
7. Planned Changes to Improve Safety 
A chloro-polyisobutylene storage tank is planned for installation in early July, 1999.  This will reduce the number of trailers on-site at any one time.
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