Advance Chemical Distribution, Inc. (N) - Executive Summary

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See Nowata executive summary attachment.EPA RISK MANAGEMENT PROGRAM 
 
ADVANCE CHEMICAL DISTRIBUTION, INC. 
NOWATA, OK. 
EXECUTIVE SUMMARY 
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INTRODUCTION 
 
This Advance Chemical facility is a chemical distribution plant located north of the city of Nowata, Oklahoma.  It is part of the Advance Chemical Distribution, Inc. Business Unit of HCI USA Distribution Companies Inc. headquartered in St. Louis, Missouri.  HCI USA Distribution Companies is a chemical distribution company serving customers with worldwide products, chemicals, and advanced materials. The company ranks among the top 10 chemical distribution firms in North America.  HCI USA Distribution Companies has approximately 1,000 employees at more than 50 facilities in 21 states and Mexico.  HCI USA Distribution Companies may be found at its Web Page: www.hollandchemical.com. 
 
It is the worldwide policy of HCI USA Distribution Companies to design, blend and distribute its products and to handle materials througho 
ut their life cycle in a manner that protects the environment and safeguards employees, customers and the public from unacceptable risk.  
 
Advance participates in the Responsible Distribution Process program of the National Association of Chemical Distributors (NACD). The Community Outreach and Emergency Response Plan of Responsible Distribution Process brings chemical distribution plants and local communities together through communications and cooperative emergency planning.  Advance also participates in the safe handling programs of The Chlorine Institute for which the company has been a member for 15 years.  
 
The HCI Safety Program of the HCI Health, Safety and Environmental Program are designed to prevent fires, explosions and accidental chemical releases. The program requires safety audits, inspection and maintenance programs, and safety training for employees and contract workers. Facilities are encouraged to listen to the concerns of the community and to consider these concerns 
when designing and implementing process safety systems. 
 
 
PLANT DESCRIPTION 
 
This Advance Chemical facility is located one and a half miles north of the city of Nowata in an industrial area.  The facility employs 18 people on a full time basis.  At this facility, Advance repackages Chlorine, stores and handles both Chlorine and Sulfur Dioxide, which are considered hazardous by the Environmental Protection Agency (EPA).  Chlorine has many beneficial uses, some of which include the production of consumer goods such as plastics, pipe, automobile parts, and toys among a few, but Chlorine's main use in this area remains the treatment of waters ensuring safe drinking water for all.  Sulfur Dioxide is also used in the treatment of water among other uses.  The same properties that make these chemicals valuable as a commodity also make it necessary to observe certain safety precautions in handling them to reduce the threat to nearby members of our community as well as to that of the people in  
our company.  It is our policy to adhere to all applicable Federal, State and Local regulations.  
 
 
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Advance Chemical maintains continuous efforts toward constantly improving its community status as a valuable asset to the city of Nowata.  This is accomplished through several special activities along with the company generating a substantial tax base for ongoing improvements for the city, and the county.  
 
One such activity that the company participates in as a member is the Nowata County Local Emergency Planning Committee (LEPC).  This committee in conjunction with other groups is responsible for pre-planning the safety of all citizens within the city, and county during emergencies and natural disasters.  Advance Chemical provides the county LEPC with a meeting place at its facility free of charge.  Company management personnel have conducted meeting topics for LEPC on numerous occasions. Advance has also conducted safety seminars at various locations throughout, Ok 
lahoma, and the surrounding states for over ten years.  These seminars are open to the public and are also free of charge.  The goals of these seminars are to enhance the knowledge of the attendees in the fields of preventing, responding safely to, and controlling emergencies in the event of a release.  Seminar attendees include people from industrial plants, city water and waste treatment plants, emergency response companies, city and county police departments, city and county fire departments, state emergency management agencies, local governments, the news media, interested citizens, and neighbors, among others.              
 
 
ACCIDENT RELEASE & EMERGENCY RESPONSE POLICIES 
 
The Emergency Programs in place at the facility include an: 
 
Emergency Action Plan,  
Fire Prevention Plan, 
Emergency Response Plan, and a 
Transportation Emergency Plan. 
    
Along with these written plans, Advance also maintains a facility organization plan that outlines the responsibilities of each job description  
from top management positions to the newest employee.  The General Manager and the Environmental Coordinator for the mid-west region both maintains an office in the Tulsa area.   Their responsibilities include overseeing the management of environmental, health, and safety programs for the entire company. The Branch Manager of the facility maintains direct responsibility for the plant in conjunction with his staff, the Plant Manager, the Site Safety Officer, and other management employees.   
 
Advance Chemical maintains a close working relationship with local emergency responders.  Emergency responders from the city fire department and third party companies are invited to tour the facility annually in order to gain knowledge of the physical setup of the plant.  This information becomes very valuable during an emergency incident.  The company also maintains a working relationship with area clinics and hospitals in order to be prepared during emergency events of any kind.    
 
