Ross Incineration Services, Inc. - Executive Summary |
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5/31/00 Risk Management Plan for Ross Incineration Services, Inc. Executive Summary Introduction The purpose of this Executive Summary is to provide the public with information about Ross Incineration Services, Inc., ("RIS") Risk Management Plan ("RMP"). RIS is a commercial hazardous waste treatment and storage facility that processes substances covered by the accidental release prevention regulations under section 112(r) of the Clean Air Act. All facilities covered by these regulations must develop and implement programs that prevent accidental releases of regulated substances and reduce the severity of those releases that may occur. These risk management programs must be described in a RMP. The RMP must include a hazard assessment, a prevention program and an emergency response program. The RMP must be submitted to the U.S Environmental Protection Agency by June 21, 1999. RIS has developed its risk management programs and submitted its RMP to comply with these regulations. It is RIS' policy to provide its employees with a safe work environment and its neighbors with a safe environment in which to live. RIS is committed to providing employees with safe equipment. RIS is also committed to complying with State and Federal regulations regarding working conditions and accident prevention. The personal health and safety of RIS employees and neighbors is of primary importance. To this end, RIS maintains safety and health programs that employ an aggressive approach toward injury and illness prevention and a safe work environment. RIS operates within guidelines set by its Statement of Safety, Health and Environmental Policy, which is as follows: - Our business success and our commitment to protection of human health and the environment are consistent and complimentary goals. - We will demonstrate leadership in protection of human health and the environment in our workplace, marketplace and the community. - We will comply with all applicable safety, heal th and environmental regulations, and hold the broader goals of: eliminating preventable injuries; preventing adverse environmental and health impacts; reducing wastes and emissions; and promoting resource conservation. - Management and all employees are collectively and individually responsible for compliance with safety, health and environmental regulations, policies and procedures. - We will communicate our safety, health and environmental achievements and challenges openly, honestly, clearly, and professionally with employees, customers, our community, and government agencies. - This policy will guide all our decisions and actions that have potential safety, health or environmental impacts. Safety Information RIS is regulated under the Resource Conservation and Recovery Act ("RCRA"). This group of regulations requires RIS to operate under strict specifications. Under these regulations RIS is also required to operate under a Part B permit. The purpose for the RCRA regulati ons (and the Part B permit) is to assure that RIS operates its processes in a manner that protects human health and environment. The RIS facility operation was designed to prevent accidental releases as well as mitigate potential releases. Daily inspections are conducted for the operational processes, storage areas and secondary containment areas. Additional inspection and monitoring (also required by RCRA and the Part B permit) are also conducted to assure that the processes are operating within permitted and regulated specifications. RIS firmly believes that a release of a hazardous chemical from its facility that would adversely impact the environment or cause concern to human health is very unlikely. Waste management processes at RIS are engineered and constructed with controls to prevent or mitigate off-site releases of hazardous chemicals to the environment. Current operating and safety procedures further reduce the possibility of such a release. RIS' Emergency Response Program minimizes hazards to human health and the environment from fires and unplanned releases of hazardous waste constituents from facility operations. This program includes provisions to coordinate on-site emergency response personnel if a chemical spill or fire were to occur. It also includes provisions to coordinate response to site emergencies, if necessary, with local, State and Federal emergency management personnel. Emergency Coordinators ("EC") and Emergency Response Team ("ERT") personnel employed by RIS are trained to greatly control chemical spills and fires to minimize the possibility of an off-site release of hazardous chemicals. RIS employees receive extensive training to enable them to perform their jobs correctly and safely. Each RIS Operations employee receives hundreds of hours of supervised, on the job training to learn operating procedures and proper techniques to operate process equipment and machinery. All RIS employees receive 40 hours of RCRA and OSHA t raining within their first six months of employment. This safety training helps RIS employees recognize and manage the hazards associated with their jobs. It also provides organized and consistent procedures to respond to emergency situations, including chemical spills and fires. Refresher training is provided annually to apprise each employee of facility process upgrades, potential process hazards, and safety procedure changes. RIS trainers review emergency response responsibilities, contingency plan