Hampshire Chemical Corporation - Executive Summary |
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Executive Summary for Hampshire Chemical Corporation, Nashua, New Hampshire Facility 1. Accidental Release Prevention and Emergency Response Policies We at Hampshire Chemical Corporation are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of all substances. We are also coordinated with Nashua Fire & Rescue which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass the production of industrial organic and inorganic chemicals. The Facility falls under North American Industrial Classification (NAICS) 325188 and 325199 and manufactures chelating agents, shampoos, sarcosines, isophorone nitrile and other various organic chemical intermediates, primarily on a batch basis. The facility inclues research and development (R&D) operations dedicated to the development of new products and short-term full-scale production. The plant's entire chemical manufacturing process operations are located at one continguous facility under common ownership and control. The facility operates 24 hours/day for 365 days/yr. We have seven substances regulated by the Risk Management Program. These substances include Hydrocyanic Acid, Formaldehyde (solution), Ammonia (anhydrous), Ethylenediamine, Phosphorus Trichloride , Methylamine (solution) and Ammonia (aqueous). The maximum inventory of Hydrocyanic Acid at our facility is 1,080,800 lbs. The maximum inventory for 44% Formaldehyde solution is 550,573 lbs. The maximum inventory for 40% Methylamine is 268,858 lbs. The maximum inventory for Ethylenediamine is 292,500 lbs. The maximum inventory f or Anhydrous Ammonia is 426,073 lbs. The maximum inventory for 29.4% Aqueous Ammonia is 292,500 lbs. The maximum inventory for Phosphorous Trichloride is 110,818 lbs. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release of Hydrocyanic Acid from the HAMP-ENE 100 - Adiabatic Nitrile Process. In this scenario 115,787 lb. of Hydrocyanic Acid is released from the railcar. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The relea sed quantity is 100% of the maximum capacity of the source. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 16 miles is obtained corresponding to a toxic endpoint of 0.011 mg/L. The alternative release scenario for Anhydrous Ammonia involves a release from Anhydrous Ammonia storage. The scenario involves the release of 8231 lbs. ammonia. The release occurs from a relief valve for a duration of 1 minute. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Anhydrous Ammonia is 1.4 miles. The alternative release scenario for Hydrocyanic Acid involves a release from HAMP-ENE 100 - Adiabatic Nitrile Process. The scenario involves the release of 497 lb. of Hydrocyanid Acid. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 1 minute. The release is also assumed to be controlled by continuously manning the operation. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.011 mg/L of Hydrocyanic Acid is 0.43 miles. The alternative release scenario for Phosphorus Trichloride involves a release from HAMPOSYL-L process. The scenario involves the release of 858 lb. of Phosphorous Trichloride. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 40 minutes. Passive mitigation controls such as dike(s) are taken into account to calculate the scenario. The release is also assumed to be controlled by continuously manning the operation. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.028 mg/L of Phosphorus Trichloride is 0.24 miles. The alternative release scenario for 29.4% Aqueous Ammonia involves a release from Aqueous Ammonia process. The scenario involves the release of 218 lb. of ammonia. Toxic liquid is assumed to be re leased to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by continuously manning the operation. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Aqeuous Ammonia is 0.19 miles. The alternative release scenario for Ethylenediamine involves a release from HAMP-ENE 100 - Adiabatic Nitrile Process. The scenario involves the release of 1206 lb. of Ethylenediamine . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by continuously manning the operation. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.49 mg/L of Ethylenediamine is 0.19 miles. The alternative release scenario for 44% Formaldehyde involves a release from 1,3 PD TA - Nitrile Process. The scenario involves the release of 1800 lbs. of 44% Formaldehyde. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is also assumed to be controlled by continously manning the operation. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.012 mg/L of 44% Formaldehyde is 0.19 miles. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from the Methylamine railcar used in the SARCOSINE - Nitrile Process. In this scenario 150,000 lb. of 40% Methylamine is released. It is assumed that the entire quantity is released and evaporates and the vapor cloud finds an iginition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.28 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 3 flammable substances as a class involves a release from SARCOSINE - Nitrile Process. The release is assumed to result in a pool fire. The scenario involves the release of 1590 lb. of 40% Methylamine in minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 is 0.01 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 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. The following sections briefly describe the elements of the release prevention program that is in place at our facility source. Process Safety Information Hampshire Chemical Corporation maintains a record of safety information that describes the chemical hazards, operating parameters and equipment des igns associated with all processes subject to our Process Safety/Risk Management programs. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses include; Hazard and Operabiltiy Studies, Dow Fire & Explosion Index and Dow Chemical Exposure Index. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years. The most recent PHA/update was performed on 05/20/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, Hampshire Chemical Corporation maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Hampshire Chemical Corporation 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. Refresher training is provided at least every 3 years and more frequently as needed. Mechanical Integrity Hampshire Chemical Corporation carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel trained in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Management of Change Written procedures are in place at Hampshire C hemical Corporation 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 offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted at Hampshire Chemical Corporation. The most recent review was performed on 05/20/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Hampshire Chemical Corporation conducts audits on a regular basis to determine whether the provisions set out under our Process Safety and Risk Management Programs are being implemented. The most recent compliance audit was conducted on 02/09/1998. These audits ar e carried out at least every 3 years and any corrective actions undertaken as required. Incident Investigation Hampshire Chemical Corporation promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. Employee Participation Hampshire Chemical Corporation truly believes that process safety management and accident prevention is a team effort. Company employees participate in hazard analysis and incident investigations and are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, an evaluation of safety performance of the contractor is carried out. Only contractors with acceptable safety performance are approved to perform work at the site. Hampshire Chemical Corporation has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Hampshire Chemical Corproation prioritizes accident prevention to ensure the safety of our operations. These efforts have resulted with the minimization of accidental release in the past five years and the prevention of any impact on the community from any accidental release. There have been 5 accidental releases of regulated substances from our facility within t he last 5 years. The first release took place on 04/24/1995 and involved 114 lb. of Anhydrous Ammonia. There were no known impacts offsite. There was one onsite injury. Another release, of 205 lb. of Anhydrous Ammonia, occurred on 08/27/1997. There were no known impacts either onsite or offsite. Another release, of 434 lb. of Anhydrous Ammonia, occurred on 11/09/1997. There were no known impacts either onsite or offsite. Another release, of 158 lb. of Anhydrous Ammonia, occurred on 06/06/1998. There were no known impacts either onsite or offsite. Another release, of 208 lb. of Anhydrous Ammonia, occurred on 06/12/1998. There were no known impacts either onsite or offsite. 6. Emergency Response Plan Hampshire Chemical Corporation has 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, onsite evacuations and notification of local emer gency response agencies. To ensure proper functioning, we perform quarterly drills of our plan. Our emergency response equipment is regularly inspected and serviced. In addition, the plan is updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Nashua SARA Committee is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Some of the steps we want to take to continue to improve safety at our facilty include: adoption of The Dow Chemical Company's U.S. Area Safety Standards, verification of process safety information for covered process, and efforts to establish a Citizen's Advisory Board. These changes are expected to be implemented by year end 1999. |