Axchem, Inc. - Executive Summary |
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Its current President and vice-president established Axchem, Inc. in 1982. Safety has always been important to Axchem, Inc.; it has become a way of life in our facility. Senior Management commitment to safety is evident by their personal involvement and active participation on our safety committee and at our monthly safety meetings. Annually we invite MIOSHA Health and Safety Divisions to give an informal audit of our facility. With the new information supplied by MIOSHA we revise our policies and programs so they stay in compliance with all applicable Federal and State Regulations. All employees complete a safety orientation before they are assigned a task. All employees shall receive safety training for the equipment and area they will be assigned to work. They shall not be allowed to operate any equipment until this safety training is successfully completed. We require all of our full-time production employees to be Hazwoper trained to the Technician Level. All truck driver s and contractors who enter or perform work for Axchem, Inc. in our facility shall sign in and out as they arrive and depart. They are also required to attend a contractor orientation program, designed to instruct them what to do and where to go in the event of an emergency. Truck drivers who are common carriers making a delivery or a pickup must sign in at our shipping and receiving department before they are unloading or loading. They are also required to sign out before leaving our facility. Axchem, Inc. understands that safety in the workplace results in safety in the community and for the environment. The accidental release prevention and emergency response policy at Axchem, Inc. is covered in detail in our Spill Control and Prevention Plan. One of the most important features about this plan is the fact that all covered processes at Axchem, Inc. are designed in accordance to governing standards to all applicable NFPA, NEC, OSHA-PSM standards and State and Local building ordi nances. The construction materials for these processes are recommended by the chemical manufacturer or at least are compatible with the chemical. The processes have safety features such as level controls, emergency relief valves, rupture discs, check valves, interlocking pumps, a liquid tight dike, mass flow meter, automatic closing heat actuated valve, fail close actuator valves and built-in safety redundancies. The processes also have a scrubber system that will not allow vapors or fumes to escape into the atmosphere. Although these safety features do not prevent accidental releases they shall significantly reduce the potential impact on the community, the environment and our employees. In case of a spill inside our building we have constructed it so it has a floors that are recessed 12 inches in respect to the outside grade and the building is equipped with sump tanks to handle the spilled material. We also can use of Northern A-1 a spill clean-up contractor. Axchem, Inc. is a manufacturer of liquid polymers and specialty chemicals, we also repackage several types of powdered polymers. Presently, our facility handles two chemicals, which appear on the regulated substances list: Dimethylamine and Formaldehyde. The maximum quantity stored at our facility is 8100 gallons and 5965 gallons respectively. The storage tanks capacity is approximately 10% higher than the maximum quantity allowed being stored. In all the following release scenarios I used the OCA Guidance Reference Tables or Equations as a reference. There was not any damage caused to environmental receptors in these scenarios. The public receptor impact shall be minimal because of the great care, planning, equipment and personnel training provided by Axchem, Inc. Axchem, Inc. worst case release scenario of a toxic substance is a liquid spill and vaporization of 60,000 pounds of Formaldehyde. The Formaldehyde storage tanks are located indoors, they are connected to a vapor scrubber system. Th ere are written operating procedures, preventive maintenance programs, enclosures, drains, sumps and our self contained building to ensure that any unlikely release would be contained within our facility. These safety factors prevent the likelihood of a release causing catastrophic impact on public or environmental receptors. Personnel are trained to response quickly in the event of an emergency involving a spill or leak. An alternative release scenario of a toxic substance is a transfer hose failure while unloading Formaldehyde. All trailers, which deliver this product to Axchem, Inc. are designed with excess flow valves, which shall close if the discharge rate out of the hose is to great. This will stop the flow of Formaldehyde from the trailer. There are also written procedures which require the unloading operator to be located in the area, dressed in proper Personal Protective Equipment and ready to react in an emergency situation. The operator shall activate a water sprinkl er system, which will eliminate 50-70% of the vapor released. They will turn on the exhaust fan to eliminate the remaining vapors and neutralize any material before it is disposed of. In this scenario there would be no impact on any public or environmental receptors. Axchem, Inc. worst case release scenario of a flammable substance would be a vapor cloud explosion of 56,000 pounds of Dimethylamine. This storage tank is located outside in a fenced in fire rated dike designed to handle 50% more than the storage tanks capacity. There are written operating procedures, level controls, fail closed actuator valves and preventive maintenance programs to ensure the overall safety of the operation and equipment. A liquid tight dike limits the surface area and thus reduces the release rate. An automatic closing heat-actuated valve prevents the continued flow of liquid in the event of a fire. These factors shall limit the impact caused by a release. An alternative release scenario of a fl ammable substance would be a vapor cloud explosion of 10,000 pounds of Dimethylamine. There are excess flow valves, check valves, a fire rated dike, a fire wall, written operating procedures, preventive maintenance program to ensure the overall safety of the operation and equipment. Axchem, Inc. complies with all MIOSHA standards and regulations regarding health and safety. We are also subject to Process Safety Management under OSHA, and comply with all of its elements. Axchem, Inc. has an extensive training program for our new employees as well as current ones. Safety is stressed as a key component to productivity and quality. All of our processes are designed with operator, community and environmental safety in mind. For our employee's reference, we provide operating procedures at the Production Managers desk and each employee is issued their own copy. All changes that occur to the procedures are covered in detail with the employees at a production meeting. They shall also b e issued a new set of instructions when complete. Axchem, Inc. has been extremely fortunate and has had no significant accidents within the past five years. We believe this is due largely to our training program, employee involvement and equipment selection. We have however had a few minor releases involving Dimethylamine; the largest release was 50 pounds back in March of 1997. In no case has there ever been any onsite or offsite damages or injuries caused by a release of Dimethylamine. To the best of knowledge we have never had a release involving Formaldehyde. The emergency response program at Axchem, Inc. is outlined in detail in our Site Emergency Plan Handbook. I will address a few key elements. First, we have sent a copy of this plan to our Local Emergency Planning Committee (LEPC), Fire and Police Departments. I worked closely with our LEPC when we were developing our Risk Management Plan and I hope to continue working closely with them. This coming year Axchem, Inc. t he Fire Department, the LEPC, and other emergency agencies shall plan a mock disaster to see how we work together as a group. In the event of an emergency the Police and Fire Departments shall acts as the public notification system, going door to door. We also have contacts at a variety of newspapers, radio and television stations to help get the evacuation notification broadcasts to the public. Axchem, Inc. employees, visitors, contractors and truck drivers are notified of an emergency in one of three ways: public address system, alarm or by word of mouth. The chosen method of communication shall depend upon the urgency of the emergency. Once an emergency has been signaled the Site Emergency Coordinator is in charge until the incident is terminated. All of our full time production personnel have been trained how to response in emergencies. They receive 40 hours of Technician level Hazwoper training. In addition, they receive fire extinguisher training, self-contained breathing apparatus training, Hazard Communication training, HazMat DOT Training, Site emergency training and non- routine task training. It is our belief that all this training shall better equip our employees to handle themselves in an emergency. In the future Axchem, Inc. shall provide our employees with state of the art equipment, once it has proven itself in the field. Presently, we our in the process of building another plant and plan to equip this plant as well as our existing plant with continuously monitoring equipment for Dimethylamine and Formaldehyde. We are examining ways to run the batch process using Process Logic Controllers and a computer. We understand the safer our plant is, the safer our employees, community and environment shall stay. Axchem, Inc. shall continue conducting monthly safety meetings and continue to strive to improve in areas such as quality, productivity, health and safety. At Axchem, Inc. we believe safety is accomplished by planning, it is not by accid ent. |