Chloramone, Inc. - Executive Summary |
|
The Chloramone Company is a producer of sodium hypochlorite solution and a repackager of chlor-alkali products. Chloramone is a fully owned subsidiary of Kuehne Chemical Co., Inc. All safety procedures in place for Kuehne Chemical are followed by Chloramone as well. The following is a copy of our NJDEP approved Risk Management Program. This program describes the accidental release prevention and emergency response policies in effect at this site. The general accidental release prevention and chemical specific prevention steps are also described. SECTION CONTENTS I. Safety Review II. Standard Operating Procedures (1) Sodium Hypochlorite Mfg. Unit (2) Chlorine Repackaging Facility (3) Sulfur Dioxide Repackaging Facility III. Preventive Maintenance Program IV. Operator Training (1) Sodium Hypochlorite Mfg. Unit (2) Chlorine Repackaging facility (3) Sulfur Dioxide Repackaging Facility (4) Qualifications for Instructor V. Accident Investigations VI. Risk Assessment/Risk Analysis VII. Emergency Response Program VIII. Risk Management Program Audit IX. Management of modifications (change) to EHS equipment or procedures X. Contractor Policies SECTION I. SAFETY REVIEWS Yearly safety reviews will be conducted on each EHS facility 1. Sodium Hypochlorite Manufacturing Unit 2. Chlorine Repackaging Facility 3. Sulfur Dioxide Repackaging Facility by the following individ uals, TCPA Responsible Manager Plant Superintendent Facility Supervisors The safety review shall consist of a visual inspection of each EHS facility to ensure all design and operating criteria is current. The review will also include an inspection of operating records and interviews of operations personnel to determine whether the facility is being operated in accordance with the standard operating procedures. Unauthorized deviations discovered by the team will be documented and immediately discontinued. The safety review report will be submitted to the responsible manager for his approval. SECTION II. Standard Operating Procedures Sodium Hypochlorite Manufacturing Unit The Standard Operating Procedures are written, contained in a binder and located at both the operations control room and facility engineering office. The SOP's are also referred to as the "Operators Manual'. The SOP's are readily available to the EHS Operators as both reference and refresher material. As new policies are developed, they are explained to the EHS Operators and posted within the SOP's. The SOP's are reviewed regularly by the EHS Facility supervisors and reviewed at a minimum, annually, by the TCPA responsible manager with an audit team. The Standard Operating Procedures manual includes (but is not limited to) the following elements: a. Material Safety Data Sheets for the following substances: 1. Chlorine 2. Sodium Hydroxide 3. Sodium Hypochlorite b. Plant safety information and procedures pertinent to chlorine. c. Principles of Bleach Manufacturing - Sodium Hypochlorite manufacturing process, EHS Operator responsibilities, chemical reactions and chlorine temperature vs. vapor pressure graphs. d. Theory of operation, encompassing the role of chlorine within the process. e. A description of each element of instrumentation used in the process, along with the safety instrumentation incorporated within the unit. f. Standard start up procedures with corresponding checkli st. g. Description of all log sheets and log book to be filled out by the EHS Operator. h. An itemized listing of normal operating conditions which includes temperatures, pressures and instrumentation readings. i. An itemized listing of abnormal operating conditions, including probable causes and corrective actions to be followed. j. An itemized shutdown procedures list. k. An itemized procedure list for the switching of rail road tank cars. I. An itemized procedure list for the connecting and disconnecting of chlorine rail road cars. m. Emergency shutdown procedures as pertaining to different emergency conditions that may possibly occur within the process. n. A listing of facility personnel, supervision and outside agencies, along with telephone numbers to be called in the event of an emergency. o. Procedures to be followed for the preparation of EHS equipment prior to maintenance work and procedures for restarting EHS equipment after maintenance work has been completed. p . Copies of the simplified flow diagrams for the unit. Standard Operating Procedures Chlorine Repackaging Facility The Standard Operating Procedures are written, contained in a binder and located at the repackaging operations control room and the facility field office. The SOP's are also referred to as the "Operators Manual". The SOP's are readily available to the EHS Operators as both reference and refresher material. As new policies are developed they are explained to the EHS Operators and posted within the SOP's. The SOP's are reviewed regularly by the EHS Facility supervisors and reviewed at a minimum, annually, by the TCPA responsible manager with an audit team. The Standard Operating Procedures manual includes (but is not limited to) the following elements: a. Material Safety Data Sheets for the following substances: 1. Chlorine 2. Sodium Hydroxide b. Plant safety information and procedures pertinent to chlorine. c. Pre start-up