implementation criteria and site evacuation procedures during this annual training. Additionally, each RIS employee attends monthly safety training sessions where he or she focuses on applicable OSHA safety procedures and established safety programs. Qualified safety and health professionals provide training at RIS. Facility Information RIS is a commercial hazardous waste treatment and storage facility located in rural Lorain County, Ohio. RIS began its waste management operation s in 1949. Its primary method of waste treatment is and has always been incineration. The entire RIS facility encompasses approximately 80 acres and is surrounded by farmland, dense woodland and a small residential area. RIS thermally treats non-hazardous and hazardous solid and liquid wastes including spent solvents, paint solids and off specification chemicals and chemical products from manufacturing facilities. RIS has drum and bulk storage capabilities and is permitted to store waste for treatment in tanks and in a covered, open sided container storage facility. RIS complies with State and Federal regulations for hazardous waste treatment and storage facilities (RCRA). RIS operates under a Federal RCRA Part B permit. It also complies with OSHA standards and State and Federal air standards specific to the treatment of hazardous wastes. Waste Management Processes For the purposes of this submittal, RIS considered four processes that encompass the entirety of its facility opera tions. With the exception of RIS' Container Storage Facility ("CSF") each of these processes is made up of several units. These processes include: 1) CSF storage 2) Movement and handling of bulk waste (tankers and roll-off containers) and small containers on-site (including waste repackaging activities performed outdoors, and staging and set-up for processing near the incineration system) 3) Waste management activities at the Process Dock, placement and storage of liquid wastes in the Tank Farm tanks, and processes in RIS' Metering Building 4) Waste feeds to the Incineration System To determine the applicability of this Accidental Release Prevention regulation to the RIS facility, RIS reviewed its records for a three year period to determine which of the regulated chemicals were received and managed at RIS above the listed Threshold Quantity ("TQ"). The following list provides the names of these chemicals. It is important to note that these chemicals were received from manufac turers as wastes and waste mixtures rather than as products. Toxic Substances Acrylonitrile Epichlorohydrin Piperidine Phosphorus Oxychloride Phosphorus Trichloride Allyl Alcohol Vinyl Acetate Monomer Formaldehyde Hydrochloric Acid 37% Toluene Diisocyanate (unspecified monomer) Chloroform Hazard Assessment The regulated chemicals that were received above the TQ were then evaluated in an off-site consequence analysis that considered management of these chemicals in the processes described above. Both a Worst Case analysis and an Alternative Case analysis were run following standard assumptions found in U.S. EPA's Off-Site Consequence Analysis Guidance and specified modeling program. Following is a summary of RIS' worst case and alternative case release scenarios. We want to emphasize that the possibility of these scenarios actually occurring is very remote for several reasons. First, the assumptions used to determine the worst case off-site release scenari os were highly conservative. It is highly unlikely that a tank or tanker would fail in such a way that the entire contents of the material would be released. These scenarios do not take into account the preventative measures currently incorporated into RIS' standard operating procedures, or the emergency response procedures that would minimize or prevent potential off-site releases. For example, routine inspections of tanks, tankers and other containers help prevent the potential for a spill of the nature described here. In the event of an incident, materials would be secondarily contained. Secondary containment is designed to mitigate releases. In addition, RIS' ERT members would immediately act to contain and clean up the waste material, and the release rate to the air would be minimal. Offsite Consequence Analysis Modeling Results * Worst-case release scenario - toxic substances This worst-case scenario represents all toxic regulated substances held above the listed thres hold quantity. It assumes that a bulk tanker of a liquid waste containing the regulated chemical Acrylonitrile would fail in an uncontained area of the RIS facility. The percentage of the regulated chemical in the waste and the capacity of the tanker were used to determine the quantity of the regulated chemical released during this scenario. No active mitigation was considered for this worst-case release scenario. According to U.S. EPA's Off-Site Consequence Analysis Guidance and specified modeling program, this potential release would reach offsite endpoints and nearby public receptors. * Alternative Case release scenarios - toxic substances The following provides release scenarios for each regulated toxic substance managed in a process at RIS above the listed threshold quantity. 