Van Waters & Rogers 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 Van Waters & Rogers 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. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Blending, repackaging and distribution of chemicals.. We have 4 regulated substances present at our facility. These substances include Ammonia (aqueous), Cyclohexylamine [Cyclohexanamine], Formaldehyde (solution) and Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid]. Ammonia (aqueous ) is used for ____________________________. Cyclohexylamine [Cyclohexanamine] is used for ____________________________. Formaldehyde (solution) is used for ____________________________. Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid] is used for ____________________________. 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 required offsite consequence analysis for our facility, we have used the EPA's RMP*Comp(TM). 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 Warehousing Operations. In this scenario 2100 lb. of Cyclohexylamine [Cyclohexanamine] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to ___% of the maximum capacity of the source by a system of administrative controls. Passive mitigation systems such as dike(s) and enclosure(s) are also taken into account to calculate the scenario. These mitigation systems have the effect of ___________________________. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.3 miles is obtained corresponding to a toxic endpoint of 0.16 mg/L. An additional worst case release scenario for Program 2 and 3 toxics, involving a catastrophic release from Bulk Operations, is also included in the RMP because __________________________. In this scenario 36250 lb. of Cyclohexylamine [Cyclohexanamine] is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to ___% of the maximum c apacity of the source by a system of administrative controls. Passive mitigation systems such as dike(s) and sumps(s) are also taken into account to calculate the scenario. These mitigation systems have the effect of ___________________________. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.3 miles is obtained corresponding to a toxic endpoint of 0.16 mg/L. One alternative release scenario for Cyclohexylamine [Cyclohexanamine] involves a release from Warehousing Operations. The scenario involves the release of 180 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 5 minutes. Passive mitigation controls such as berms(s) and enclosure(s) are taken into account to calculate the scenario, having the effect of __________________. The release is also assumed to be controlled by sprinkler system(s) and Emergency Response Team and equipme nt.. These active mitigation systems have the effect of _________________. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.16 mg/L of Cyclohexylamine [Cyclohexanamine] is 0.1 miles. The alternative release scenario for Formaldehyde (solution) involves a release from Warehousing Operations. The scenario involves the release of 228 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 5 minutes. Passive mitigation controls such as berms(s) and enclosure(s) are taken into account to calculate the scenario, having the effect of __________________. The release is also assumed to be controlled by sprinkler system(s) and Emergency response team and equipment.. These active mitigation systems have the effect of _________________. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.012 mg/L of Formaldehyde (soluti on) is 0.1 miles. Another alternative release scenario for Cyclohexylamine [Cyclohexanamine] involves a release from Bulk Operations. The scenario involves the release of 1450 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 2 minutes. Passive mitigation controls such as dike(s) and sumps(s) are taken into account to calculate the scenario, having the effect of __________________. The release is also assumed to be controlled by emergency shutdown system(s) and Foam fire suppression system; Emergency Response Team and equipment.. These active mitigation systems have the effect of _________________. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.16 mg/L of Cyclohexylamine [Cyclohexanamine] is 0.1 miles. The alternative release scenario for Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] involves a rel ease from Warehousing Operations. The scenario involves the release of 253 lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 5 minutes. Passive mitigation controls such as berms(s) and enclosure(s) are taken into account to calculate the scenario, having the effect of __________________. The release is also assumed to be controlled by sprinkler system(s), neutralization, emergency shutdown system(s) and Emergency Response Team and equipment.. These active mitigation systems have the effect of _________________. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid] is 0.1 miles. The alternative release scenario for Ammonia (conc 20% or greater) involves a release from Warehousing Operations. The scenario involves the release of 187 lb. of . Toxic liq uid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 5 minutes. Passive mitigation controls such as sumps(s) and enclosure(s) are taken into account to calculate the scenario, having the effect of __________________. The release is also assumed to be controlled by sprinkler system(s), neutralization, emergency shutdown system(s) and Emergency Response Team and equipment.. These active mitigation systems have the effect of _________________. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (conc 20% or greater) is 0.0 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 Sta ndard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Van Waters & Rogers 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 What If. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of _________. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 06/16/2000. Operating Procedures For the purposes of safely conducting activities within our covered processes , Van Waters & Rogers 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 Van Waters & Rogers 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 _____ years and more frequently as needed. Mechanical Integrity Van Waters & Rogers Inc. 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, contr ols and pumps. 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 Van Waters & Rogers Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 10/07/2000. 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 Van Waters & Rogers Inc.. The most recent review was performed on 10/07 /2000. 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 Van Waters & Rogers Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on __________. 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 Van Waters & Rogers 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 a minimum of 5 years. Employee Participation Van Waters & Rogers Inc. 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. Van Waters & Rogers 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 Van Waters & Rogers Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Van Waters & Rogers 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. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. NA is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planne d Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by _________. |