Continental Chemical Company - Executive Summary

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1.0 Executive Summary 
This Executive Summary includes a brief summary of the following elements of the Risk Management Plan (RMP) prepared by Continental Chemical Company (CCC), 2175 Acoma Street, Sacramento, California: 
* Accidental release prevention and emergency response policies 
* Stationary source and regulated substances handled 
* Worst-case scenarios and alternative release scenarios including administrative controls and mitigation measures 
* General accidental release prevention program and chemical-specific prevention steps 
* Five-year accident history 
* Emergency response program 
* Planned changes to improve safety 
1.1 Accidental Release Prevention and Emergency Response Policies 
Continental Chemical Company has the following policies in place to prevent or minimize accidental releases and to respond to emergencies: 
* Hazardous materials spill prevention and emergency response plan addresses the procedures to handle releases of chlorine and training of employees. 
* Step-by-step procedures for the following activities involving chlorine: 
- Pre-Startup Safety Review  
- Chlorine Receiving and Shipping including: 
* Daily Tanks Car Checks 
* Connecting/Disconnecting Plant Piping Systems To Tanks Cars 
* Preparing and Filling Cylinders and Containers 
- Chlorine Repackaging 
- Titration of the By-Gas System  
- Emergency Kit Installation for Tanks Cars, Cylinders, and Containers 
* Control measures to be taken in the event of physical contact or airborne exposures. 
* Procedures to ensure the mechanical integrity of systems that handle chlorine that include designating responsibility, inspection and testing, deficiency management, and quality assurance.   
* Quality assurance procedure to evaluate new installations for suitability to the process application and applicability of the PSM/RMP program. 
* All employees involved in receiving, handling, operation or maintenance of chlorine receive initial and annual refresher training.   
* Incident/accident invest 
igation to evaluate and address causes and contributing factors. 
* Lock out/tag out and hot work permit policies and procedures. 
* Accident investigation procedures and documentation. 
1.2    Stationary Source and Regulated Substances 
Chlorine is received and stored onsite as a liquefied compressed gas in tank cars.  Chlorine is displaced from the car using compressed air and is dispensed through a manifold system into two lines for chlorine repackaging and sodium hypochlorite manufacture. 
Maximum Quantity Onsite 
740,000 pounds 
1.3.    Worst-Case Release Scenarios / Alternative Release Scenarios and Administrative Controls and Mitigation Measures 
1.3.1 Worst-Case Release Scenarios 
Use of the look-up tables provided in the USEPA Chlorine Guidance Document for the worst-case scenario (180,000 pound release, 10-minute duration, 1.5 meters per second wind speed, F stability class, urban topography), indicate a toxic endpoint distance of 14 miles. 
1.3.2 A 
lternative Release Scenarios and Administrative Controls and Mitigation Measures 
In the implementation of its Process Safety Management Program for this facility, CCC has performed HAZOPS analyses using the AIChE Guide Word Protocol and evaluated the following scenarios: 
* Human error 
* Vandalism /sabotage 
* Mechanical /electrical failure 
* Physical damage 
* Natural disaster 
* Fire / explosion. 
Use of the look-up tables provided in the USEPA Chlorine Guidance Document for the alternative release scenario (3,000 pound release, 60-minute duration, 3 meters per second wind speed, D stability class, urban topography), indicate a toxic endpoint distance of 0.10 miles.  The HAZOPS analyses were last reviewed in June 1999. 
1.4    General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
CCC is in compliance with the OSHA PSM and RMP regulations.  Specific steps that are key to the CCC prevention program include: 
* Developing and maintaining written Process Safety Infor 
mation identifying workplace chemical and process hazards, equipment used in the process, and technology used in the processes. 
* Developing and maintaining Process Hazard Analysis used to identify potential failure scenarios and conditions of the process and facility that could result in the release of chlorine. 
* Developing and maintaining Operating Procedures that are specifically designed to address the handling and maintenance of materials and equipment associated with direct or indirect use of chlorine. 
* Providing and maintaining Training Programs that are specifically designed to address all operational, maintenance, and emergency aspects of processes associated with the chlorine systems. 
* Developing and maintaining a Pre-Start Up Safety Review of equipment and process associated with the chlorine systems. 
* Developing and maintaining a program that ensures the Mechanical Integrity of equipment associated with the chlorine systems. 
* Developing and maintaining a Hot Work Permi 
t system to address any hot work that may directly or indirectly affect the chlorine systems. 
* Establishing and maintaining a Management of Change program to address any equipment or process changes associated with the chlorine systems. 
* Developing and maintaining an Accident Investigation program that addresses all types of incidents (e.g., actual releases, fires, near occurrences, etc.) in a timely manner in an effort to prevent the reoccurrence of such incidents. 
* Maintaining an Emergency Response capability that can address small quantity releases of chlorine and extinguish incipient fires.  CCC has chemical-specific emergency procedures for chlorine. 
* Establishing and maintaining a comprehensive Injury/Illness Prevention Program in accordance with State of California OSHA regulations.  DOES CCC HAVE ONE???? 
* Ensuring that there is Employee Participation at all levels of the organization (e.g., operators, supervisors, etc.). 
* Establishing an on-going Audit component of the RM 
P that ensures periodic re-evaluation of prevention program elements. 
1.5    Five-year Accident History 
CCC has had no chlorine release incidents since 1995.  
1.6 Emergency Response Program 
CCC has an Emergency Response Plan that addresses: 
* Emergency Response Teams, contact names and phone numbers 
* Local and regional emergency contacts and numbers including governmental agencies 
* Chemical-specific procedures for minor and major releases, fire-fighting procedures, first aid and waste disposal.  Includes health and safety data and levels. 
* General safety rules 
* Response procedures for fire, earthquake and medical emergency. 
* Fire inspection program 
* Delegated responsibilities 
* Identification of spill / clean-up contractors 
* Policies regarding safety meetings and training 
* Agency reporting requirements. 
1.7    Planned Changes to Improve Safety 
CCC intends to make the following changes to improve safety: 
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