ULRICH CHEMICAL, INC. - Executive Summary
1. ACCIDENTIAL RELEASE PREVENTION & EMERGENCY RESPONSE POLICIES: We at Ulrich Chemical, Inc. are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidential release prevention program in place 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, we are completely corrdinated with the Fayette County Local Emergency Planning Committee and the Lexington Fire Department which provides highly trained emergency response personnel to control and mitigate the effects of the release. |
2. THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED: Ulrich's primary activities encompass chemical repackaging, warehousing and distribution. Currently, there are 2 regulated substan
ces present at this facility. These substances are Ethyl Ether and Formaldehyde 37%. The current maximum inventory for Ethyl Ether is 9,376 lbs. and Formaldehyde is 13,689 lbs.. However, due to the nature of our industry, maximum inventory volumes will fluctuate upon customer demand.
3. WORST CASE RELEASE SCENARIO(s) & ALTERNATIVE RELEASE SCENARIO(s): To perform the required offsite consequence analysis for this facility, we have used EPA's RMP*Comp program. 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 formaldehyde. The scenario involves a release of 3000 lbs. of formaldehyde, from a 330 gallon intermediate bulk container (IBC), in a liquid form over 10 minutes. Passive mitigation controls such as enclosures have been taken into account in calculating this scenario. Under worst case weather conditions, namely Class F atmospher
ic stability and 1.5 m/s windspeed, the maximum distance of 0.1 miles is obtained corresponding to a toxic endpoint of 0.012 mg/l.
The alternative release scenario for formaldehyde involves a release from a storage container. The scenario involves a liquid release of 900 lbs. over 5 minutes. Passive mitigation controls such as enclosures have been taken into account in calculating this scenario. The release is assumed to be controlled by active mitigation measures that include absorption of spilled product. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.012 mg/l is 0.1 miles.
The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from ethyl ether. The scenario involves a release of 232 lbs. of ethyl ether from a 55 gallon drum. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity particip
ating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.04 miles is obtained corresponding to a endpoint of 1psi overpressure.
The alternative release scenario for ethyl ether involves a release from a storage container. The scenario involves a liquid release of 115 lbs. over 5 minutes. Passive mitigation controls such as enclosures have been taken into account in calculating this scenario. The release is assumed to be controlled by active mitigation measures that include absorption of spilled product. Under neutral weather conditions, the maximum distance of <0.1 miles is obtained corresponding to an endpoint of 1 psi overpressure.
4. THE GENERAL ACCIDENTIAL RELEASE PREVENTION PROGRAM: Our facility has taken all the necessary steps to comply with the accidential release prevention requirements as set forth under 40 CFR Part 68. Formaldehyde 37% is subject to OSHA's PSM standard as set forth under 29 CFR 1910.119. The follow
ing sections briefly describe the elements of our release prevention program that are in place at this facility.
a). Process Safety Information: Ulrich Chemical, Inc. maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all regulated processes.
b). Process Hazard Analysis: This facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analysis are the Faulty Tree Analysis and What If techniques. The studies are completed by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every 2 years or prior to the implementation of a process change. Any findings related to the hazard analysis are addressed in a timely manner.
c). Operating Procedures: For the purpose of safely conduc
ting activities within our covered processes, Ulrich Chemical, Inc. 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 with the processes.
d). Training: Ulrich Chemical, Inc. has a comprehensive training program in place to ensure that employees involved in operating regulated processes are completely competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every 3 years or more frequently as needed.
e). Mechanical Integrity: Ulrich Chemical, Inc. carries out maintenance checks on process
equipment to ensure proper functions. Process equipment examined by the checks include product storage containers and intermediate bulk containers. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training to ensure maintenance is performed correctly. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
f). Management of Change: Written procedures are in place at Ulrich Chemical, Inc. to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job task are affected by a modification in process conditions are promptly made aware of and trained to deal with the modification.
g). 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 Ulrich Chemical, Inc.. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
h). Compliance Audits: Ulrich Chemical, 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.
i). Incident Investigation: Ulrich Chemical, 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.
j). Employee Participation:
Ulrich Chemical, Inc. truly believes that process safety management and accident prevention is a team effort. Company employees 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, in particular, information resulting from process hazard analysis.
k). 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. Ulrich Chemical, Inc. has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the applicable procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-Year Accident
History: Ulrich Chemical, Inc. has had an excellent record of preventing accidential releases over the last 5 years. Due to our stringent release prevention policies, there have been no accidential release's during this period.
6. Emergency Response Plan: Ulrich Chemical, Inc. has developed an written emergency response plan to deal with the potential for accidential release's 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 plan.
Fayette County is the Local Emergency Planning Committee (LEPC) wi
th which our emergency plan has been coordinated and verified.
7. Planned Changes To Improve Safety: At this time, no changes are required at this facility.