| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

LDEQ Facility # 22353 
Van Waters & Rogers Inc. is a wholesale chemical distributor serving a number of U.S. industries.  Founded in 1924, VW&R supplies the food industry, chemical compounders, pharmaceuticals, mining, forest products, oil and gas producers, electronics, coatings and many other key industries with the chemical raw materials required to produce or refine products used in numerous end-use markets. 
Van Waters & Rogers Inc. is a member of the National Association of Chemical distributors (NACD) and complies with the Responsible Distribution Process (RDP), an environmental, health and safety improvement initiative. 
Some of the products stored and handled by VW&R are subject to EPA's Risk Management Program rule (40 CFR Part 68).  A key requirement of this rule is the preparation and submission of an RMP Plan, contained herein.  The contents of the RMP Plan ar 
e prescribed by EPA, including this Executive Summary. 
1. Prevention Program for Program 2 
* Safety Information 
* Hazard reveiw 
* Operating Procedures 
* Training 
* Maintenance 
* Compliance Audits 
* Incident Investigation 
2. Emergency Response Approach 
Van Waters & Rogers Inc. has an Emergency Contingency Plan in place.  This Plan is shared with local emergency responders who have access to VW&R facility personnel (and up-to-date phone numbers).  VW&R responds to minor incidents but will call in professional emergency responders in the event of all other incidents. 
VW&R invites and encourages local emergency responders such as the fire department to visit and familiarize themselves with VW&R products and facilities.  Joint emergency exercises are conducted when possible. 
Our facility's primary activities encompass Chemical Repackaging, Storage & Distribution.  We have two reg 
ulated substances above TPQ present at our facility.  The substance are Ammonia Aqueous 30% and Cyclohexylamine. 
Listed below is the way the RMP regulated substances are stored/handled on site and the maximum inventory present at any one time. 
1. Ammonia Aqueous 30% is received in bulk by tank truck and off loaded into a 10,000 gal storage tank. The Ammonia Aqueous is then repackaged into 55 gal and 330 gal containers and moved into storage for distribution to our end use customers. In addition to the repackaging of smaller containers we also load tank trucks from our 10,000 gal storage tank for distribution to our end use customers. The estimated maximum inventory of Ammonia Aqueous 30% onsite at any one time will be 43440 lbs for bulk storage tank and warehouse container storage combined. 
2. Cyclohexylamine is received in bulk by tank truck and transfered from tank truck to 55 gal and 330 gal shipping containers.The containers are  then moved to warehouse storage for distribution 
to our end use customers.The estimated maximum inventory of Cyclohexylamine onsite at any one time will be 75000 lbs combining all containers.   
(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 look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for the Program 2 substance as a class involves a catastrophic release from the RMP substances in inventory onsite. The RMP substance is assumed to be immediately released to form a pool of 1 cm height, from which evaporation takes place.  The entire pool is estimated to have evaporated over 10 minutes. By using Class F atmospheric stability and 1.5 m/s wind speed.  Listed below are  
the maximum distances in miles and the corresponding toxic endpoint of mg/L for the RMP substance inventoried onsite using the above conditions.  RMP COMP software was used to model each scenario. 
WCS and ACS for Aqueous Ammonia 30%  
1. Worse Case Scenario release of 22,440 lbs Ammonia Aqueous 30%, the maximum distance of 0.3 miles is obtained corresponding to a toxic endpoint of .14 mg/L. 
2. Alternate Case Scenario release of 448 lbs Ammonia Aqueous 30%, the maximum distance of <0.1 miles is obtained under normal operating conditions using active mitigation of onsite Emergency Personnel and Equipment.  Atmospheric Class D stability and 3m/s wind speed was used  
WCS and ACS for Cyclohexylamine 
1. Worse Case Scenerio release of 2500 lbs Cyclohexylamine, the maximum distance of 0.1 miles is obtained corresponding to a toxic endpoint of .16mg/L 
2. Alternate Case Scenerio release of 180 lbs Cyclohexylamine ,the maximum distance of 0.1 miles is obtained under normal operating conditio 
ns using active mitigation of onsite Emergency Personnel and Equipment.Atmospheric Class D stability and 3m/s wind speed was used.   
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. 
Safety Information 
Van Waters & Rogers Inc maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Hazard Review 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is the "What-If" technique. The  
studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years.  Any findings related to the hazard analysis are addressed in a timely manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Van Waters & Rogers 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. 
Van Waters & Rogers 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 frequ 
ently as needed. 
Compliance Audits 
Van Waters & Rogers Inc conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  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 
Van Waters & Rogers 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. 
Van Waters and Rogers Inc carries out highly documented maintenance checks on process equipment to ensure proper operations.Process equipment examined by the checks includes among others Storage Tanks,Piping Systems,Relief and Vent Systems,Contr 
ols and Pumps.Maintenance operations are carried out by qualified personel.Any equipment  deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Van Waters & Rogers Inc is dedicated  in all areas to minimize accidents.This facility over the past 5 yrs did have 1 accidental release which had no off site consequences but injured an employee. 
Van Waters & Rogers Inc is 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.  Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control a 
nd mitigate the effects of the release.  We are also completely coordinated with the local Fire Department which provides additional emergency response expertise. 
Van Waters & Rogers 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. 
The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
Signature:    ________________________________________ 
Title:        ________________________________________ 
Date signed:    ________________________________________
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