General Chemical Corporation - Executive Summary |
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Executive Summary This Risk Management Plan (RMP) is submitted by General Chemical Corporation's Syracuse Works in compliance with the requirements of section 112(r)(7) of the Clean Air Act (CAA) and was prepared in accordance with United States Environmental Protection Agency (USEPA) regulations contained in 40 CFR Part 68, Accidental Release Prevention Provisions. The Accidental Release Prevention program requires the owner of a stationary source having listed substances present in quantities greater than the corresponding threshold quantities to develop and implement a risk management program. The program must consist of a hazard assessment, a release prevention program and an emergency response program. Additionally, the operator must describe the site's risk management program in a risk management plan (RMP). However, the regulation provides for 3 different programs of compliance dependent upon the eligibility criteria of covered processes including, but not limited to, the pot ential impact of chemical releases as identified in the hazard assessment. For example, chemical processes which meet the criteria for program level 1 and program level 2 have very minimal requirements for release prevention programs and emergency response as compared to those for program level 3. At General Chemical's Syracuse Works, one listed chemical, Anhydrous Ammonia, is managed on-site in quantities greater than the threshold quantity under the program level 3 criteria. No chemicals are managed on-site under program level 1 or program level 2 criteria. As identified in this plan, Syracuse Works is in compliance with the requirements of 40 CFR Part 68 for management of Anhydrous Ammonia. This RMP describes Syracuse Work's risk management program which includes a hazard assessment, release prevention program and emergency response program. The hazard assessment includes one worst case release scenario and one alternative case release scenario. The hazard assessment was conduc ted in accordance with 40 CFR Part 68, Subpart B (68.20-68.42), as well as the USEPA's Off-site Consequence Analysis Guidance Document. The release prevention and emergency response programs at this site were developed based on requirements from the CAA's Accidental Release Prevention Provisions as well as OSHA's Process Safety Management standard. This RMP was prepared in accordance with 40 CFR Part 68, Subpart G (68.150-68.190), which provides a format for a written RMP. The required elements of an RMP, as defined by the USEPA, are listed below along with the section in which they are located in this RMP. All information identified in the attached registration form is current as of June 15, 1999. * Section 1.0 - Accidental Release Prevention and Emergency Response Policies * Section 2.0 - Description of Stationary Source and Regulated Substances * Section 3.0 - Hazard Assessment * Section 4.0 - General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps * Section 5.0 - Five Year Accident History * Section 6.0 - Emergency Response Program * Section 7.0 - Planned Changes to Improve Safety 1.0 Accidental Release Prevention and Emergency Response Policies General Chemical Corporation recognizes that the responsible management of health, safety and the environment in and around its facilities is one of its highest corporate priorities and a key element in its successful business strategy. General Chemical Corporation is committed to implementing policies and procedures which ensure that its operations are conducted in compliance with applicable laws and regulations. Achieving responsible health, safety and environmental management will be accomplished by: operating our facilities safely and prudently; efficiently using energy and materials; seeking ways to minimize or reuse wastes; and otherwise complying fully with all applicable local, state, and federal laws and regulations. Our policy is to implement reasonable controls to prevent and/or mitigate foreseeable releases of regulated substances. However, if a release does occur, Syracuse Works has prepared employees in conjunction with local emergency response groups, to respond to a release. 2.0 Description of Stationary Source and Regulated Substances General Chemical's Syracuse Works manufactures Sodium Nitrite. The process of producing Sodium Nitrite requires Anhydrous Ammonia to be used as a raw material. Sodium Nitrite has a broad range of applications. For example, it is used as a corrosion inhibitor, and a meat-curing agent. It is also used in the production of textile dyes, rubber compounds, and charcoal briquettes. Anhydrous Ammonia is received by the Syracuse facility as a pressurized liquid in rail cars and is unloaded into two storage tanks. Each storage tanks contains 12,669 gallons of Anhydrous Ammonia. 3.0 Hazard Assessment USEPA's Accidental Release Prevention Provisions require that General Chemical provide information about th e worst case release scenario and alternative case release scenario for Anhydrous Ammonia handled at its Syracuse Works. The following are brief summaries of these scenarios. 3.1 Worst Case Release Scenario The worst case release scenario as defined by the USEPA is a hypothetical accident for one of the chemicals at a site. It assumes that all safety systems in the facility simultaneously failed and that all of the chemical in the largest container holding it at a site is released in a very short time. An USEPA designated table defines the distance the material will travel until it disperses so much that it is no longer hazardous. The worst case release scenario at General Chemical's Syracuse Works assumes that a rail car containing Anhydrous Ammonia fails. The USEPA requires us to assume that all safety and release prevention systems simultaneously fail, and the contents are released in 10 minutes. The USEPA designated table states that all the material released would travel 4.4 miles before it reaches a non-hazardous concentration. 