Brewer Environmental Industries, LLC - Kahului - Executive Summary |
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a. Accidental Release Prevention and Emergency Response Policies. C. Brewer and Company, Limited, the parent company, issued a policy guide on October 9, 1992 for all subsidiaries to follow. The policy is a commitment to environmental compliance which assigns the responsibility of implementing the policy to the Chief Executive Officer of the company, or designated individual or individuals to ensure compliance. The purpose of the policy is to provide employees with a safe and healthy environment and at the same time protect, preserve and improve the environment. The facility's overall approach to chemical safety begins with the premise that safety is everyone's responsibility. Preventing injuries and incidents is good business and working safely is a condition of employment. Workplace hazards are minimized through preventive measures such as facility and equipment design, purchase of less hazardous products and development of standard operating procedures. Contr ol measures include facility inspections to discover potential problems, employee reports of hazardous conditions through a "Stop Card" program, training and a safety award program. Effective April 1, 1999 a new safety recognition program was established. The program consist of quarterly incentives (the longer a team is accident free, the better the awards) for each team that is accident free. There is a strong senior management commitment to safety and the implementation of safety programs. However, there is an effort to get management more involved in day to day safety activities through participation in "Tailgate" safety meetings and emergency response team activities. b. Stationary Source and Regulated Substance. The Brewer Environmental Industries, LLC - Kahului facility is a 10,000 sq. ft. property leased from Alexander & Baldwin, Inc for the storage of anhydrous ammonia cylinders (Highest quantity is 63,000 lbs. and the average monthly quantity is 15,000 lbs.) and is under the administrative control of the Brewer Environmental Industries, LLC - Waikapu Facility. This site is approximately 3.5 miles from the Waikapu facility. There is no permanent staff at the site. Staff from the Waikapu facility provides the manpower when work is required at this site and for daily check of the facility. The site is located in Kahului, Maui, Hawaii (Tax Map Key: 3-7-11-17 and 19). There is no street address, however, the site is located approximately 50 yards north of the intersection of Hobron Avenue and Amala Place. The facility is surrounded by petroleum storage tanks owned by other companies. 1. Worst Case. The release scenario is the total release of the largest quantity of anhydrous from a one ton cylinder. There is no passive mitigation and the release occurs under the worst weather conditions (F stability, wind speed at 1.5 meters per second). The offsite consequence analysis was conducted for anhydrous a mmonia utilizing the OCA Guidance to determine the distance to the toxic endpoint which is 0.81 mile. There will be impacts on residential population, public and environmental receptors and other commercial operations. There are no administrative or passive mitigation systems to limit the quantity of releases. There are operational procedures for storage and handling of cylinders to minimize the possibility of causing damage to cylinders and making the worst case release unlikely. Active mitigation is the use of large volumes of water directly on the leak and maintain contact until the valve is shut off or until the contents have been discharged and the tank is empty, 2. Alternative Scenario. The alternative scenario of a valve leak was selected because that is the most likely area vulnerable to damage due to dropping or mishandling of a cylinder. There is no passive mitigation and the release conditions selected were D stability class with wind spee d of 3.0 meters per second. The OCA Guidance was used to determine the distance to the toxic endpoint which is 0.06 mile. There is no impact on residential population, public or environmental receptors. There will be an impact on surrounding petroleum storage companies. There are no administrative or passive mitigation systems to limit the quantity of realeases. Active mitigation is the use of water hose streams on the valve leak to enable the employee to shut off the valve or, in situations where leaks cannot be valved off, use of large volume of water directly on the leak until the contents of the tank have been discharged and the tank is empty. d. Accidental Release Prevention Program and Chemical Specific Steps. The facility complies with the OSHA Process Safety Management rule. A process safety management plan was written for the facility which include all of the required elements. Since the process is storage only, the practices important to the prevention program are the proper storage and handling of the anhydrous ammonia cylinders. Proper loading and unloading of cylinders from trucks are very important to prevent cylinders from falling and cause possible damage to the valve area. Training and careful work practices are the key to preventing accidental damage to the cylinders. e. Five Year Accident History. The facility has not experienced any accidents during the past five years. This is understandable because the process is storage only with minimal handling of the cylinders. f. Emergency Response Program. The facility emergency response plan covers both accidental releases and natural disasters. The plan set forth policies and procedures for responding to emergencies and incorporate the following: 1. Personnel roles, lines of authority, training and communication (including notification requirements). 2. Site maps, security and control measures, refuges, evacuation route s and decontamination stations when required. 3. Emergency medical treatment and first aid. 4. Incident command system. 5. Equipment requirements. 6. Hazardous material emergency action checklist. 7. Chemical storage inventory and locations. 8. Hazard assessment information sheet. 9. Fire protection procedures. 10. Levels of emergency conditions and a recovery condition. 11. Check lists for natural disasters such as hurricances, tsunamis, earthquake, and flooding. 12. Resources listing for mutual aid, fire equipment, spill control equipment, shelters, medical providers, services, response contractors, governmental agencies, utility companies and the news media. Emergency response is coordinated with the local fire department who is the primary emergency responder for hazardous material releases. Natural disasters are coordinated with the State and Maui County Civil Defense agencies. Pe rsonnel receive anhydrous ammonia response, HAZWOPER and HAZMAT training. Anhydrous ammonia response and HAZWOPER training are conducted annually and the HAZMAT training is conducted every three years. Monthly safety sessions are held on various work related safety topics at the Waikapu facility. The sessions are generally one hour long. The alert system is basically the use of cellular telephone to inform the fire department and the main office in Waikapu if a release is discovered. The plant superintendent from the Waikapu facility is the Incident Commander and determines the level of emergency condition. The following are the various levels of emergency conditions: Level I is a potential emergency condition which is limited to a confined area and can be controlled by a first responder. Notifications are made to the fire and police departments, the State Department of Health and the U.S. Coast Guard, if the release enters the ocean. Level II is a limited emergency condition which poses a potential threat to life or property within a limited distance and may require evacuation of the surrounding area outside the facility. Notifications are also made to the Oahu and State Civil Defense agencies, the State Department of Land and Natural Resources, the State Department of Transportation, and the U.S. Environmental Protection Agency. Level III is a full emergency situation which pose a severe threat to life and property, requiring expertise of the County, State and Federal Agencies and will probably require large scale evacuation in a large area. Notifications will also include the National Response Center (if the amount of release is over a reportable quantity) and the American Red Cross. g. Planned Changes to Improve Safety. There is no plan to change the present operation primarily because the process is storage with minimal handling of the product. |