procedures to be followed to include the leak checking of filling stations, prior to the actual filling of ton containers. d. Theory of operation, encompassing the role of chlorine within the process. e. A description of each element of the instrumentation used within the facility, along with the safety instrumentation incorporated within the facility. Also, a description of all electronic and/or mechanical scales utilized for filling. f. Standard filling procedures with corresponding checklist g. Description of the log sheets and log book to be filled out by the EHS Operator. h. An itemized listing of normal operating conditions which includes temperatures, pressures and instrumentation readings. i. An itemized listing of abnormal operating conditions including probable causes and corrective actions to be followed. j. An itemized shutdown procedures checklist to be followed by operators when filling is discontinued for the day. k. An itemized procedure list for the switching of railroad tank cars. I. An itemized procedure list for the connecting and disconnecting of chlorine rail road cars. m. Emergency shutdown procedures as pertaining to different emergency conditions that may possibly occur within the process. n. A listing of facility personnel, supervision and outside agencies along with telephone numbers to be called in the event of an emergency. o. Procedures to be followed for the preparation of EHS equipment prior to maintenance work and procedures for restarting EHS equipment after maintenance work has been completed. p. Copies of the simplified flow diagrams for the unit. Standard Operating Procedures Sulfur Dioxide Repackaging Facility The Standard Operating Procedures are written, contained in a binder and located at both the SO2 operations control room and the facility engineering office. The SOP's are also referred to as the "Operators Manual". The SOP's are readily available to the EHS Operators as both reference and refresher material. As new policies are developed they are explained to the EHS Operators and posted within the SOP's. The SOP's are reviewed regularly by the EHS facility supervisors and reviewed at a minimum, annually, by the TCPA responsible manager with an audit team. The Standard Operating Procedures manual includes (but is not limited to) the following elements: a. Material Safety Data Sheets for the following substances: 1. Sulfur Dioxide 2. Sodium Hydroxide b. Plant safety information and procedures pertinent to Sulfur Dioxide. c. Pre start-up procedures to be followed to include the leak checking of valves and hoses, prior to the actual filling of tank wagons. d. Theory of operation, encompassing the role of Sulfur Dioxide. e. A description of each element of instrumentation used within the facility, along with the safety instrumentation incorporated within the facility. f. Standard filling procedures with corresponding checklist. g. Description of the log sheets and log book to be filled out by the EHS Operator. h. An itemized listing of normal operating conditions which includes temperatures, pressures and instrumentation readings. i. An itemized listing of abnormal operating conditions including probable causes and corrective actions to be followed. j. An itemized shutdown procedures checklist to be followed by operators when filling is discontinued for the day. k. An itemized procedure list for the switching of railroad tank cars. I. An itemized procedure list for the connecting and disconnecting of sulfur dioxide rail road cars. m. Emergency shutdown procedures as pertaining to different emergency conditions that may possibly occur within the process. n. A listing of facility personnel, supervision and outside agencies along with telephone numbers to be called in the event of an emergency. o. Procedures to be followed for the preparation of EHS equipment prior to maintenance work and procedures for restarting EHS Equipment after maintenance work has been completed. p. Copies of th e simplified flow diagrams for the unit. SECTION III. PREVENTIVE MAINTENANCE PROGRAM All components of the three (3) EHS Facility's have been identified and incorporated into a calendar based inspection program. Records of scheduled maintenance, testing, inspections performed and equipment condition are maintained in a central file at the facility field office and are utilized in the continuing analysis of equipment reliability and replacement requirements. The TCPA Responsible Manager reviews performance of these functions against schedule. Training information regarding EHS specific aspects of maintenance as well as Material Safety Data Sheets is maintained by maintenance supervision and utilized during training and review. Maintenance work orders are issued according to the calendar based inspection program through the facility "Maint Star" computer program. Additional permits for lock out/tag out entry and purging of equipment are issued as necessary for the task being perfo rmed. Procedures and work orders both designate any specific cautions which must be taken based upon the nature of the function to be performed and hazards which may be present. Identical replacement items are inventoried in quantity based upon the frequency of replacement items are purchased by itemized description and specification and