3.2 Alternative Case Release Scenario The alternative case scenario is a more credible hypothetical, site-specific chemical release. It takes into account safety and release prevention systems and procedures used at the plant to control releases. It is more realistic than the worst case release scenario; is calculated from a USEPA designated table; and, is used to plan a facility's emergency response to accidents. The alternative case release scenario for Anhydrous Ammonia at Syracuse Works assumes Anhydrous Ammonia would be lost due to failure of a transfer hose during the unloading process. It takes into account plant safety systems designed to limit a release. The USEPA designated table states that the material released would travel 0.1 miles before reaching a non-hazardous concentration. 4.0 General Accidental Release Prevention Programs and Chemical - Specific Prevention Steps General Chemical maintains a comp rehensive release prevention program designed to prevent accidental releases and ensure safe operations of our processes. The accidental release prevention program implemented at Syracuse Works includes procedures and practices which address each of the required elements of the risk management program including: * Process Safety Information - Information relating to the hazards of the chemical(s), process technology and equipment information is maintained to ensure proper operation. * Mechanical Integrity - Equipment is routinely inspected and maintenance activities are managed in a manner to maintain the integrity of the equipment. * Process Hazard Analysis - Processes are routinely analyzed to identify and correct potential hazards, as well as increase the safety of the operating conditions. * Standard Operating Procedures - Detailed procedures are in place identifying actions necessary for multiple phases of operation, operating limits and safety considerations. * Employee Par ticipation - Employees at all levels are involved in key roles of the release prevention program. * Training - Employees in the operating process are trained in detail to ensure proper operation of the plant. * Management of Change - Process parameters are maintained through a management of change system which documents the changes as well as evaluates changes for safety. * Pre-startup Safety Review - Significant changes to the processes are evaluated in detail in order to verify that the proper procedures for engineering, operations, emergency response and overall safety are addressed prior to start-up. * Incident Investigation - All incidents are investigated to ensure proper modifications are made to reduce or eliminate the potential for re-occurrence. * Safe Works Practices - Standard safety practices are in place to help insure worker safety including lockout/tagout procedures, control of entry into process areas, line breaking procedures, confined space entry procedures an d hot work procedures. * Contractor Safety - Contractors are evaluated and trained prior to performing work on-site to reduce the potential of an incident. * Compliance Audits - Audits are performed at a minimum of three-year intervals to verify procedures and practices are adequate and are being followed. * Emergency Response - Plans are made with the community emergency response groups as well as on-site emergency response teams to ensure procedures are in place in case an emergency situation occurs. In addition to this general accidental release prevention program, General Chemical's Syracuse Works has taken additional chemical-specific prevention steps designed to perform the following: * quickly detect a release of Anhydrous Ammonia; * contain or control a release of Anhydrous Ammonia; * and/or, reduce the consequences of a release of Anhydrous Ammonia. The following types of safety features are used in various processes: Release Detection * Process temperature and pre ssure controls * Area release detection system with alarms * Operator surveillance of all process areas Release Containment and Control * Pressure relief devices on pressurized storage units and process vessels * Check valves on unloading systems * Automatic and manual shutdown systems on process and unloading equipment Release Mitigation * Emergency shutdown procedures * Fire suppression and extinguishing systems * Deluge system * Trained emergency response personnel * Notification procedures for plant personnel and local officials * Personal protective equipment for emergency response personnel * Emergency Response plans prepared with local emergency response officials 5.0 Five Year Accident History Due to proactive actions taken to prevent accidents and the strong safety culture developed by General Chemical's Syracuse Works, there have been no incidents in the past 5 years that meet the reporting requirements for the USEPA's Accidental Release Prevention Prov isions. 6.0 Emergency Response Program General Chemical's Syracuse Works maintains an integrated contingency plan which consolidates all of the various federal, state and local regulatory requirements for emergency response planning. Our program 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 Onondaga County Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee which is comprised of local government officials, local emergency response officials, and industry representatives. Syracuse Works, the LEPC and local fire departments have coordinated communication to notify the public quickly, if necessary, as well as facilitate quick response to an incident. In addition to periodic LEPC meetings, Syracuse Works conducts periodic emergency response drills that involve emergency response organizations . 7.0 Planned Changes to Improve Safety Syracuse Works performs periodic process hazard analysis to evaluate and to strive continuously to improve health, safety and environmental performance as technical developments, scientific understanding, consumer and community needs, and regulatory requirements evolve and change, some of which result in process modifications. For example, the following improvements are currently planned for Syracuse Works: * Installation of secondary containment for the Anhydrous Ammonia storage units. * Installation of an excess flow valve on the outlet of the Ammonia storage tanks. * Installation of a liquid Ammonia sensor in the vapor line to the compressor to automatically shut down the compressor if liquid is present in the vapor line. 8.0 Certification The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. _______________________________________ Plant Manager |