General Chemical Corporation - Executive Summary |
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Executive Summary This Risk Management Plan (RMP) is submitted by General Chemical Corporation's Delaware Valley Works in compliance with the requirements of section 112(r)(7) of the Clean Air Act (CAA) and was prepared in accordance with United States Environmental Protection Agency (USEPA) regulations contained in 40 CFR Part 68, Accidental Release Prevention Provisions. The Accidental Release Prevention program requires the owner of a stationary source having listed substances present in quantities greater than the corresponding threshold quantities to develop and implement a risk management program. The program must consist of a hazard assessment, a release prevention program and an emergency response program. Additionally, the operator must describe the site's risk management program in a risk management plan (RMP). However, the regulation provides for 3 different programs of compliance dependent upon the eligibility criteria of covered processes including, but not limited to, the potential impact of chemical releases as identified in the hazard assessment. For example, chemical processes which meet the criteria for program level 1 and program level 2 have very minimal requirements for release prevention programs and emergency response as compared to those for program level 3. At General Chemical Delaware Valley Works, five listed chemicals are managed on-site in quantities greater than the threshold quantity under the program level 3 criteria. No chemicals are managed on-site under program 1 or program 2 criteria. The chemicals managed according to program level 3 criteria include Anhydrous Ammonia, Anhydrous Hydrogen Fluoride, Oleum, Methyl Chloride and liquid Sulfur Dioxide. Liquid Sulfur Dioxide is used sparingly and is not maintained on-site at all times. Because liquid Sulfur Dioxide is not currently managed on-site, but may be during the next five years, General Chemical is filing a predictive RMP for future use of liquid Sulfur Dioxide. As identified in this plan, Delaware Valley Works is in compliance with the requirements of 40 CFR Part 68 for management of liquid Sulfur Dioxide, Anhydrous Ammonia, Anhydrous Hydrogen Fluoride, Oleum and Methyl Chloride. This RMP describes Delaware Valley Work's risk management program which includes a hazard assessment, release prevention program and emergency response program. The hazard assessment includes one worst case release scenario and five alternative case release scenarios. The hazard assessment was conducted in accordance with 40 CFR Part 68, Subpart B (68.20-68.42), as well as the USEPA's Off-site Consequence Analysis Guidance Document. The release prevention and emergency response programs at this site were developed based on requirements of the CAA's Accidental Release Prevention Provisions, the OSHA Process Safety Management Standard and the Delaware Extremely Hazardous Substances Regulation. This RMP was prepared in accordance with 40 CFR Part 68, Subpart G ( 68.150-68.190), which provides a format for a written RMP. The required elements of an RMP, as defined by the USEPA, are listed below along with the section in which they are located in this RMP. All information identified in the attached registration form is current as of May 1, 1999. * Section 1.0 - Accidental Release Prevention and Emergency Response Policies * Section 2.0 - Description of Stationary Source and Regulated Substances * Section 3.0 - Hazard Assessment * Section 4.0 - General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps * Section 5.0 - Five Year Accident History * Section 6.0 - Emergency Response Program * Section 7.0 - Planned Changes to Improve Safety 1.0 Accidental Release Prevention and Emergency Response Policies General Chemical Corporation recognizes that the responsible management of health, safety and the environment in and around its facilities is one of its highest corporate priorities and a key element in its successful business strategy. General Chemical Corporation is committed to implementing policies and procedures which ensure that its operations are conducted in compliance with applicable laws and regulations. Achieving responsible health, safety and environmental management will be accomplished by: operating our facilities safely and prudently; efficiently using energy and materials; seeking ways to minimize or reuse wastes; and otherwise complying fully with all applicable local, state, and federal laws and regulations. Our policy is to implement reasonable controls to prevent and/or mitigate foreseeable releases of regulated substances. However, if a release does occur, Delaware Valley Works has prepared employees, in conjunction with local emergency response groups, to respond to a release. 2.0 Description of Stationary Source and Regulated Substances General Chemical's Delaware Valley Works is a complex operation that manufactures specialty and indus trial chemicals. These products include sulfur-based chemicals, fluoborates, sulfuric acid, and other specialty products. Delaware Valley Works occupies 130 acres on the lower Delaware River. It is divided into North and South portions by Philadelphia Pike. The North Plant contains batch reactors used to make specialty chemical products. The South Plant houses the sulfuric acid plant and units for making photo salt products. Support facilities at the plant includes warehouse space, product packaging line, loading and unloading facilities for trucks, and railcars. The plant also contains its own product testing laboratory, as well as research and development facilities. Nine production processes at Delaware Valley Works use one or more of the regulated chemicals identified above. The processes, and associated regulated chemical(s) are outlined below: Process - Potassium Nitrite Production Regulated Chemical - Anhydrous Ammonia Use - Raw material Quantity stored per p rocess (lbs.) - 60,000 Process - Potassium Fluoride/Bifluoride Regulated