are verified upon receipt to ensure that no substitution occurs. All construction and repair materials for Sulfur Dioxide service are selected on the basis of recommendations of the Sulfur Dioxide Manufacturing Association, which has extensive advisory publications pertinent to this consideration, and forms the Standard to the Chemical industry in regards to Sulfur Dioxide. All construction and repair materials for Chlorine service are selected on the basis of recommendations of the Chlorine Institute, which has extensive advisory publications pertinent to this consideration, and forms the Standard to the Chemical industry in regards to Chlorine. Construction, repairs and modifications to the Chlorine Repackaging facility and Hypochlorite Manufacturing facility are and will be in accordance with the guidelines and recommendations of the Chlorine Institute. Construction, repairs and modifications to the Sulfur Dioxide Repackaging facility are and will be in accordance with the guidelines and recommendations of the Sulfur Dioxide Manufacturing Association. All maintenance department personnel have been trained to perform necessary maintenance procedures and repairs safely and properly, and all work is inspected and tested prior to return to EHS service. All procedures are performed in accordance with either the Sulfur Dioxide Manufacturing Association recommendations or those of the Chlorine Institute. Scheduled time periods for performance of these inspections are, at a maximum, those suggested by these particular recommendations, except where our particular experience has indicated shorter intervals, or where particular o perating conditions have suggested unscheduled inspections or maintenance based on our experience or caution. Maintenance on EHS Equipment at any of the three (3) facility's must be approved by the TCPA Responsible Manager prior to being performed. The Responsible Manager provides the conduit for necessary communications between the maintenance, production and engineering departments. Overdue Preventive Maintenance Work Orders are handled by the facility Maintenance Coordinator. Each work order is consecutively numbered and must be turned over to the maintenance coordinator by the maintenance supervisor upon completion of the assignment. Daily meetings are held by both maintenance coordinator and supervisor to discuss current and outstanding work. Overdue work orders are rescheduled as priority assignments. Preventive maintenance work orders which are not turned back in within a reasonable amount of time (30 days), will require the plant manager to intervene and ensure that the as signment is completed. In the instance of work to be performed by outside contracted personnel the same procedures for assurance of proper materials, procedures and communications will be utilized, and regularly reviewed by the TCPA Responsible Manager. All safety instrumentation is checked as part of the Standard Operating Procedures and also incorporated within the calendar based inspection program. Safety instrumentation checks are also performed prior to facility startup in the event the facility has been out of service for any reason. Procedures are in place for the commissioning of new or replacement EHS equipment and based upon recommendations of both the Sulfur Dioxide Manufacturing Association and those of the Chlorine institute. Procedures have also been established for the de-commissioning of EHS equipment. Safety training for EHS maintenance personnel, which includes proper practices and materials selection is conducted through out the year and additionally reviews pa st performance's which may have resulted in the release of or potential release of an EHS substance. SECTION IV. OPERATOR TRAINING Hypochlorite Manufacturing Facility Job Description The Bleach Manufacturing Unit Operator's function is to operate all equipment necessary to manufacture bleach from raw materials. The following is a breakdown of duties and responsibilities of the Hypochlorite Facility EHS Operator: 1. Monitoring of instrumentation and make the adjustments necessary to maintain the process within the specified limits. 2. To analyze the materials, by titration, and to make the adjustments needed to maintain a quality product. 3. To inspect the equipment at predetermined intervals, locate deficiencies, and to either repair or remove from service any piece of equipment found to be deficient. 4. To respond to any alarm and immediately correct the condition. 5. To respond to emergency conditions which may lead to, or be, an EHS release, and make necessary repairs t o the extent of his ability. In order to qualify for the operator position the applicant should have experience as a chemical operator, preferably as a continuous process operator. The applicant should have a high school education with some knowledge of mathematics and chemistry. Applicants will also be required to pass a pre-employment physical which will include respiratory and substance abuse testing. Evaluation The EHS facility Supervisor uses a training sheet which lists every piece of equipment and function, as a guide when observing the performance of and orally quizzing the trainee. Before the trainee is qualified, a written test must be taken and passed. The supervisor will acknowledge the