Southchem Inc - Executive Summary

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Southchem Inc., Bedford, VA  Executive Summary 
Southchem is a member of National Association of Chemical Distributors and complies with the requirements of the Responsible Distribution Process. 
This facility handles products in closed containers only. No transfere of product is preformed. 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Southchem 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. 
2.    The Stationary Source and the Regulated Substances Handled 
Our facility's primary activities encompass Chemical distribution.  We have 2 regulated substances present at our facility.  These substanc 
es include Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] and Chlorine.  Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] and  Chlorine are only stored for distribution.                                         . 
The maximum inventory of Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] at our facility is 21000.00 lb. while Chlorine is present at our facility in a maximum quantity of 9000.00 lb.. 
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 EPA's RMP*Comp(TM).  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Chlorine.  In this scenario 150 lb. of Chlorine is released.  The toxic liquid released 
is assumed to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to evaporate over 1 minutes.  The released quantity has been limited to 2% of the maximum capacity of the source by a system of administrative controls.  Passive mitigation systems such as dike(s) are also taken into account to calculate the scenario.  These mitigation systems have the effect of limiting the amount and duration of the release.  At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.3 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. 
The alternative release scenario for Chlorine involves a release from Chlorine.  The scenario involves the release of 150 lb. of .  Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to have evaporated after 1 minutes.  Passive mitigation controls such as dike(s) are taken into account to calculate the scenario, havi 
ng the effect of limiting the extent of teh pool.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.2 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 following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
Process Safety Information 
Southchem 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 e 
fficiently.  The methodology used to carry out these analyses is Checklist, HAZOP and Fault Tree.  The studies are undertaken by qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 3 years.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update was performed on 06/01/1999. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Southchem 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 in the processes. 
Southchem 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 every  year and more frequently as needed. 
Mechanical Integrity 
Southchem Inc carries out highly documented maintenance checks on process equipment to ensure proper operations. 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 Southchem Inc to manage changes in process chemicals, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 04/24/1998.  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 wit 
h 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 Southchem 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. 
Compliance Audits 
Southchem Inc conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  The most recent comliance audit was conducted on 06/03/1999.  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 
Southchem 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 
Southchem 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, including information resulting from process hazard analyses in particular. 
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.  Southchem Inc has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informe 
d of all the procedures for emergency response should an accidental release of a regulated substance occur. 
5.    Five-year Accident History 
Southchem Inc has had an excellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, there has been no accidental release during this period. 
6.    Emergency Response Plan 
Southchem 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. 
d County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
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. The National Association of Chemical Distributors requirements of the Responsible Distribution Process which require us to keep Southchem to provide update training and information to its employees to help improve safety at our facility.  
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