ChemDesign Corporation - Executive Summary |
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ChemDesign Corporation Risk Management Plan Executive Summary June 21, 1999 Accidental Release Prevention and Emergency Response Policies We at ChemDesign Corporation are strongly committed to employee, public and environmental safety. This commitment is the basis of having a comprehensive accidental 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. It is also our policy to maintain an emergency response plan and team capable of responding to and minimizing the effects of any chemical emergency that might occur at the facility. Facility Overview and Regulated Substances Handled ChemDesign Corporation (CDC) is a custom manufacturer of a wide variety of fine organic chemicals with the end uses of our products many and varied. It offers a br oad range of manufacturing flexibility for its customers and produces materials for use by the agricultural, electronics, coatings and other industries. Sales are worldwide. CDC has 12 major buildings located on a 44-acre site. Six of the buildings are devoted to chemical production. Two of the buildings are chemical warehouses. Three of the buildings house a combination of laboratories, general warehouses, administrative offices and maintenance shops. One building contains a wastewater treatment facility. The plant is operated around the clock seven days a week. CDC has three processes containing chlorine in excess of the Environmental Protection Agency's (EPA) Risk Management Program (RMP) threshold quantity. Chlorine is a greenish-yellow gas with a pungent, irritating bleach odor. It is shipped as a liquified compressed gas. Symptoms of chlorine vapor overexposure include the following: Burning of eyes, nose, mouth; lacrimation (discharge of tears), rhinorrhea (discharge of thin nasal mucous); cough, choking, substernal (occurring beneath the sternum) pain; nausea, vomiting; headache, dizziness; syncope (fainting); pulmonary edema (fluid in the lungs that may not manifest itself till hours after the initial exposure); pneumonia; hypoxemia (reduced oxygen in the blood); dermatitis. Severe overexposure may result in death. Liquid chlorine exposure may cause frostbite. Worst Case and Alternative Release Scenarios In CDC's three RMP processes, the chlorine is used directly from the shipping container to avoid making multiple transfers. The shipping container is a Department Of Transportation (DOT) approved steel cylinder containing 2,000 pounds (one ton) of chlorine. One of the processes consists of the storage of up to six 1-ton liquid chlorine cylinders on a steel storage rack outside the Building 16 chemical production building. The second process consists of two 1-ton liquid chlorine cylinders stored on a rack inside an evaporator building lo cated outside one of the chemical production buildings. One cylinder at a time is connected to the evaporator located within the building to convert the liquid chlorine to chlorine gas for use in a chemical production process in one of the chemical production buildings. The third process consists of up to four 1-ton liquid chlorine cylinders on a steel storage rack outside the Building 8 chemical production building. In a worst case scenario accident involving for instance a fire outside a cylinder or collision of a large vehicle with a cylinder, all 2,000 pounds of chlorine within a single cylinder could be released within 10 minutes. Based on the Environmental Protection Agency's (EPA) RMP*Comp computer program, such an accidental release could extend downwind far enough to affect off-site persons or the environment. An alternative release scenario that would be more likely to occur than the worst case scenario could consist of a leak from a 1/16" diameter hole in a chlorine cyl inder or its valve. Based on EPA's RMP*Comp computer program, such a release would not extend downwind far enough to effect off-site persons or the environment. General Accidental Release Prevention Program Due to the nature of constantly changing production capabilities of the custom chemical manufacturing business, a broad range of Federal, State and local regulations governs CDC. All the major OSHA regulations including Process Safety Management, Hazardous Waste Operations and Emergency Response, and Right-To- Know are integral to our efforts to minimize the potential for any chemical incident, not just the "covered" chemical. We also fall under the Environmental Protection Agency's standards for air, water and land protection by compliance with such regulations as the Clean Air Act, RCRA, TSCA and FIFRA to name a few. This site has an employee population of 192 with a staff of four full-time time health, environmental and safety professionals to coordinate efforts in those a reas. Detailed programs are in place to address the needs of process safety, employee safety, employee health, environmental protection, facility and equipment loss and downtime and much more. Key to the process safety efforts, covering both OSHA and EPA requirements and more, is our formal four part pre-startup review of any new process. This program consists of: 1. Development of a Custom Chemical Checklist (CCC) which consists of a documented detailed review of the hazards compared with regulatory requirements; 2. Process Hazard Analysis (PHA) usually consisting of a Hazard and Operability (HAZOP) study by a multi-disciplinary team of employees; 3. Thorough training programs for all operators and maintenance personnel on the operation of the process, it's hazards and methods of minimizing the potential for upset conditions; 4. Pre-Startup inspections to be sure all is in order before any chemicals are introduced to the process. During this process, efforts are made to minimiz e inventory requirements, minimize waste generated, maximize product conversion efficiency and enhance employee and environmental safety. Engineering controls are integral to the operation and are enhanced wherever economically feasible and directly beneficial