trainee's competence in each area by initialing the training sheet. The trainee accepts responsibility of each area by initialing the appropriate space on the training sheet. Only when the training sheet is completed and the written test is passed will the trainee be qualified as a n operator Training Schedule Upon receipt of notification that the applicant has passed the physical, the trainee will have three to five days of general orientation and classroom training with the Bleach Process Supervisor and facility training coordinator. Weeks two to four (or five depending upon the trainee's experience) will be spent on a day shift working with a qualified EHS Operator in "On The Job Training". The operator that teaches the trainee must have at least one year experience and a complete understanding of each function of the EHS Facility. Weeks five or six, after the trainee has passed the written test and has been evaluated as being competent on all phases of the operation, and has accepted responsibility for all phases of the operation, will normally be spent on a midnight shift with a qualified operator to familiarize the trainee with the duties of midnight operations. The time limit for training is six weeks. After the trainee is qualified, he spends an ad ditional four weeks on the day shift, in order to make it possible for the supervisor to assist the new operator in the decision making processes that is required of all EHS operators. As the operators rotate through the shift schedule, the supervisor reviews with the day shift operator any updates of the standard operating procedure, material safety data sheets, safe handling practices, and reviews of any accident reports. Any items that are seasonal procedure changes, such as winter freeze up precautions are reviewed in these sessions. As the operators are on the day shift every other week, the operators are kept very much up to date. Any information that the supervisor deems necessary is noted in the operators log book daily. OPERATOR TRAINING Chlorine Repackaging Facility Job Description The Repackaging EHS Operator's duties are to fill from Chlorine Road Cars, one (1) ton containers, 150# cylinders and DOT approved MC-331 tank trailers, The following is a breakdown of d uties and responsibilities of the Repackaging EHS Operator: I. To continuously monitor the filling of one (1) ton containers, 150# cylinders or MC-331 tank wagons with chlorine. Shipping containers while in the process of being filled must never be left unattended. 2. To make sure that shipping containers are never overfilled. 3. To constantly be on the alert for possible leakage of Chlorine during the filling process and to take corrective measures if leaks are detected. 4. To safely handle the repositioning of full shipping container 5. To notify the supervisor of any safety problems perceived by the operators in the equipment being used or the procedure being followed. 6. To be completely familiar with and to periodically review the Repackaging Standard Operations Manual 7. To wear and have readily available, all safety equipment as required by the Standard Operating Procedures. 8. To fill out all logs and check sheets as required by the Standard Operating Procedures. 9. To ensure that all containers are properly marked, labeled and packaged. 10. To safely load and unload chlorine packages onto or off of proper transportation vehicles. In order to qualify for the Repackaging Operator position, the applicant should be physically fit and at a minimum, the ability to read, write and speak English, and able to do simple arithmetic. Previous experience is not required. Evaluation The supervisor uses a training sheet, which lists each of the Repackaging Operator's duties as a guide when observing the performance of the trainee. He will also orally test the trainee. Before the trainee is qualified, he must pass a written test, in order to indicate that he understands the hazards associated with the handling of chlorine and the safety precautions and procedures that must be followed. The supervisor will acknowledge the trainee's competence in each area by initialing the training sheet with the corresponding date competence was achieved. The train ee will only be considered fully qualified to perform each operating duty after he has passed the written test and has met all the training requirements for each job description duty. The trainee will accept responsibility for each duty as he becomes qualified by initialing, with date the appropriate space on the training sheet Training Schedule Upon receipt of notification that the applicant has passed the physical, the trainee will have one to two days of general orientation and personal training which will include visual aid instruction (video's) and hands on training on how to wear and use SCBA and also on the proper application of the leak stoppage kits which apply to the repackaging department. He will spend the next thirty (30) days (as necessary), receiving "On The Job Training" with a qualified repackaging operator and the facility supervisor. A qualified operator is one who has had at least one (1) year experience in the job description duties that he will be training so meone in. The total amount of time allowed for training will be 30 working days. Each EHS Repackaging Operator will be evaluated every six (6) months by the facility supervisor and retraining will be conducted annually. OPERATOR TRAINING Sulfur Dioxide Repackaging Facility Job Description The Repackaging EHS Operator's duties are to fill from Sulfur Dioxide Rail Road Cars, USDOT approved MC-331 tank trailers. The following is a breakdown of duties and responsibilities of the Repackaging EHS Operator: I. To continuously monitor the filling of MC-331 tank wagons with sulfur dioxide. Shipping containers while in the process of being filled must never be left unattended. 