Rinchem Company, Inc. - East Warehouse - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Rinchem Company, Inc. (Rinchem) is totally committed to safety and the implementation of safe procedures. Its committment is exemplified by its overall safety policy which states: "No job is more important than the health and safety of our employees, our communities and the environment." This policy is supported by everyone at Rinchem, but first and foremost by senior management. Rinchem is a member of the National Association of Chemical Distibutors(NACD) and meets or exceeds all aspects of the NACD Responsible Distibution Process program for the safe handling and storage of chemicals. THE FACILITY AND REGULATED SUBSTANCES HANDLED Rinchem's East Albuquerque Chemical Warehouse at 6139 Edith Blvd. NE stores chemicals for the semiconductor industry. There is only one substance regulated under 40 CFR part 68 - 37% hydrochloric acid - that is stored above the threshold quantity at this facility. The hydrochloric acid is not involved with any processes at this location other than handling and storage of closed drums and bottles. Rinchem is located in an industrial part of town with a mixed residential/commercial population nearby. The East Warehouse was built taking into consideration fire codes, building codes and industry standards for warehouses that store hazardous materials. There are many features designed into the building that help to prevent a release of any of the stored substances to the environment such as secondary containment at the docks and dikes in the rooms where the materials are stored. The materials in the warehouse are segregated by hazard class according to the applicable federal and state regulations. WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS The modeling of the worst-case and alternative release scenarios was performed using EPA's RMP COMP program which is a very conservative model. The worst case scenario consists of th e largest vessel in the facility containing the regulated substance releasing all of its contents. This would involve a release from one 55-gallon drum. The passive mitigation systems that are in place at the facility and considered for the modeling of the scenario are the dikes that are in each room of the facility to contain a spill and the fact that the material is delivered right to the building and stored in the building. No product is stored outside. The worst case of the contents of an entire drum being released is very unlikely because of the daily inspections that are performed in the facility to verify that no drums are leaking, and the policy that any release is stopped and then cleaned up immediately upon detection. The alternative release that was modeled was the scenario of a case of four one-gallon bottles of hydrochloric acid being broken as the result of a case being dropped or punctured by a forklift. This scenario was chosen because it would be the most likely situation that could occur. The same mitigation measures that were considered in the worst case scenario of dikes and enclosure in a building were considered. Because releases are cleaned up immediately, the chance of the alternative release having an offsite impact is unlikely. According to the conservative method used to do the modeling of the scenarios, the estimated distance to toxic endpoint for the worst-case scenario is 0.2 miles, and for the alternative release it is 0.1 miles. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The three key elements of Rinchem's release prevention program are (1) compliance with federal and state regulations, (2) engineering controls, and (3) dedication to training and safety. The areas of compliance include: - having an OSHA Process Safety Management Plan for flammables at the facility - having a Hazardous Materials Management Plan - only accepting materials that are in Department of Transportation-approved containers - segregating materials according to their hazard class - having secondary and tertiary containment inside the building and around the facility - limiting access to the facility - performance of daily inspections of the material handling equipment used in the facility The facility is inspected daily to ensure that all operations are running safely and smoothly and to determine if any of the containers in storage are leaking. It is Rinchem's policy that any time a release is detected, the supervisor is notified and it is cleaned up immediately by properly trained technicians. Training is an essential element of Rinchem's prevention program since an informed and trained workforce can prevent most accidents. The training includes classroom and on-the-job training for all new employees as well as annual reviews of the operating procedures with the employees and supervisors who p erform the tasks at the facility. FIVE-YEAR ACCIDENT HISTORY There has never been a reportable accident involving hydrochloric acid at this facility. EMERGENCY RESPONSE PLAN Rinchem has a comprehensive emergency response plan. The plan includes evacuation and notification procedures for the employees of Rinchem and for the public. The facility is included in the written community emergency response plan. Our employees are fully trained to respond to any release related to the materials stored on-site. Rinchem's technicians and supervisors attend annual emergency response refreshers where tabletop drills are performed and facility orientation classes are held where evacuation plans and procedures are reviewed. Facility-wide drills are also performed. PLANNED CHANGES TO IMPROVE SAFETY Rinchem believes that no changes are necessary at this time to address improvement to safety at our facilities. Rinchem's procedures, safety policies, facility design and many oth er preventative measures are adequate to keep its employees, the community and the environment safe. However, we are committed to continue working our corrective action process to monitor and improve the safety of all operations. |