Brewer Environmental Industries, LLC - Puhi - 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 - Puhi facility is located at 3-1480 Kaumualii Highway, Lihue, Hawaii. The facility store pesticides, fertilizers (bulk and bagged) and industrial chemicals such as hydrochloric acid (Highest quantity is 12,000 lb s. and the average monthly quantity is 5,000 lbs.), and chlorine (Highest quantity is 48,000 lbs. and the average monthly quantity is 22,000 lbs.). The products are warehoused and distributed from the facility mainly on the Island of Kauai. The site is owned by C. Brewer and company, Limited and consist of approximately 8 acres. The site is bounded on the north by Kauai Nursery and Landscape, a foliage company, and agricultural land (sugar) to the east, west and south. c. Release Scenarios. 1. Worst Case. The release scenario is the total release of the largest quantity of a one ton chlorine 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 chlorine. The process is storage only and the OCA Guidance was used to determine the distance to the toxic endpoint which is 7.4 miles. There will be o ffsite impact on residential population, and public and environmental receptors. There is no administrative or 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. 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 and is most likely to occur than the worst case scenario. There is no passive mitigation and the release conditions selected were D stability class with wind speed of 3.0 meters per second. The OCA Guidance was used to determine the distance to the toxic endpoint which is 0.74 mile. There will be impact on residential population, but not on public or environmental receptors. Active mitigation is the use of Chlorine Institute Emer gency Kit "A" for 150 lb. cylinders and Chlorine Institute Emergency Kit "B" for one ton cylinders. 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 chlorine cylinders. Dry, isolated and fire proof storage spaces are provided where the temperature of the vicinity of the cylinders never reaches 140 degrees Fahrenheit. 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 no t experienced any accidents during the past five years. This is understandable because the process is storage only with minimal handling of the chlorine 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 routes 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 spill control equipment, shelters, medical providers, support organizations, 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 Kauai County Civil Defense agencies. Personnel receive chlorine response, HAZWOPER and HAZMAT training. Chlorine response and HAZWOPER training are conducted annually and the HAZMAT training is conducted every three years. Weekly tailgate safety meetings are also held covering various safety topics. These meetings are short, 15-20 minute meetings. The alert system is basically the use of interplant buzzer, air horns and messengers. Truck drive rs away from the facility will be contacted by cellular phone. The plant superintendent 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 em ergency 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. Level IV is the recovery and re-entry condition. The facility will cooperate with County, State, and/or Federal public health and medical personnel to determine when it is safe to authorize re-entry into the affected areas. Cleanup activities will be initiated and written reports will be submitted to the appropriate agencies. g. Planned Changes to Improve Safety. There are no plans to change the present operation for chlorine primarily because the process is storage. Chlorine use in the state, especially by swimming pools and sewage treatment plants are being eliminated and substituted with bleach or hypoc hlorite in powdered or tablet form depending on the size of the facility. This will enable Brewer Environmental Industries, LLC to reduce the chlorine inventory. |