Brewer Environmental Industries, LLC -Barbers Pt. - 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, more effort is needed by management to get 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 - Barber's Point facility is located at 91-291 Kaomi Loop, Kapolei, Hawaii. The facility store pesticides, fertilizers (bulk and bagged) and industrial chemicals such as hydrochloric acid (Highest quantity is 11, 000 lbs. and average monthly quantity is 1,500 lbs.), chlorine (Highest quantity is 123,000 lbs. and average monthly quantiy is 50,000 lbs.) and anhydrous sulfur dioxide (Highest quantity is 20,000 lbs. and average monthly quantity is 8,000 lbs.). The products are warehoused and distributed from the facility mainly on Oahu as well as throughout the State of Hawaii. The site is leasehold with Campbell Estates being the leaseholder and consist of approximately 6.2 acres. The site is bounded on the north by Chevron Hawaii Refinery, undeveloped parcels to the south and east and the Pacific Ocean and shoreline to the west. c. Release Scenarios. 1. Worst Case. The release scenario is the total release of the largest quantity of the regulated chemical 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 chlorine and anhydrous sulfur dioxide. The process is storage only for both chlorine and anyhydrous sulfur dioxide and are stored in the same type of cylinders. In both cases the OCA Guidance was used to determine the distance to the toxic endpoint which is 5.4 miles. Both cases have offsite 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 is most likely to occur than the worst case scenario, and there is an active mitigation measure that can limit the amount of release. In both cases the OCA Guidance was used to determine the distance to the toxic endpoint. (a) Chlorine. Th e alternative scenario of a valve leak was selected because that is the most likely area vulnerable to damage due to dropping of a cylinder or mishandling of a cylinder. The distance to the endpoint is 0.62 miles. There is no residential population within the distance, however, there are other commercial receptors within the distance. Active mitigation is the use of Chlorine Institute Emergency Kit "A" for 150 lb. cylinders and Chlorine Institute Emergency Kit "B" for one ton cylinders. (b) Anhydrous Sulfur Dioxide. The distance to the endpoint is 0.31 miles. There is no residential population within the distance, however, there are other commercial receptors within the distance. The alternative scenario of a valve leak was selected because that is the only possible area vulnerable to damage from a fall or mishandling of a cylinder. Active mitigation is the use of Chlorine Institute Emergency Kit "B" for one ton cylinders. Anydrous sulfur dioxide one ton cylinders are identical to one ton chlorine cylinders which can accommodate the use of chlorine emergency kits. 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 and anhydrous sulfur dioxide 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 not experienced any accidents during the past five years. This is understandable because the process is storage only with minimal handling of the chlorine and sulfur dioxide 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 sys tem. 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 Oahu Civil Defense agencies. Personnel receive chlorine response, HAZWOPER and HAZMAT training. Chlorine response and HAZWOPER training are conducted annually and the HAZMAT tra ining is conducted every three years. Monthly tailgate safety sessions are held on various safety issues. Since there are only six personnel at the site, the alert system is basically the use of air horns and messenger. Truck drivers 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. Notificat ions 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 City, 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 the 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 are initiated and written reports are submitted to the appropriate agencies. g. Planned Changes to Improve Safety. There are no p lans to change the present operations for chlorine and anhydrous sulfur dioxide, 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 hypochlorite in powdered or tablet form depending on the size of the facility. This will enable Brewer Environmental Industries, LLC to reduce the chlorine inventory. |