1. CSF Storage For a regulated toxic chemical stored in a tanker at the CSF, it was assumed that a piping connection on a tanker would fail. The duration of the spill was estimated to be about 20 minutes. The material would fall into a secondary containment area, thereby limiting the exposed surface area of the pool and reducing the release rate to the air. For containerized toxic substances, it was assumed that a container at the CSF dock would fail. The spill rate would be 55 gallons/minute and the duration of the spill would be one minute. The material would fall into a secondary containment area, thereby limiting the exposed surface area of the pool and reducing the release rate to the air. 2. Movement and handling of bulk waste and small containers on-site For bulk wastes in transit at RIS, it was assumed that a piping flange or a valve on a tanker moving on-site would fail in an uncontained area. The duration of the spill was estimates to be about 20 minutes. No passive mitigation was considered. For containerized material, it was assumed that a container in set-up for incineration would fail. It was assumed that the spill rate would be 55 gallons/minute and the duration of the spill would be one minute. The material would fall into a secondary containment area, thereby limiting the exposed surface area of the pool and reducing the release rate to the air. 3. Waste management activities at the Process Dock, Tank Farms, and Metering Building. For bulk wastes it was assumed that a tank in the tank farm would be overfilled. The duration of the spill would be about ten minutes. The material would fall into a secondary containment area, thereby limiting the exposed surface area of the pool and reducing the release rate to the air. For containerized material, it was assumed that a container being pumped would spill in its entirety or fail. It was assumed that the spill rate would be 55 gallons/minute and the duration of the spill would be one minute. The material would fall into a secondary containment area, thereby limiting the exposed surface area of the pool and reducing the release rate to the air. 4. Waste feeds to the I ncineration System For bulk material it was assumed that piping leading from the tank farm to the metering building would be sheared. The duration of the spill was estimates to be about ten minutes. The material would fall into a secondary containment area, thereby limiting the exposed surface area of the pool and reducing the release rate to the air. For containerized material, it was assumed that a direct feed container would fail. It was assumed that the spill rate would be 55 gallons/minute and the duration of the spill would be 1 minute. The material would fall into a secondary containment area, thereby limiting the exposed surface area of the pool and reducing the release rate to the air. The Alternative Case release scenarios described above showed off-site impacts for Acrylonitrile, Epichlorohydrin, Piperidine, Phosphorus Oxychloride, Phosphorus Trichloride, Vinyl Acetate Monomer, Hydrochloric Acid, and Chloroform. There were no off-site impacts for Allyl Alcohol and Toluene Diisocyanate (all 4 scenarios). Five Year Accident History RIS has not had an accidental release of a regulated chemical within the last five years at the RIS facility. Emergency Response Program RIS has plans and agreements in place with local response organizations to respond to emergencies at the RIS facility. RIS' Contingency Plan addresses various types of potential emergency situations, including spills, fires, civil unrest, employee injuries, earthquakes and high winds. Under its Contingency Plan, RIS will notify and work with the local fire departments, sheriff, and hospital to control most emergency situations. A crisis communication plan also is in place to address more serious incidents with members of the local community. In extreme emergency situations, RIS may notify and seek assistance from the following organizations: * American Red Cross * Army Corps of Engineers * CHEMTREC * Environmental Emergency Response Center, U.S. EPA Region V * Lorain County Disaster Services * Lorain County Local Emergency Planning Committee * National Response Center * Ohio EPA Emergency Response Currently six of RIS' key Operations personnel are trained as Emergency Coordinators ("EC's") to manage emergency situations at the RIS facility. An EC is on-site or on-call 24 hours per day, seven days per week. It is the EC's responsibility to determine the degree of any emergency condition and coordinate response actions accordingly. RIS employs an ERT to act as first responders during most emergency situations. These qualified and trained RIS employees immediately clean up chemical spills and extinguish small fires. They are trained in first aid and CPR and provide limited medical assistance to injured employees. The EC may assemble the appropriate response team for any emergency situation by utilizing ERT members, Operations personnel, safety and health professionals employed by RIS, and any appropriate off-site emergency management personnel. In Conclusion RIS has a continued commitment to maintain and improve safety at its facility. RIS would like to emphasize that its business success and its commitment to protection of human health and the environment are consistent and complimentary goals. We believe that much can be done to prevent environmental accidents, and we are committed to maintaining an environmentally sound, safe, and healthy workplace for the benefit of our employees and our community. We are committed to complying with State and Federal regulations regarding working conditions and accident prevention. We will communicate our safety, health and environmental achievements and challenges openly, honestly, clearly, and professionally with employees, customers, our community, and government agencies. |