Alco Chemical Div. of National Starch & Chemical C - Executive Summary |
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ALCO CHEMICAL RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies We at Alco Chemical are strongly committed to employee, public and environmental safey. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installlation, operating procedures, maintenance and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent potential releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our faciliy's primary activities encompass water based batch reactions. We have three regulated substances present at our facility. These substances include 1) Carbon Disulf ide, 2) Anhydrous Dimethylamine and 3) Ethylenediamine. Although we receive Anhydrous Dimethylamine, we dissolve it in water prior to transferring it to our storage tank and hence, is no longer in Anhydrous form, thus in a less hazardous form. The regulated substances at our facility are involved in several uses. The primary use of all substances is in producing additives for industrial cooling water treatment for prevention of disease causing bacterium and algae. They are also used to reduce harmful bacterial growth in the sugar manufacturing industry. The maximum inventory of Carbon Disulfide at our facitiy is 556,000 lbs while Anhydrous Dimethylamine is present at our facility in maximum quantity of 430,000 lbs and Ethylenediamine is present in a maximum quantity of 139,000 lbs. These inventory amounts are based upon EPA's definition under "Worst Case Scenario". EPA's definition stipulates that for maximum inventory amount calculations for the "Worst Case Scenario", all v essels and equipment are assumed to be full to the maximum capacity. While in reality, Alco does not keep the inventory to these maximum capacity and the normal inventory of these substances is much lower than the maximum amounts decribed earlier 3. The Worst Case Release Scenarios and the Alternate Case Scenarios including adminstrative control and mitigation measures to limit the distances for each reported scenario: To perform the required offsite consequence analysis for our faciltiy, we have used SLAB models & look up table. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. Our release prevention plan involves both fixed systems and various elements described in OSHA's Process Safety Management standard. All of these are discussed in greater details in Section 4. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps: We have fixed systems such as deluge system, sprinklers, fire monitor nozzles, elevated monitor nozzles, remotely operated nozzles, dikes, and run off collection system. Any or all of these would be activated depending upon the gravity of situation. However, we also have other components to our Prevention Program. These are briefly described below. 4.1 PROCESS SAFETY INFORMATION ----------------------------------------- Alco Chemical maintains a detailed record of safety information that decribes the chemical hazards, operarting parameters and equipment designs associated with covered processes. 4.2 PROCESS HAZARD ANALYSIS -------------------------------------- We conduct comprehensive studies to ensure that hazards associted with our processes are identified and controlled efficiently. The methodolgy used to carry out these analyses is HAZOPS. The studies are undertaken by a team of qualified personnel with expertise in engineering a nd process operations and are revalidated at a regular interval of 5 years. Any findings related to the hazard analysis are addressed in a timely manner. 4.3 OPERATING PROCEDURE ------------------------------- For the purpose of safely conducting activities within our covered processes, Alco Chemical maintains written operating procedures. These procedures address various modes of operation such as initial start up, normal operations, emergency shut down, emergency operations, and normal shut down. Alco Chemical does not use temporary mode of operations. The information is readily accessible to operators involved in the processes. Alco Chemical is an ISO 9001 certified facility. ISO (International Standard Organization) accreditation requires Alco to maintain its operating procedures current and establishes internationally recognized protocols by which Alco conducts its business. As a requirement for maintaining Alco's ISO certification, Alco Chemical reviews its operating procedures on a regular basis. 4.4 TRAINING ----------- Alco Chemical has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. 4.5 MECHANICAL INTEGRITY ------------------------------ Alco Chemical carries out highly documented maintenance inspections on process equipment to ensure proper operations. Process equipment examined by these inspections inlude among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shut down systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices and elements of OSHA's Process Safety Management standard. Furthermore, these personnel are provided specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 4.6 MANAGEMENT OF CHANGE --------------------------- Written procedures are in place at Alco Chemical to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and are trained to deal with the modification. 4.7 PRE-START UP SAFETY REVIEWS ----------------------------------------- Pre-start up safety reviews related to new processes and modifications in established processes are conducted as a regular practice at Alco Chemical. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe start up prior to placing equipment into operation. 4.8 COMPLIANCE AUDITS -------------------------- Alco Chemical conducts audits on r egular basis to determine whether the provisions set out under the OSHA PSM Standard rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 4.9 INCIDENT INVESTIGATION ------------------------------- Alco Chemical promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a substance. These investigations are undertaken to identify the situation leading to the incident as welll as any corrective actions to prevent the release from reoccurring. All reports are maintained for a minimum of 5 years. 4.10 EMPLOYEE PARTICIPATION ---------------------------------- Alco Chemical truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident pre vention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the OSHA PSM Standard rule, including information resulting from process hazard analyses in particular. 4..11 CONTRACTORS ------------------- On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Alco Chemical has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency for response should an accidental release of regulated substance occur. At no time, are contractors allowed to perform non-routine activities such as welding, entering into confined space, and opening process lines without a permit from Alco mainten ance personnel. The permitting procedures require that all safety measures have been taken prior to performing such tasks. 5. Five Year Accident History Alco Chemical has had an excellent record of preventing accidental releases over the last 5 years. We have not had a release reportable under the RMP program. 6. Emergency Response Plan Alco Chemical carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addtion, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. |