Chemical - Anhydrous Hydrogen Fluoride Use - Raw Material Quantity stored per process (lbs.) - 430,000 Process - Ammonium Fluoborate Regulated Chemical - Anhydrous Ammonia Use - Raw material Quantity stored per process (lbs.) - 60,000 Process - Oleum Production Regulated Chemical - Oleum Use - Product Quantity stored on site (lbs.) - 6,630,000 Process - Fluosulfonic Acid Production Regulated Chemical - Anhydrous Hydrogen Fluoride, Oleum Use - Raw material, Raw material Quantity stored per process (lbs.) - 540,000, 4,000 Process - Sodium Metabisulfite Production Regulated Chemical - Liquid Sulfur Dioxide (Anhydrous) Use - Raw material Quantity stored per process (lbs.) - 180,000 Process - Ammonium Thiosulfate Production Regulated Chemical - Anhydrous Ammonia Use - Raw material Quantity stored per process (lbs.) - 705,000 Process - Fluoboric Acid Production Regulated Che mical - Anhydrous Hydrogen Fluoride Use - Raw material Quantity stored per process (lbs.) - 150,000 Process Spent Acid Regeneration Regulated Chemical - Methyl Chloride Use - Impurity Quantity stored per process (lbs.) - 56,000 *Liquid Sulfur Dioxide is not maintained on-site at all times and is not currently on-site at the time of this RMP submittal. Liquid Sulfur Dioxide may be brought on-site in the future to supplement raw material requirements. *The Spent Acid regeneration unit serves an essential environmental function for refineries by recycling spent sulfuric acid catalyst used to make blending components for cleaner burning gasoline. Additionally, this unit also serves to regenerate spent acid that contains small concentrations of Methyl Chloride from other processing operations. *The Potassium Fluoride/Bifluoride and Fluoboric Acid processes share the same storage unit for Anhydrous Hydrogen Fluoride. Anhydrous Hydrogen Fluoride is transported on site for t hese processes via rail car. The quantity of Anhydrous Hydrogen Fluoride located on site in rail cars is included as part of the Potassium Fluoride/Bifluoride process. 3.0 Hazard Assessment USEPA's Accidental Release Prevention Provisions require that General Chemical provide information about the worst case release scenario and the five alternative case release scenarios for liquid Sulfur Dioxide, Anhydrous Ammonia, Anhydrous Hydrogen Fluoride, Oleum and Methyl Chloride handled at its Delaware Valley Works. The following are brief summaries of these scenarios. 3.1 Worst Case Release Scenario The worst case release scenario as defined by the USEPA is a hypothetical accident for one of the chemicals at a site. It assumes that all safety systems in the facility simultaneously fails and that all of the chemical in the largest container holding it at a site is released in a very short time. A USEPA-designated table defines the distance the material will travel until i t disperses so much that it is no longer hazardous. The worst case release scenario at General Chemical's Delaware Valley Works assumes that a rail car containing liquid Sulfur Dioxide fails. The USEPA requires us to assume that all safety and release prevention systems fail, and the contents are released in 10 minutes. The USEPA-designated table states that the material released would travel 16 miles before it reaches a non-hazardous concentration. 3.2 Alternative Case Release Scenarios The alternative case scenario is a more credible hypothetical, site-specific chemical release. It takes into account safety and release prevention systems and procedures used at the plant to control releases. It is more realistic than the worst case scenario; is calculated from a USEPA-designated table; and, is used to plan a facility's emergency response to accidents. 3.2.1 The alternative case release scenario for liquid Sulfur Dioxide at Delaware Valley Works assumes liquid Sulfur D ioxide would be lost due to failure of an unloading hose during the transfer process. It takes into account plant safety systems designed to limit a release. The USEPA-designated table states that the material released would travel 1.0 miles before reaching a non-hazardous concentration. 3.2.2 The alternative case release scenario for Anhydrous Hydrogen Fluoride at Delaware Valley Works assumes Anhydrous Hydrogen Fluoride would be lost due to the failure of an unloading hose during the transfer process. It takes into account plant safety systems designed to limit a release. The USEPA-designated table states that the material released would travel 0.43 miles before reaching a non-hazardous concentration. 3.2.3 The alternative case release scenario for Oleum at Delaware Valley Works assumes Oleum would be lost due to failure of a loading line during the transfer process. It takes into account plant safety systems designed to limit a release. The USEPA-designated table states th at the material released would travel 0.25 miles before reaching a non-hazardous concentration. 3.2.4 The alternative case release scenario for Methyl Chloride at Delaware Valley Works assumes Methyl Chloride would be lost due to failure of a Spent Acid unloading hose during the transfer process. It takes into account plant safety systems designed to limit a release. The USEPA-designated table states that the material released would travel 0.10 miles before reaching a non-hazardous concentration. 3.2.5 The alternative case release scenario for Anhydrous Ammonia at Delaware Valley Works assumes Anhydrous Ammonia would be lost due to the failure of an unloading hose during the transfer process. It takes into account plant safety systems designed to limit a release. The USEPA-designated table states that the material released would travel 0.43 miles before reaching a non-hazardous concentration. 