2. To make sure that shipping containers are never overfilled. 3. To constantly be on the alert for possible leakage of Sulfur Dioxide during the filling process and to take corrective measures if leaks are detected. 4. To notify the supervisor of any safety problems encountered by the operators in the equipm ent being used or the procedure being followed. 5. To be completely familiar with and to periodically review the Repackaging Standard Operations Manual. 6. To wear and have readily available, all safety equipment as required by the Standard Operating Procedures. 7. To fill out all logs and check sheets as required by the Standard Operating Procedures. 8. To ensure that all containers are properly marked, labeled and packaged. 9. To safely load and unload sulfur dioxide onto or off of proper transportation vehicles. In order to qualify for the Repackaging Operator position, the applicant should be physically fit and at a minimum, the ability to read, write and speak English, and able to do simple arithmetic. Previous experience is not required. Evaluation The supervisor uses a training sheet, which lists each of the Repackaging Operator's duties as a guide when observing the performance of the trainee. He will also orally test the trainee. Before the trainee is quali fied, he must pass a written test, in order to indicate that he understands the hazards associated with the handling of chlorine and the safety precautions and procedures that must be followed. The supervisor will acknowledge the trainee's competence in each area by initialing the training sheet with the corresponding date competence was achieved. The trainee will only be considered fully qualified to perform each operating duty after he has passed the written test and has met all the training requirements for each job description duty. The trainee will accept responsibility for each duty as he becomes qualified by initialing, with date the appropriate space on the training sheet Training Schedule Upon receipt of notification that the applicant has passed the physical, the trainee will have one to two days of general orientation and personal training which will include visual aid instruction (video's) and hands on training on how to wear and use SCBA and also on the proper ap plication of the leak stoppage kits which apply to the repackaging department. He will spend the next thirty (30) days (as necessary), receiving "On The Job Training" with a qualified repackaging operator and the facility supervisor. A qualified operator is one who has had at least one (1) year experience in the job description duties that he will be training someone in. The total amount of time allowed for training will be 30 working days. Each EHS Repackaging Operator will be evaluated every six (6) months by the facility supervisor and retraining will be conducted annually. GENERAL REQUIREMENTS FOR INSTRUCTOR Job Description The duties of the "Facility Training Instructor" are as follows: 1. Conduct training sessions for facility personnel; a. General Safety b. Hazard Awareness c. Function Specific 2. Document and maintain necessary records in accordance with all local, state and federal regulations. 3. Conduct training sessions for "C ontractor" personnel. 4. Perform out of facility safety training - as necessary. Qualifications for "Facility Training Instructor" include but are not limited to the following: 1. Minimum of 3 years experience with company (this may be waived dependent upon prior verifiable instructor experience) 2. Prior knowledge and understanding of subject matter to be presented. Facility Training Instructor should be available to attend out of facility seminars and training in order to keep instructional skills current. SECTION V. ACCIDENT INVESTIGATION 1. Accident Investigation Team EHS Facility Supervisor Plant Manager TCPA Responsible Manager 2. Procedure must begin within 24 hours of time of incident. 3. Procedure Outline - Investigation to be conducted in three (3) stages. STAGE I - Facts Gathering The EHS Facility Supervisor will gather the initial investigation information. This will include, but not be limited to; Time of incident Location of incident EHS released (if any), amount and duration Personnel involved The supervisor will identify equipment, materials, procedures (operating and preventive) and personnel relevant to the accident while also determining the consequences of the incident. The consequences being, but not limited to; Number of evacuees Number of injuries/fatality's (if any) Community Impact Facility impact The supervisor will piece together the chronological details of the EHS incident. This may be accomplished by the careful review of available information; Personnel interviews