Nalco Chemical Company -- Plant 1 - Executive Summary

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Executive Summary 
1.  Accidental Release Prevention and Emergency Response Policies 
    At Nalco Chemical Company, we are committed to operating and maintaining all of our processes in a  
    safe and responsible manner.  We use a combination of accidental release prevention and emergency  
    response planning to help ensure the protection of the environment, the safety of our employees, and  
    the safety of the general public.  As founding members of the local Community Advisory Group, we  
    firmly believe in that we must consider community concerns when conducting our business.  This  
    document provides a brief overview of the comprehensive risk management activities that we have  
    designed and implemented to protect the public, including: 
    + A description of our facility and use of substances regulated by EPA's RMP regulation 
    + A summary of results from our assessment of the potential offsite consequences from accidental  
       chemical releases 
An overview of our accidental release prevention programs 
    + A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 
    + An overview of our emergency response program 
    + An overview of planned improvements at the facility to help prevent accidental chemical releases  
       from occurring and adversely affecting our employees, the public, and the environment 
2.  Stationary Source and Regulated Substances 
    Nalco Chemical Company is the largest provider of water treatment and process chemicals, services  
    and systems in the world.  Our facility produces these chemicals using a variety of raw materials and  
    process operations.  We use the following chemicals that EPA has identified as having the potential to  
    cause significant offsite consequences in the event of a substantial accidental release: 
    Toxic Chemicals 
    + Cyclohexylamine is blended with other chemicals to make corrosion inhibitors. 
    + Epichlorohy 
drin is reacted with dimethylamine to make polymers used in the paper industry. 
    Flammable Chemicals 
    + An aqueous solution of 60% dimethylamine is reacted with epichlorohydrin to make polymers used in  
       the paper industry. 
    Our accidental release prevention programs and our contingency planning efforts help us effectively  
    manage the hazards that are posed to our employees, the public, and the environment by our use of  
    these chemicals. 
3.  Key Offsite Consequence Analysis Scenarios 
    The following are brief summaries of the key offsite consequence analysis scenarios, including  
    information about the key administrative controls and minimization measures to limit the endpoint  
    distances for each scenario: 
    Worst-case Release Scenario:  Regulated Toxic Chemicals 
         Our worst-case release scenario involves the rupture of a full, 10,000 gallon rail car of  
    epichlorohydrin and the failure of all active minimization systems.  The 
spilled material forms a pool in the  
    natural depression near the tracks, and on a warm 970F day, the pool evaporates.  The wind is  
    assumed to be moving slowly through the area at 3.4 mph, which keeps the vapors from rapidly  
    dispersing.  The vapors will affect nearby industrial, commercial, and residential areas, if it is not  
    cleaned up.     
         However, the area is equipped with two automatic, active minimization systems.  The first system is  
    a remote camera that will alert operators in the control room to a spill or other malfunction in the area.   
    Switches in the control room can shut down equipment to mitigate releases.  The second system is an  
    area air-monitoring network of sensors that will directly alert the onsite emergency response team in  
    the event of a release.  Immediate action by plant personnel will minimize the impact on the environment  
    and community.  The onsite emergency response team will notify local business 
es, schools, and  
    outside emergency services to alert the general population to take the proper precautions, if the release  
    will affect offsite areas. 
    Alternate Release Scenarios:  Regulated Toxic Chemicals 
         A more realistic release scenario involves a leak during the transfer of chemicals delivered by truck  
    or railcar, because temporary hose connections must be made each time.  The transfer pump is pooling  
    100 gallons of chemical per minute until plant personnel can shut off the pump.  Meteorological  
    conditions more typical of the Chicago area are fanning the chemical vapors through the area.  These  
    more realistic conditions reduce the affected area from a release of either epichlorohydrin or  
    cyclohexylamine and only affects adjacent industrial businesses, not residential or commercial areas. 
    Worst-case Release Scenario:  Regulated Flammable Chemicals 
         Our worst-case release scenario involving a flammable substance 
is the rupture of a full tank  
    containing 60% dimethylamine.  The entire contents of the tank spill and fill the containment dike.  The  
    wind is moving through the area at a slow 3.4 miles per hour, evaporating the dimethylamine.  Twenty  
    minutes after the spill, the vapors ignite and explose  The froce from the blast will assert an extra  
    pressure of 1 psi affecting nearby industrial areas. 
    Alternate Release Scenario:  Regulated Flammable Chemicals 
         A more realistic release scenario involves a leak during the transfer of chemicals delivered by truck  
    or railcar, when temporary hose connections, which must be made each time, have failed.  The transfer  
    pump is pooling 100 gallons per minute of the dimethylamine solution until plant personnel can don the  
    proper protective equipment and manually shut off the pump.  Despite these minimization efforts, the  
    evaporated vapors explode.  The force from the blast will affect only affects 
adjacent industrial  
    businesses, not residential or commercial areas. 
    We are using this information to help us ensure that our emergency response plan and the community  
    emergency response plan address all reasonable contingency cases. 
4.  General Accidental Release Prevention Program and Chemical Specific Prevention Steps 
    We maintain a number of programs to help prevent accidental releases and ensure safe operation.  The  
    accident prevention programs in place include: 
    + Standard procedures for process operations and maintenance activities. 
    + A review process for every change to ensure safe operation. 
    + Scheduled maintenance, inspections, and audits to prevent releases from malfunctioning equipment. 
    + Investigations of releases, accidents, and near misses to prevent reoccurring incidents. 
    + Communication of the specific hazards of the chemicals to employees. 
    + Proper training for all personnel working directly with hazardous was 
    + Design of buildings to minimize the impact of an explosion. 
    + Barriers around tanks and other equipment to contain catastrophic releases 
    + Periodic testing of the atmospheric levels of chemicals in the plant. 
    + An air monitoring system to alert plant personnel of hazardous chemical releases. 
    + A thorough safety review of an area before welding or other "hot" activities may occur. 
    The elements of our prevention program work together to prevent accidental chemical releases.  Our  
    company and our employees are committed to the standard that these management systems set for the  
    way we do business, and we have specific accountabilities and controls to ensure that we are  
    meeting our own high standards for accident prevention. 
5.  Five Year Accident History 
    We keep records of accidental chemical releases that occur at our facility.  In the past five years, we  
    have not had any accidents involving an RMP covered process that res 
ulted in death, injury,  
    evacuation, sheltering in place, significant property damage, or environmental damage.  For any  
    accident of this nature, we will conduct a formal incident investigation to identify and correct the root  
    causes of the event. 
6.  Emergency Response Program 
    We maintain an integrated contingency plan, which consolidates various federal, state, and local  
    regulatory requirements for emergency response planning.  Our program provides the essential  
    planning and training for effectively protecting workers, the public, and the environment during  
    emergency situations. 
    We ensure our plant is prepared to respond to emergencies through several means: 
    + Maintaining an on site Emergency Response Team trained to respond to fires and chemical releases. 
    + Conducting an annual, comprehensive, emergency simulation that calls upon plant and community  
       emergency response groups to work together during a planned, large-sc 
ale disaster scenario to  
       evaluate capability. 
7.  Planned Changes to Improve Safety 
    The following is a list of improvements that we are planning to implement at the facility to help prevent  
    and/or better respond to accidental chemical releases: 
    + Improved Emergency Response Team Training and Emergency Coordinator Training 
    + Upgrade the foam distribution system in the flammable storage area with filters to improve reliability. 
    + Upgrade the computers for the area air monitoring system. 
    + Upgrade the computers for the central fire alarm system. 
    + Introduce new fire extinguishers specifically designed to fight flammable liquid fires.
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