4.0 General Accidental Release Prevention Programs and Chemical - Specific Preve ntion Steps General Chemical maintains a comprehensive release prevention program designed to prevent accidental releases and ensure safe operations of our processes. The accidental release prevention program implemented at Delaware Valley Works includes procedures and practices which address each of the required elements of the risk management program including: * Process Safety Information - Information relating to the hazards of the chemical(s), process technology and equipment information is maintained to ensure proper operation. * Mechanical Integrity - Equipment is routinely inspected and maintenance activities are managed in a manner to maintain the integrity of the equipment. * Process Hazard Analysis - Processes are routinely analyzed to identify and correct potential hazards, as well as increase the safety of the operating conditions. * Standard Operating Procedures - Detailed procedures are in place identifying actions necessary for multiple phases of operat ion, operating limits and safety considerations. * Employee Participation - Employees at all levels are involved in key roles of the release prevention program. * Training - Employees in the operating process are trained in detail to ensure proper operation of the plant. * Management of Change - Process parameters are maintained through a management of change system which documents the changes as well as evaluates changes for safety. * Pre-startup Safety Review - Significant changes to the processes are evaluated in detail in order to verify that the proper procedures for engineering, operations, emergency response and overall safety are addressed prior to start-up. * Incident Investigation - All incidents are investigated to ensure proper modifications are made to reduce or eliminate the potential for re-occurrence. * Safe Works Practices - Standard safety practices are in place to help insure worker safety including lockout/tagout procedures, control of entry into process areas, line breaking procedures, confined space entry procedures and hot work procedures. * Contractor Safety - Contractors are evaluated and trained prior to performing work on-site to reduce the potential of an incident. * Compliance Audits - Audits are performed at a minimum of three-year intervals to verify procedures and practices are adequate and are being followed. * Emergency Response - Plans are made with the community emergency response groups as well as on-site emergency response teams to ensure procedures are in place in case an emergency situation occurs. In addition to this general accidental release prevention program, General Chemical's Delaware Valley Works has taken additional chemical-specific prevention steps designed to perform the following: * quickly detect a release of an extremely hazardous substance; * contain or control a release of an extremely hazardous substance; * and/or, reduce the consequences of a release of an extremely h azardous substance. The following types of safety features are used in various processes: Release Detection * Process temperature and pressure controls * Operator surveillance of all process areas * On-line video surveillance * Area monitoring for early detection systems Release Containment and Control * Pressure relief devices on pressurized storage units and process vessels * Secondary containment for storage units * Check valves on unloading systems * Automatic and manual shutdown systems on process equipment Release Mitigation * Emergency shutdown procedures * Deluge systems * Trained emergency response personnel and fire brigade on-site * Notification procedures for plant personnel and local officials * Personal protective equipment for emergency response personnel * Emergency Response plans prepared with local emergency response officials 5.0 The Five Year Accident History Due to proactive actions taken to prevent acci dents and the strong safety culture developed by General Chemical's Delaware Valley Works, there have been no incidents in the past 5 years that meet the reporting requirements for the USEPA's Accidental Release Prevention Provisions. 6.0 Emergency Response Program General Chemical's Delaware Valley Works maintains an integrated contingency plan which consolidates all of the 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. Furthermore, we coordinate our plan with the Delaware County (PA) and New Castle County (DE) Local Emergency Planning Commissions (LEPCs). This coordination includes periodic meetings of the committees which are comprised of local government officials, local emergency response officials, and industry representatives. Delaware Valley Works, the LEPCs and the loc al fire departments have coordinated communication to notify the public quickly, if necessary, as well as facilitate quick response to an incident. In addition to periodic committee meetings, Delaware Valley Works conducts periodic emergency response drills that involve emergency response organizations. 7.0 Planned Changes to Improve Safety Delaware Valley Works performs periodic process hazard analysis to evaluate and to strive continuously to improve health, safety and environmental performance as technical developments, scientific understanding, consumer and community needs, and regulatory requirements evolve and change, some of which result in process modifications. For example, the following improvements are currently planned for Delaware Valley Works: * Installation of valves which are remotely operated by an operator and also triggered automatically under certain conditions for Hydrogen Fluoride unloading. * Installation of secondary containment for the Anhydrou s Ammonia storage units that support the Ammonium Thiosulfate process. * Installation of water fog sprays for the Anhydrous Hydrogen Fluoride storage tanks which support the Fluosulfonic Acid process. * Installation of video monitoring equipment for the Anhydrous Ammonia storage tanks, which support the Ammonium Fluoborate and Potassium Nitrite processes. * Up-grading the spent acid transfer piping system. * Improve the inspection, testing and preventative maintenance program for the Oleum process. * Reduce the maximum quantity of liquid Sulfur Dioxide potentially stored on site. Certification 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. Plant Manager Date |