Log and check sheets Recorded instrumentation data All of the above information should be obtained within three (3) days of the time of the incident. STAGE 2 - Facts Evaluation The EHS Facility Supervisor along with the Plant Manager and TCPA Responsible Manager will, from the data collected, determine the specific cause of the accident (human error, procedural inadequacies, equipment failure). STAGE 3 - Conclusions/Recommendations Alter careful rev iew of the collected data, the EHS Facility Supervisor along with the Plant Manager and TCPA Responsible Manager will recommend changes to be implemented in order to greatly reduce or eliminate the risk of any recurrence of the accident. In making these recommendations, they will consider the following (but not be limited to) for changes or additions; Instrumentation Equipment Preventive Maintenance Procedures Operating Procedures Operator Re-training and anything else they deem necessary and practical to reduce the recurrence risk. Accident/Incident Investigation Report The report of the accident team finding will be written by the TCPA Responsible Manager within 14 days of receipt of information from the EHS Facility Supervisor and will contain, at a minimum, the following information; a. The time, date and location of the EHS incident. b. The amount, duration and nature of the EHS release. c. The equipment, materials, procedures and personnel involved d. A chronologically deta iled description of the EHS incident e. The consequences of the EHS incident, including the number of evacuees, injuries/fatalities and community impact. f. Direct or indirect cause of the incident, to be classified as human error, procedural inadequacy or equipment failure. g. Listing of recommended actions to prevent recurrence. 4. Review of Accident Investigation Report Upon its issuance, the accident investigation report will be reviewed by the following individuals within 14 days; Executive Vice President Plant Manager EHS Facility Supervisor TCPA Responsible Manager A timetable will be established for the implementation of agreed upon recommendations (if not already completed). The EHS Facility supervisor will furnish a report on the first (1st) Monday of each month indicating the status of implementation of recommended changes as established by the timetable. 5. Accident/Incident Investigation Record Keeping All accident and incident investigation reports will be kept within a separate file to be stored with all other TCPA Program files. At a minimum, reports will be kept for ten (10) years. 6. Accident investigation Yearly Summary Report At the end of each calendar year, the TCPA Responsible Manager will compile an accident investigation summary report. This report will be distributed to the following individuals; Plant Manager Transportation Manager Production Supervisors Maintenance Supervisor This report will contain, but not be limited to the following information; a. A listing of EHS accidents/incidents which have occurred during the year, with a brief description of each accident/incident. b. A categorization of human error; procedural inadequacy or equipment failure along with responsible individuals for accident. c. Implementation of corrective actions schedule d. Progress report on corrective actions taken to date. SECTION VI. RISK ASSESSMENT/ANALYSIS The Hazard Analysis Team shall consist of the following members; Plant Manager, TCPA Responsible Manager, Production Supervisor, and any other facility personnel or outside consultant that the team deems necessary to perform the analysis. The hazard analysis will be performed on any new or modified EHS facilities. This will encompass modifications in EHS equipment, preventive maintenance procedure, and or standard operating procedures. A hazard analysis will also be done on all existing EHS facilities at least once every five years The hazard analysis will, in it's analysis identify all EHS equipment, potential release points, and the approximate quantities and causes of the potential releases. In the period between performances of hazard analysis, data will be generated by each EHS facility to be considered by the analysis team. The data will include equipment failure data EHS accident reports and preventive maintenance data. In the analysis the team will determine which potential EHS release may result in an off-site impact equal to or above the ATC for th e particular EHS. The team will then perform a risk assessment on all these potential release points. The risk assessment will consist of the following four determinations; the estimated EHS release quantity, a dispersion analysis the consequences on the surrounding population, and an estimation of the probability of the EHS release's occurrence. The team will then develop a risk reduction plan for all potential EHS releases utilizing state of the art technologies and or alterations in operating procedures and preventive maintenance procedures. When the team has completed it's hazard analysis. it will prepare a report which will contain the following elements; a. A list of all EHS facilities (including equipment) on which the study has been performed. b. A list of all potential release points along with the approximate rates, quantities and the potential causes. c. A corresponding list of each