ChemDesign Corporation - Executive Summary

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Risk Management Plan 
Executive Summary 
February 18, 2000 
 
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 broad range of manufa 
cturing 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 muco 
us); 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. 
 
CDC also has two processes containing phosphorous oxychloride in excess of the EPA RMP threshold quantity.  Phosphorous oxychloride vapor is invisible and has a strong pungent odor.  It is shipped as a liquid.  It is a strong irritant to eyes, mucous membranes and the respiratory tract.  It is highly toxic and may cause lung injury, even in low concentrations.  In higher concentrations, more serious problems may occur, including fluid in the lungs, coughing, shortness of breath, dizziness, headache, chest pain, nausea, vomiting, kidney damage and death. 
 
Processes 
 
In CDC's two phosphorous oxychloride pr 
ocesses, the phosphorous oxychloride is stored in its shipping containers.  The shipping container is a Department Of Transportation (DOT) approved plastic drum containing 725 pounds of phosphorous oxychloride.  One of the processes consists of the storage of up to 24 drums stored on pallets inside the Building 13 chemical warehouse.  The second process consists of up to 24 drums stored on pallets on the Building 9 drum storage pad. 
 
In CDC's three chlorine processes, the chlorine is stored in its shipping containers.  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 located outside the Building 16 chemical production build 
ing.  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 the Building 16 chemical production building.  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, along with an adjacent evaporator building containing up to two 1-ton liquid chlorine cylinders stored on a rack.  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 the Building 8 chemical production building.    
 
Worst Case Release Scenario 
 
In a worst case scenario accident, all 725 pounds of phosphorous oxychloride within a single drum could be released within 10 minutes.  Based on the Environmental Protection Agency's (EPA) RMP*Comp computer program, such an accidental release could extend do 
wnwind far enough to affect off-site persons or the environment. 
 
Alternative Release Scenarios 
 
An alternative phosphorous oxychloride release scenario that would be more likely to occur than the worst case scenario could consist of a leak from a 1/8" diameter hole in the side of the drum.  Based on EPA's RMP*Comp computer program, such a release could extend downwind far enough to affect off-site persons. 
 
An alternative chlorine 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 cylinder 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. 
 
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 Pr 
ocess 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" chemicals.  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 health, environmental and safety professionals to coordinate efforts in those areas.  A fifth employee devotes half his time to health, environmental and safety matters. 
 
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 prog 
ram consists of: 
 
1. Development of a Custom Chemical Checklist (CCC) which consists of a documented detailed review of the hazards and any applicable 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 minimize 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.  Process Engineers and Process Developm 
ent Chemists oversee all processes to ensure safe operations. 
 
Chemical-Specific Release Prevention Measures 
 
A number of precautions and safety measures are employed to prevent occurrence of any chlorine releases.  No flammable or combustible materials are stored or located near the cylinders.  The evaporator buildings are constructed of steel, are thermally insulated and are kept closed during chlorine usage.  The two storage areas and evaporator buildings are protected from large vehicle collisions by concrete-filled metal posts.  Only DOT-approved steel cylinders are used.  The cylinders are leak-tested and inspected by the supplier before they are filled.  Respirators are worn by employees while connecting or disconnecting cylinders to and from the evaporators.  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 re 
adily available for emergency use by employees responding to a chlorine leak.  Chlorine detectors in the evaporator buildings and the chemical production buildings sound audible alarms in the event of chlorine leaks.  The detectors also automatically close automatic control valves on the evaporators.  The steel lines connecting the evaporators with the chemical production buildings are welded to prevent leaks.  Caustic scrubbers remove any chlorine that vents from the process. 
 
A number of precautions and safety measures are employed to prevent occurrence of any phosphorous oxychloride releases. The phosphorous oxychloride drums are banded together three to a pallet so they cannot tip over.  All employees who drive forklifts are rigorously trained and retrained on the safe transport of phosphorous oxychloride drums.  The Building 13 warehouse is equipped with monitored and pressure-boosted foam sprinklers.  It is locked when no employees are present.  The Building 9 drum storage pad is 
centrally located within the site's perimeter fencing.  It has overhead cover and a bermed concrete floor.   
 
General Release Prevention Measures 
 
To prevent occurrence of any release, 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-Year Accident History 
 
There have been no chlorine or phosphorous oxychloride 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 depart 
ments have detailed and comprehensive emergency notification systems and our internal emergency response plan clearly outlines our means of communicating with these organizations.   Numerous fire pull stations throughout the site automatically alert both fire departments of any emergency.  Numerous portable dry chemical fire extinguishers throughout the site are available for the immediate use of all employees, who are annually provided hands-on fire extinguisher training.  An on-site employee emergency response team is trained and equipped to handle most spills or releases.  It consists of 79 hazardous material technicians, 9 emergency medical technicians and 9 confined space rescue technicians.  An on-site emergency command center is fully equipped with radios and telephones for close cooperation 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 loc 
ated on-site to provide immediate information on wind speed and direction.  Wind socks installed on several buildings also provide wind direction.  All site supervisors and operators are equipped with portable radios.  A site public address system allows instant communication with most 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 or phosphorous oxychloride  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 means of our on-site gas release siren and public address system to shelter-in-place in their buildings.  The gas release siren is also audible to most neig 
hbors 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.  The siren is tested monthly.  Our on-site emergency response team is trained to respond to the source of the leak in adequate personal protective equipment and contain it. 
 
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 and 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 125 
0 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 will be added to the staff in February 2000.  
 
Additional safety measures are being evaluated.  These include: 
 
? placing all the phosphorous oxychloride drum pallets within plastic tubs to contain any leak and reduce the possibility of any collision damage 
? placing plastic covers over the phosphorous oxychloride drum pallets to protect the drums from rain during transport and to direct any drum sidewall leaks down into the plastic containemnt tub 
? pla 
cing automatic actuators on the valves of cylinders being evaporated so that the valves may be automatically or remotely closed in the event of a leak from the evaporator or its lines  
 
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 sessions 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. 
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 sessions 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.
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