Chem Lab Products, Inc. - Executive Summary

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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 
 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Chem Lab Products, Inc. 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 regulated substances.  Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. 
 
 
2.    The Stationary Source and the Regulated Substances Handled 
Our facility's primary activities encompass Manufacturing of bleach.  We have one regulated substance present at our facility.  This substance is Chlorine.  The regulated substance  
at our facility Chlorine is used for Manufacturing Bleach. 
 
The maximum inventory of Chlorine at our facility is four Railcars @ 180,000 lbs. for a maximum of 720,000 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 look-up tables and equations provided by EPA's RMP*Comp(TM).  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 from the Railcar in the Bleach Manufacturing.  The scenario involves the release of 180,000 lb. of Chlorine in a gaseous form over 10 minutes.  At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 14 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. 
 
One alter 
native release scenario has been submitted for the toxic substance present in Program 3 processes.   
 
The Alternative Release Scenario for Chlorine involves a release from Railcar in the Bleach Manufacturing process.  The scenario involves the release of 15,000 lb. of Chlorine in a gaseous form over 10 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.6 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.  This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition.  The process at our facility is subject to the OSHA PSM standard under 29 CFR 1910.119.  Our facility is also subject to EPCRA Section 302 notification requirements.    The following sections briefly describe the elements of 
the release prevention program that is in place at our stationary source. 
 
Process Safety Information 
Chem Lab Products, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
 
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 is HAZOP.  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 at least once a year and more frequently as needed.  Any findings related to the hazard analysis are addressed in a timely manner. 
 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Chem Lab Products, Inc. maintains written operating procedures.  These procedures address variou 
s 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 
Chem Lab Products, Inc. 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 once a year and more frequently as needed. Due to the small number of personal involved and their close daily contact training and safety issues are constant parts of the bleach processing operation. 
 
Mechanical Integrity 
Chem Lab Products, Inc. carries out highly 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 a 
nd vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
 
Management of Change 
Written procedures are in place at Chem Lab Products, Inc. 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 as a regular practice at Chem Lab Products, Inc.  These reviews are conducted to confirm that construction, equipment, operating and mai 
ntenance procedures are suitable for safe startup prior to placing equipment into operation. 
 
Compliance Audits 
Chem Lab Products, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP 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. 
 
Incident Investigation 
Chem Lab Products, Inc. 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.  All reports are retained for a minimum of 5 years. 
 
Employee Participation 
Chem Lab Products, Inc. truly believes that process safety management and accident prevention is a team effort.  Company employees are strongly encouraged to expr 
ess 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, a thorough evaluation of safety performance of the contractor is carried out.  Chem Lab Products, Inc. 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 
Chem Lab Products, Inc. has had an excellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, the 
re has been no accidental release during this period. 
 
6.    Emergency Response Plan 
Chem Lab Products, Inc. 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 addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 
 
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.  Additional monitoring and Emergency Shutdown Equipment are some of the major steps we want to take to improve 
safety at our facility.  These changes are expected to be implemented by September 30, 2001.
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