potential EHS release points which describes what risk reduction shoul d be taken for each one, along with the proposed implementation schedule. The risk reduction plan will include the previously mentioned considerations. d. An explanation of any potential EHS releases which the team has determined does not require a risk reduction plan. e. The findings of the dispersion analysis and the consequence analysis prepared on potential releases that would have an off site impact. prepared in accordance with the requirements of N.J.A.C. 7:31-3.9. The report will be signed by each member of the team and submitted to the responsible manager for his review. SECTION VII. EMERGENCY RESPONSE PROGRAM The facility Emergency Response Plan is organized into a binder containing the following elements: a. A description of the properties of chlorine along with a current copy of the Material Safety Data Sheet. Also included is information on where chlorine is located on site. b. A description of the properties of Sulfur Dioxide along with a current copy of the Mater ial Safety Data Sheet. Also included is information on where Sulfur Dioxide is located on site. c. A list of all available Emergency Response Equipment on site (to include hand held gas monitors) and where such equipment is located. d. A list of emergency response team personnel, in-house and off site, along with telephone numbers. The list designates the emergency coordinator, emergency response team leader, emergency response team and all alternates. e. A detailed description of company personnel and government agencies that must be contacted in the event of a release of Chlorine or Sulfur Dioxide. This description also details the information the DEP will be expecting and at what time intervals. f. Procedures for the handling of emergency Chlorine or Sulfur Dioxide releases. g. A guideline for the rescue of any person who is over come or missing during a Chlorine or Sulfur Dioxide emergency. h. A copy of the most current South Kearny emergency response management program, wh ich encompasses off site evacuation and the providing of information to the media. i. A description of site reentry conditions and parties responsible for determining safe reentry. j. A description of evacuation plans for on site personnel. k. A description of the latest chlorine treatment procedures as per the Chlorine Institute. The balance of the Emergency Response Program deals with the training of on site emergency response personnel and the requirement for the conducting of yearly emergency drills to evaluate training and overall plan effectiveness. At a minimum, two drills will be conducted for each EHS facility. At a minimum, each EHS facility will conduct 1 site specific drill and 1 table top exercise. The facility will conduct at a minimum, 1 facility wide drill in which local agencies (i.e., police, first aid and LEPC) are invited for participation and/or review. The program also stipulates that an evaluation report by the emergency response team be written up afte r each drip or actual emergency. The facility Responsible Manager for the TCPA program will ensure that all elements of the emergency response program are carried out. Copies of the facility Emergency Response Plan are located at the following locations: Hypochlorite Manufacturing Facility Control Room Office Repackaging Facility Office Engineering Field Office Main Office Complex SECTION VIII RISK MANAGEMENT PROGRAM AUDIT A yearly audit of the facility's approved Risk Management Program will be conducted by the following personnel; Plant Manager Transportation Manager TCPA Responsible Manager Production Supervisor Maintenance Supervisor Each of the above named positions will familiarize themselves with the Facility's approved Risk Management Program. They will investigate each aspect of the program to ensure it is being conformed to. During the investigation, they will use, as a guide, both the Risk Management Program Checklist and the Summary Risk Management Program. A li st of deficiencies with recommended corrective actions will be compiled and submitted with the audit report. The complete audit report will be submitted to the TCPA Responsible Manager for his review. Within 30 days of the Audit Report's submission to the Responsible Manager, the audit team members (named above) will meet to review the status of all recommended corrective actions to ensure their completion. SECTION IX. MANAGEMENT OF MODIFICATIONS (CHANGE) TO EHS EQUIPMENT/PROCEDURES Prior to the modification of any EHS equipment or procedures, a determination will be made as to whether the change is major or minor. Minor modifications (as defined under NJAC 7:31-3.15 (a) 1) will be signed off by the Facility TCPA Responsible Manager in accordance with the requirements under 7:1E-3.15 (a) 5.i Major modifications (as defined under NJAC 7:31-3.15 (a) 1) will require that the Facility TCPA Responsible Manager conduct a Risk Assessment on the items to be changed in accordance with the requirements at 7:31-3.9 (c) through (i). A report will be issued, signed by the Responsible Manager affirming the requirements at 7:31-3.15 (a)1 through 4 have been performed. Kuehne Chemical Company, inc. reserves the right to assign successors in any of the organizational staff who implement individual