 
 
 
 
                                    
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WORST CASE & ALTERNATIVE CASE SCENARIOS 
 
The EPA was mandated by the law to define the Worst Case Scenario (WCS), as an unlikely event: the largest single storage vessel losing all of its contents in 10 minutes.  Advance Chemical's Nowata facility does have off-site consequences to the public and the environment under this law.  
 
Efforts maintained by the facility to prevent such an incident from occurring include several programs.  One basic program is the general housekeeping policy for the entire plant with a special emphasis placed on the storage areas for these containers.  Under this policy, combustible materials, and other products are not allowed to build up or to be stored in the processing or storage areas.  Another important program is implementing the knowledge gained from being a member of The Chlorine Institute for fifteen years. The Institute establishes written pamphlets, and videos among other information to guide facilities in prevention and emergency progr 
ams that cover issues such as processing, handling, storage, and releases of chemicals such as Chlorine.  Along with the numerous training programs from the Institute, the facility also complies with container specifications, inspections, and testing requirements of laws in-acted by the Department of Transportation.  Still other programs such as the NACD's Responsible Distribution Process, and guidance implemented based on EPA's SARA Title III regulations aids the facility in setting-up, and maintaining a more safe plant due to issues like the separation of products within certain areas of the facility.  Programs like these coupled with company policy help to ensure that the possibility of a release of this magnitude would never occur at the facility.   
 
The EPA calls a more likely incident, many of which will have limited or no off-site consequences, an Alternate Release Scenario (ARS).  An ARS for this facility could be a small hose or vessel leak.  For the Nowata facility the ARS wi 
ll have off-site consequences for both Chlorine and Sulfur Dioxide, but would be limited to an area in close proximity to the plant.   
 
The facility maintains emergency equipment specifically designed to be able to stop leaks of Chlorine or Sulfur Dioxide if they occur.  This equipment includes Chlorine Institute approved kits for railcars, ton containers, and cylinders, along with a recovery vessel located at another nearby company facility.  Advance Chemical maintains employees who are trained in the specialized use of this emergency equipment.  
 
 
ACCIDENT PREVENTION PROGRAM & CHEMICAL SPECIFIC ACCIDENT PREVENTION PROGRAM 
 
HCI USA Distribution Co., Inc maintains Health, Safety and Environmental manuals, which contain company policies for Risk Management, Training, Product Stewardship, Community Outreach and Hazard Communication among others.  The manuals also include Emergency Action Plans, Emergency Response Plans, and Transportation Emergency Plans. The facility is also in complian 
ce with the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard which requires careful reviews of the hazards and the safeguards that must be implemented to prevent releases of regulated chemicals.  This facility has 50 years experience in handling chlorine, and 10 years experience in handling sulfur dioxide. 
 
 
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FIVE YEAR ACCIDENT HISTORY 
 
Advance Chemical Distribution, Inc. purchased the existing operations at this site in the early 1990s from an established local distribution company.  The facility has experienced one accidental release involving Chlorine in the past five years.  Other than this incident, Advance has never experienced a release of Chlorine in any magnitude, nor has the plant ever experienced a release of Sulfur Dioxide.   
 
The accidental Chlorine release involved a one ton container that had foreign material trapped between one of the valves and its valve seat.  Once filled, the container was moved to a sto 
rage-observation area where it began to leak about an hour later when internal pressure forced the foreign material out of the valve.  To correct the leak, the container valve was simply closed.  The release occurred inside the plant and caused no injury to company personnel or damage to equipment.  Off-site, the vapors did cause minor damage to vegetation, but did not require the evacuation of nearby neighbors.  Following this incident, Advance has made several changes to the repackaging process  
and has re-trained the operators who rebuilds, inspects and tests the valves use in chlorine service.                            
 
 
EMERGENCY RESPONSE PROGRAM 
 
This facility has emergency plans, which have been coordinated with local fire department and the Local Emergency Planning Committee (LEPC). The branch invites the local fire department; third party emergency response companies, and other  
departments and agencies to joint training events, and to annual plant tours. All of our safety e 
quipment at the plant is Y2K compatible. 
 
Our response plan for chlorine is based upon the Chlorine Institute's Pamphlet 64, Emergency Response Plans for Chlorine Facilities. The emergency response plans for all of our facilities include procedures for notification of the local fire authority and notification of any potentially affected neighbors. 
 
 
PLANNED CHANGES 
 
The Nowata facility has made several changes over the years to enhance the safe repackaging, handling and storage of compressed liquefied gases such as Chlorine and Sulfur Dioxide.  Some of these changes have occurred due to plant inspections based upon information from industrial associations such as The Chlorine Institute and the NACD; still others are based upon internal company policies.  While most of the changes have been accomplished in the past, the company continuously inspects and audits its facility to identify any existing needs.  Currently, the facility is working toward completing a minor project aimed at impr 
oving handling methods deployed when unloading cylinders from trucks, among others.  This project consists of updating portable racks that are used to secure cylinders during the off-loading process.  
 
To continue to improve upon its safety record, Advance Chemical requires all of its facilities to conduct incident investigations, safety compliance audits, continuous training of emergency procedures, and continuous community outreach actions which include: educating and training neighbors, customers, fire departments, and emergency response teams.
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