to the efficiency or safety of the operation. Departments consisting of full time Process Engineers and Process Development Chemists oversee all processes to ensure safe operations. Chemical-Specific Prevention Measures A number of precautions and safety measures are employed to prevent occurrence of the worst case accident. No flammable or combustible materials are stored or located near the cylinders. The evaporator building is constructed of steel, is thermally insulated and is kept closed during chlorine usage. The two storage areas and the evaporator building are protected from large vehicle collisions by concrete-filled metal posts. Only DOT-approved steel cylinders are used. Respirators are worn by employees while connecting or disconnecting cylinders to and from the evaporator. Chlorine cylinder patching and repair kits are readily available near all chlorine processes. Employee members of CDC's emergency response team are trained on the use of the kits. Self-contained breathing apparatus is readily available for emergency use by employees responding to a chlorine leak. Chlorine detectors in the evaporator building and the Building 16 chemical production building sound an audible alarm in the Building 16 chemical production building in the presence of chlorine leaks. The detectors also automatically close an automatic control valve on the evaporator. The steel line connecting the evaporator with the chemical production building is welded to prevent leaks. A caustic scrubber removes any chlorine that vents from the process. The entire site is fenced. The main gate is manned by a security guard around the clock. The site chemical production buildings are manned around the clock. 5-Yea r Accident History There have been no chlorine releases over the last 5 years that have resulted in deaths, injuries or significant property damage on site, or offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency Response Program CDC is located on the border of two municipalities (Fitchburg and Westminster) and as such believes we have a responsibility to both to ensure their safety from upset conditions should they occur at our operations. We work closely with the two fire departments both for training as well as drilling purposes. Both fire departments have detailed and comprehensive emergency notification systems and our internal emergency response plan clearly outlines our means of communicating with these organizations. An on-site employee emergency response team is trained and equipped to handle most spills or releases. An on-site emergency command center is fully equipped with radios and telephones for close c ooperation of our emergency response team with the fire departments in an emergency. Four emergency response drills are conducted each year with the two fire departments. Two weather stations are located on-site to provide immediate information on wind speed and direction. Wind socks installed on several buildings also provide wind direction. Site supervisors are equipped with portable radios. A site public address system allows instant communication with all site employees. A number of site managers, including safety and environmental, are always on-call when off-duty by means of cellular phone and beepers. In the event of a significant chlorine release, our emergency response plan requires that the fire departments be immediately notified of the release, along with the wind speed and direction as indicated on our on-site weather instruments. While the fire departments notify potentially effected downwind residents, businesses and schools, our employee will be instructed by me ans of our on-site gas release siren and our on-site public address system to shelter-in-place in their buildings. The gas release siren is also audible to most neighbors within a half mile of the site. They have been advised by means of a letter and an on-site Safety Fair held on August 21, 1999 what the siren means and how they should respond if they hear it. Our on-site emergency response team is trained to respond to the source of the leak in adequate personal protective equipment and stop it using the chlorine cylinder patch and repair kit. Sheltering-in-place is a proven way of protecting personnel in the path of a gas release. Efficiency of protection is based on how well air is prevented from entering the place of shelter. Sheltering-in-place is accomplished by doing the following as soon as learning of a gas release: * going inside the nearest building * turning off air conditioning and heating * closing all windows and doors * extinguishing any fire in the fireplace an d closing the chimney flue * if in a vehicle, turning off the air conditioning and outside air and closing windows * tuning the radio to a local emergency broadcast station: WEIM 1250 AM * staying indoors and waiting for the "all clear" * if having trouble breathing, placing a wet cloth over the nose and mouth and breathing through it Planned Changes to Improve Safety CDC is constantly evolving new and better ways to enhance our safety programs. Since the date on which the site's RMP plan was originally submitted to EPA (6/21/99), ChemDesign has installed a gas release siren, held a public Safety Fair to discuss the RMP plan, and added one full-time safety professional to its staff. Another safety professional is expected to be added to the staff in early 2000. The maintenance and improvement of safety is an ongoing job at this facility. Training in matters of safety takes place throughout the year. Safety-related recommendations from employees, whether made during formal ses sions like process hazard analyses or made upon observation of a potential hazard, are always considered carefully for implementation. This process is continuous and, even at times when no major process changes are anticipated, existing safety systems and procedures are fine-tuned as a matter of course. Safety, whether of employees, neighbors or the environment, is integral to the way ChemDesign does business. There is no other way. |