elements of the site risk management program. Qualifications of these "successors" may vary and as such we shall not set forth specific qualifications for any of these positions. However, any successor must have a solid knowledge and background of the facility and systems in which they will be implementing equipment or procedural changes. A transitional period of not less than ten (10) business days will be afforded to ensure that any "successor" to the organizational staff of the site risk management program be properly trained and qualified for the position. Changes made to the organizational staff that implement individual elements of the site risk management program will be made in writing to the Department within thirty (30) working days of the date the change occurs. SECTION X. CONTRACTOR & CONTRACTOR POLICIES It has been, and shall continue to be in the future, the policy of this facility to utilize "in-house" employees for the construction, maintenance and modification of both EHS and non-EHS equipment. The following procedures will be followed in dealings with contractors and contractor employees who may be utilized for work on or adjacent to EHS Equipment; 1. Contractors will be required to furnish information regarding their own safety performance and programs 2. Contractors will be required to assure that each of their employees is adequately trained in the work practices necessary to safely perform his/her job. 3. Contractors and their employees will be periodically evaluated in the performance of their functions 4. Contractors will be required to advise on unique hazards pertaining to their work or hazards encountered while working at this facility 5. Contractors and their employees will be required to undergo a training seminar prior to performing any work within the facility. The training will consist of but not be limited to the following; a. Site Emergency Response Plan b Emergency Procedures c. Potential fire, explosion or toxic release hazards d. Applicable provisions of the EHS Facility Standard Operating Procedures 6. All Contractors and their employees will acknowledge the training received and understanding thereof with signed documentation to be completed at the end of training seminar. All records will be maintained within the training files located at the facility field office. 7. At no time will contractors or their employees be utilized as EHS operators or assist site personnel during an emergency response incident, including, the mitigation of a release. 8. Sign in and sign out provisions are in effect to control the entrance, exit and presence of contractors and their employees. 9. The facil ity Responsible Manager for the TCPA program will, in conjunction with the facility plant Manager, ensure that all employees (both Kuehne Chemical and Contracted employees) are properly trained in accordance with the above policies. 10. The facility Training Office will coordinate with contracted personnel to ensure that the proper training is conducted prior to any work being conducted within the facility. Kuehne Chemical Company processes two substances regulated under the RMP law. 1. Chlorine 2. Sulfur Dioxide (anhydrous) Release Scenarios Chlorine Worst case scenario: The largest storage vessel for chlorine in use at this facility is a stationary storage tank with a capacity of 134,032 pounds of chlorine. In the event of a total failure of this tank, the resulting cloud of chlorine vapor would be immediately dangerous to both life and health for a distance of 12 miles according to the RMP*Comp calculations. The total population within this radius is approximately 450,000. Alternate scenario: An alternate scenario for chlorine involves a pipeline leak which releases one pound per minute of chlorine for a duration of 50 minutes, releasing a total of 50 pounds of material. The RMP*Comp calculation for this scenario shows a distance of less than 0.1 miles to the endpoint. There is no residential population within this area. Sulfur Dioxide Worst Case scenario: The largest storage vessel for sulfur dioxide in use at this facility is a trailer with a capacity of 44,000 pounds of sulfur dioxide. In the event of a total failure of this tank, the resulting cloud of chlorine vapor would be immediately dangerous to both life and health for a distance of 6.5 miles according to the RMP*Comp calculations. The total population within this radius is approximately 200,000. Alternate scenario: An alternate scenario for sulfur dioxide involves a pipeline leak which releases one pound per minute of chlorine for a duration of 50 minutes, releasing a total of 50 pounds of material. The RMP*Comp calculation for this scenario shows a distance of less than 0.1 miles to the endpoint. There is no residential population within this area. Five Year Accident History. The only accident which occurred within the last five years was the failure of a chlorine transfer hose. Less than five pounds of material was released. Two employees were taken to the hospital for observation. They were released the same day and did not experience any long term effects. Planned changes to improve safety. All changes resulting from the most recent audit of the facility have been implemented. There are no further changes planned to improve safety at this time. |