DPC ENTERPRISES - Executive Summary

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EXECUTIVE SUMMARY 
 
1.    Accidental Release Prevention and Emergency Response Policies 
DPC Enterprises (DPCE) is 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 comply with all  
applicable federal, state, and local regulations as well as implement appropriate controls to  
prevent possible releases of regulated substances. 
 
Our emergency response program includes procedures for notification of the local fire  
department; notification of any potentially affected neighbors; and notification of local, state and  
federal agencies.   Safety is an essential part of our operations, the safety devices built-in to the  
design of this facility, the safe handling procedures that we use, and the extensive training of our  
 
personnel. 
 
2.    The Stationary Source and the Regulated Substances Handled 
DPCE is part of a 52-year-old company whose primary activities encompass distributing and  
repackaging inorganic chemicals and compressed gases as well as manufacturing water treatment  
products. For example, chlorine is used to produce sodium hypochlorite commonly know as  
household bleach.   We are headquartered in Houston, Texas and operate more than 20 plants  
across the United States. 
 
We have these regulated substances at our facility: Ammonia (anhydrous), Chlorine, and Sulfur  
Dioxide (anhydrous).  DPCE stores these materials in 150-lb. cylinders, 800-lb. containers, and  
ton containers for use by our customers. 
 
The maximum inventories of these substances at this facility are: 
 
Ammonia (anhydrous) ? 10,000 lbs. 
Chlorine  - 70,000 lbs. 
Sulfur dioxide (anhydrous) ? 10,000 lbs. 
 
3.    The Worst Case Release Scenario(s) and the Alternative Release  
Scenario(s), including administrative controls and mitigation m 
easures to  
limit the distances for each reported scenario 
To perform the required offsite consequence analysis for our facility, we have used the EPA's  
RMP Guidance for Wastewater Treatment Plants Reference Tables or Equations.  The following  
paragraphs provide details of the chosen scenarios. 
 
The worst case release scenario submitted for Program 3 toxic substances as a class involves a  
catastrophic release from Chlorine storage.  The scenario involves releasing the entire contents of  
a ton container in a gaseous form over 10 minutes.  This release would reach the toxic endpoint  
(0.0087 mg/l or 3 ppm) and public receptors. 
 
One alternative release scenario (ARS) has been submitted for each toxic substance present in  
Program 3 processes.  DPCE has assumed the substances would be released in a gaseous form  
over 30 minutes.  First, the ARS for Ammonia is a vessel leak which would reach the toxic  
endpoint (0.14 mg/l or 200 ppm) and public receptors.  Second, the scenario for Chlo 
rine is a  
vessel leak that would reach the toxic endpoint (0.0087 mg/l or 3 ppm) and public receptors.   
Last, is the ARS for Sulfur dioxide (anhydrous) involving a vessel leak.  This release would  
reach the toxic endpoint (0.0078 mg/l or 3 ppm) and public receptors. 
 
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.  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.    The following sections briefly describe the  
elements of the release prevention program that is in place at our stationary source. 
 
Process Safety Information 
DPCE maintains a detailed record of safety information that describes the chemical hazards,  
operating parameters and equipment designs asso 
ciated 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  
What If/Checklist (combined).  The studies are undertaken by a team of qualified personnel with  
expertise in engineering and process operations and are revalidated every 5 years as required or  
as necessary.  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 processes, DPCE maintains  
written operating procedures.  These procedures address various modes of operation such as  
initial startup, normal operations, temporary operations, emergency shutdown, emergency  
operations, and normal shutdown.  The information is regularly reviewed and is readily  
accessible to operators involved in the processes. 
 
Training 
DPCE has a compreh 
ensive 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 3 years and more frequently as needed. 
 
Mechanical Integrity 
DPCE carries out highly documented maintenance checks on process equipment to ensure proper  
operations.  Process equipment examined by these checks includes among others; pressure  
vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems,  
controls and pumps.  Qualified personnel carry out maintenance operations 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 DPCE to manage changes in process chemicals, technology,  
equipment and procedures.  Pro 
cess 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 DPCE.  These reviews are conducted to confirm that  
construction, equipment, operating and maintenance procedures are suitable for safe startup prior  
to placing equipment into operation. 
 
Compliance Audits 
DPCE conducts audits on a regular basis to determine whether the provisions set out under the  
RMP rule are being implemented.  These audits are carried out at least every 3 years and any  
corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
 
Incident Investigation 
DPCE promptly investigates any incident that has resulted in, or could reasonably result in a  
catastrophic rele 
ase 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 a minimum of 5 years. 
 
Employee Participation 
DPCE truly believes that process safety management and accident prevention is 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.  DPCE 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 
DPCE has had an excellent record of preventing accidental releases over the last 5 years.  Due to  
our stringent release prevention policies, there have been no accidental releases from our facility  
during this period. 
 
6.    Emergency Response Plan 
DPCE 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.  In addition, the plan is promptly updated to reflect any pe 
rtinent changes taking place  
within our processes that would require a modified emergency response. 
 
A copy of our emergency response plan has been provided to the Sedgwick County Local  
Emergency Planning Committee (LEPC) and the fire department. 
 
7.    Planned Changes to Improve Safety 
DPC continues to participate in the Chlorine Institute as well as other associations, and continues  
to improve our operations. 
 
8.    Certification Statement 
The undersigned certifies that to the best of his knowledge, information, and belief, formed after  
reasonable inquiry, the information submitted is true, accurate and complete. 
 
 
                                                    
Wayne L. Penick                            Date Signed 
Manager-Safety, Health, & Environmental Services 
 
DPCE ? WICHITA, KANSAS (8/00)        Page 1 of 4
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