Monson Companies, Inc. - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Monson Companies, Inc. are 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 and mitigate the effects of the release. We are also completely coordinated with Clean Harbors Environmental Services which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass chem ical blending, storage and distribution. We have 3 regulated substances present at our facility. These substances include chlorine, ammonia and sulfur dioxide (anhydrous). These regulated substances are stored at our facility as compressed gases in cylinders for direct distribution to our customers. The cylinders are received by Monson, stored until they are ordered by our customers and then delivered to the customer site. Monson Companies does not fill or otherwise process these chemicals. The maximum inventory of chlorine at our facility is 87,950 pounds. Ammonia and sulfur dioxide is present in quantities of 20,000 and 12,100 pounds respectively. These are the maximum quantities on hand at any time however inventories may vary depending on shipments and customer demand. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the req uired 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 Program 2 and 3 toxic substances as a class involves a catastrophic release from chlorine cylinder storage. The scenario involves the release of 87,950 pounds of chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. This scenario is extremely unlikely however since this would require a catastrophic event that would impact all chlorine cylinders in storage and cause them to release their contents in a short period of time. One alternative release scenario has been submitted for each toxic substance present in Program 2 and Program 3 processes cumulatively. The al ternative release scenario for Chlorine involves a release from Building No. 1, Rail Side (West) Loading Dock in the chlorine cylinder storage area. The scenario involves the release of 480 pounds of chlorine in a gaseous form over 480 minutes. This release scenario involves a small valve leak (1 pound per minute) that would go undetected for a period of 8 hours (assuming the leak would begin after employees leave the site at the end of the work day and would go undetected throughout the evening). The release is also assumed to be controlled by active mitigation measures that involves trained Monson personnel responding to the chlorine cylinder storage area with a patch kit for cylinder valves. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of chlorine is 0.07 miles. The alternative release scenario for ammonia involves a release from Building No. 1, Rail Side (West) Loading Dock in the anhydrous ammonia cylinder storage area. The scen ario involves the release of 150 pounds of ammonia in a gaseous form over 150 minutes. This scenario would involve a small valve leak (1 pound per minute) in a 150 pound ammonia cylinder. The release would be actively mitigated by trained Monson personnel who would respond to stop the leak with a cylinder valve repair kit. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of ammonia is 0.06 miles. The alternative release scenario for sulfur dioxide (anhydrous) involves a release from Building No. 1 Rail Side (West) Loading Dock in the sulfur dioxide cylinder storage area. The scenario involves the release of 480 pounds of sulfur dioxide (anhydrous) in a gaseous form over 480 minutes. The scenario is based on a small valve leak (1 pound per minute) that would go undetected for a period of 8 hours. The release would be actively mitigated by trained Monson personnel who would respond to seal the valve leak with a cylinder valve repair kit. U nder neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 0.07 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 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. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. As an active member of the National Association of Chemical Distributors (NACD), Monson has chosen to implement the Responsible Distribution Process (RDP) for chemical distributors in addition to meeting our regulatory obligations. We are extremely proud of our participation in this stringent program for leaders in the chemical distribution industry. This process serves as the foundation for our overall chemical management program. The following sections briefly describe the elements of the release prevention program that is in place at our facility. Process Safety Information Monson Companies, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis 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/Checklist" technique. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated annually. 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 proce sses, Monson Companies, 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. Training Monson Companies, 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 frequently as needed. Mechanical Integrity Monson Companies, Inc. carries out regular maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, relief and vent systems, emergency shutdown systems, controls and pumps. Inspections of all our cylinders a re conducted on a daily basis. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Monson Companies, Inc. to manage changes in process chemicals, technology, equipment and procedures. This program at Monson is implemented primarily through our Responsible Distribution Process (RDP). Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Monson Companies, Inc. These reviews are cond ucted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Monson Companies, Inc. conducts audits and inspections on a monthly basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least monthly and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Monson Companies, 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 at least 3 years. Employee Participation Monson Companies, Inc. truly believes that process safety management and accident prevention i s a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Monson Companies, Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Monson Companies, Inc. has had an excellent record of preventing accidental releases over the las t 5 years. Due to our stringent release prevention policies, no incidents involving regulated substances have occurred at the Monson facility since we began operation at this site in 1982. 6. Emergency Response Plan Monson Companies, 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. The plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. In addition to providing emergency response to our own facility, trained Monson personnel provide emergency response services to Cumberland County as requested. Cu mberland County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. We are currently preparing to demonstrate the proficiency of our emergency plan through a comprehensive review and drill. This is expected to be implemented by October 1999. 8. Certification Statement 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. Name: Lawrence S. Tibert Signature: Title: Director, Business Systems and Compliance Date signed: |