Hercules Incorporated - Executive Summary

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Hercules Incorporated is a member of the Chemical Manufacturer's Association and is committed to the principles of Responsible Care.  The Corporate Policy on Safety, Health, and Environment states: "At Hercules, we manufacture specialty chemical products. We do so with full committment to the Chemical Industry's Responsible Care initiative.  In keeping with this committment, we are dedicated to providing a safe and healthful environment for our employees, customers, and communities.  To do this, we are dedicated to and working toward continuous improvement in our operations to prevent pollution, reduce risk, and to enhance safety, health and environmental performance.  By Incorporating these beliefs and attitudes into the way we do things at Hercules, we take a key step forward in minimizing the environmental impact of our operations, satisfying customer needs, and creating shareholder value.   
We will adhere to the following basic principles in managing our business worldwide: 
We will comply with the letter and the spirit of all applicable safety, health, and environmental laws, regulations, and corporate guidelines.  We will define strategic objectives, develop tactical plans, identify clear accountability, provide necessary resourses, and measure our progress on safety, health, and environmental matters on an ongoing basis.  Our planning will consider both our business goals and significant safety, health, and environmental aspects of our products and operations and will work to reduce the adverse impacts.  We will provide for an open dialogue on safety, health, and environmental issues relating to our products and operations with our stakeholders, including shareholders, employees, customers, suppliers, government agencies, and communities.  We will work to continually reduce workplace injuries, incidents with the potential for causing property damage, material loss, or interruption of our business, waste, and releases to the environment.  We will emphasi 
ze product stewardship and advocate its importance to our suppliers, distributors, and customers.  Every Hercules employee, worldwide, has a role to play.  All of us are responsible and accountabile for adhering to the letter and spirit of this policy.  All of us must incorporate safety, health, and environmental considerations into our daily business activities.  It takes a total team effort to truly be a Responsible Care Company." 
Facility Description: 
Hercules is among the world's oldest and largest suppliers of resins and a leading supplier of performance, process, and water treatment solutions to the pulp and paper industry.  The Hercules-Savannah plant has been in operation since 1923. The Savannah plant is a manufacturer of chemical additives to the pulp and paper industry.  For example, epichlorohydrin is used in the production of wet strength resins.  These resins are used in paper towels, napkins, tissues, etc., so that they will not come apart easily when they get wet.  Epi 
chlorohydrin is a raw mateial for the process and  is consumed in the chemical reaction to make the product.  The  plant receives epichlorohydrin primarily in railroad tank cars and occasionally, in tank trucks.  The epichlorohydrin is stored in a single 279,000 pound (30,000 gallon) tank.  The storage tank is provided with containment which drains into the tank containment dike, providing adequate capacity to contain a full railcar.  A water blanket of 4-6 inches is maintained in the storage tank dike to reduce the potential for the release of epichlorohydrin fumes in the event of a spill or leak into the dike.   
Worst Case Scenario:   
The worst case scenario for epichlorohydrin is the catastrophic release of a full storage tank of 100% epichlorohydrin (279,000 lbs) into the containment dike.  The worst case assumes that the entire contents of the tank is release instantaneously.  Only secondary containment is considered in determining the endpoint.  Response by plant personnel and m 
itigating effects of the water blanket in the dike are not considered.  EPA lookup tables predict the fumes will travel 0.38 miles from the release point before the fume concentration in the air will reach 20 ppm which is considered a safe level.  Approximately 240 residents could be potentially affected by this release.  
Alternaitve Case Scenario: 
The alternative case scenario for epichlorohydrin is a release of the maximum charge of 100% epichlorohydrin from the reactor (10,500 pounds) resulting in the formation of an uncontaminated liquid pool.  Release rate is estimated at 40.3 pounds per minute.  EPA lookup tables predict the fumes will travel 0.19 miles from the release point before the fume concentration in the air will reach 20 ppm, which is considered a safe level.  Approximately 50 residents could be affected by this release. 
Accident Prevention: 
We prevent releases by implementing four layers of protection: designing for safety, maintaining our plant, operating safely, and 
auditing our operations.  Best engineering practices are used when designing new systems or modifying existing systems.  A hazards analysis is performed prior to any process or equipment change.  Epichlorohydrin is handled in a closed system.  Concrete dikes provide containment for potential spills from tank storage area, transfer pumps, and railcar unloading. Dry disconnects were installed to eliminate spillage at unloading station.  A water blanket is maintained in the containment dike to reduce vapor releases in the event of a spill.  A sealess transfer pump, leak proof valves, and welded transfer lines reduce the potential for fugitive emissions.  Critical equipment is maintained through the preventative maintainence work order system.  An inert nitrogen purge is used to limit flammability during unloading, storage, and reaction. Only qualified, highly trained operators perform operations, inlcuding unloading of epichlorohydrin tankcars.  Emergency response personnel must also be  
present when epichlorohydrin tankcars or trucks are unloaded.   The operator visually inspects all equipment at startup. Comprehensive leak detection monitoring is conducted quarterly.  Compliance with work instructions is audited under ISO 9000.  A comprehensive Process Hazard Analysis, as required under the OSHA PSM program, is conducted every five years.   
Five Year Accident History: 
In the past five years, the Savannah plant has not had any accidents involving epichlorohydrin that have caused injury or property damage to anyone onsite or offsite.  
Emergency Response Program:  
The Savannah plant has a written emergency response plan that provides step by step procedures for responding to hazardous material emergencies.  The plant maintains a fully equipped in-house Emergency Response Team.  The facility coordinates emergency response matters with the Chatham County Fire Department's Hazmat Team.  Two emergency response contractors, who are knowledgeable of the plant and our operat 
ions, are on call 24 hours a day.  In addition, the plant is an active participant in the LEPC and a mutual support group that includes other industries and agencies in Savannah.  In the event of an emergency, the community would be notified by the plant's neighborhood siren, by teleminder (an automated emergency telephone notification system), by local radio & television, and by the Savannah & Garden City Police Department.  The Shelter-in-Place program will be utilized whenever possible and Savannah Hazmat has provided training to the local community.
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