Arch Chemicals, Inc. - Executive Summary |
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At Arch Chemicals, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: o A description of our facility and use of substances regulated by EPA's RMP regulation o A summary of results from our assessment of the potential offsite consequences from accidental chemical releases o An overview of our accidental release prevention programs o A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule o An overview of our emergency response program o An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment o The certifications that EPA's RMP rule requires us to provide o The detailed information (called data elements) about our risk management program SITE BUSINESS Our facility produces various grades of sulfuric acid using sulfur and spent or used acid from customers. In our processes, we use by-product or waste fuels containing the following chemical that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: LIST OF REGULATED CHEMICALS Toxic Chemicals Vinyl Acetate Flammable Chemicals No chemicals handled above threshold quantity Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. RELEASE SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release sce nario and alternative release scenario for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals (Vinyl Acetate) Our worst case scenario is the catastrophic failure of the waste fuels tank. This tank is a nominal 38,000 gallon tank and is contained within a concrete dike. It is assumed that the contents of the tank would be released within 10 minutes. The maximum concentration of vinyl acetate in the waste fuels received at Beaumont is 50%. The estimated exposure distance (distance to ERPG 2 concentration) is 0.5 miles. (The estimated exposure distance before rounding is 0.46 mile.) This could potentially impact public receptors such as residences, Lamar University, and local industries and businesses within the 0.5 mile circle. Alternative Release Scenario - Regulated Toxic Chemicals (Vinyl Acetate) The alternate release scenario for vinyl acetate is a transfer hose failure during the unloading of a waste fuels tank truck. It assumed that 2670 lbs. vinyl acetate would be spilled in a 30 minute period. The estimated exposure distance (ERPG 2 concentration) is 0.10 miles. (The estimated exposure distance before rounding is 0.07 miles.) This should not impact the Lamar University football stadium or basketball arena (Montagne Center) or other off site receptors.However, due to the closeness of the Lamar facilities, they should be considered in emergency planning activities. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. PREVENTION PROGRAM We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: o Process safety information o Process hazard analysis o Operating procedures o Training o Mechanical integrity o Management of change o Pre-startup review o Compliance audits o Incident investigation o Employee participation o Hot work permit o Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: 1. All unloading operations are actively monitored 2. Plant operating personnel perform daily visual inspections of equipment. 3. Plant operating personnel perform weekly leak checks for fugitive emissions from pumps, valves, flanges, etc. 4. The waste fuels tank is located within a secondary containment dike. Tank integrity is checked at least annually by an outside contractor. 5. The waste fuel system is highly automated and will automatically shut down during certain furnace problems or upset conditions. These individual elements of our prevention program work together to prevent accidental chemical releases. Our com pany and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. The Arch Chemical goal is to have ZERO incidents- zero distribution, zero safety, and zero environmental incidents. FIVE YEAR ACCIDENT HISTORY We keep records for all significant incidents that occur at our facility-whether they are safety or environmental release related. The Arch Beaumont facility has had one accidental chemical release involving materials covered under EPA's RMP rule during the past five years: On January 28,1999 an unknown reaction occurred in Tank No. 9 (hazardous waste fuels tank) resulting in a release of 205 pounds of vapor from the tank of which 23% is estimated to be Vinyl Acetate. The Beaumont Fire Department was notified and responded to the event. There were no known injuries or property d amage. As a precaution approximately 60 persons were evacuated from the Lamar University Montagne Center. Arch has implemented measures to prevent a reoccurrance of this Event. EMERGENCY RESPONSE PROGRAM The Arch Beaumont facility has a written emergency response plan which has been updated as of May 12,1999. Our plan provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: 1)Continue to enhance operator training 2)Implement "Goal Is Zero" program for safety and environmental incidents CERTIFICATIONS For RMP covered processes, the undersigned also certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted in this Risk Management Plan is true, accurate, and complete. Signature: K.G.Scroggs Title: Plant Manager Date:6/21/1999 RISK MANAGEMENT DATA ELEMENTS The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: o Registration o Offsite consequence analysis o Five-year accident history o Program 3 prevention program o Emergency response program |