Arch Chemicals, Inc - Executive Summary |
|
ARCH CHEMICALS INC. ROCHESTER RMP EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Arch Rochester, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document is a re-submittal of our original RMP that is being made because of a process change to our 2PCL process which warrented a process hazard analysis. The change to the process does not change our original worst case or alternate case scenarios. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of resul ts from our assessment of the potential off-site consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications that EPA's RMP rule requires us to provide * The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility produces biocides, and custom chemical products. Biocides are used in anti-dandruff shampoo, anti-foulant paints and coatings. Custom chemicals go into crop protection products, pharmaceuticals and metal working fluids. The Rochester facility has been in operation since 1950 and currently employs 152 full time employees. The plant is operational 7 days per week, 365 days a year. The following chemicals, used at the Rochester site, have been identified by EPA as having the potential to cause significant off-site consequences in the event of a substantial accidental release: Toxics Quantity Handled (pounds) *Chlorine.........................................................................................360,000 *Chloroform......................................................................................88,000 *Perchloromethyl Mercaptan (PCMM).............................................284,000 Flammables *No Covered Flammables Used At The Rochester Facility Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario(s) - Regulated Toxic Chemicals Our worst -case release scenario for toxic chemicals involves a catastrophic rupture of a chlorine railcar within the plant property. The required assumption is that the entire contents(180,000 lbs.) of chlorine would be released to the air within 10 minutes. The assumed weather conditions are:wind speed, 1.5 m/sec; temperature, 25 degrees centigrade; and relative humidity, 50%. Under the above stipulated weather conditions, the chlorine could travel 25 miles before dispersing enough to no longer pose a significant hazard to the public. Within this release area, there would b e potential exposure to schools, homes, businesses, shopping malls, nursing homes, parks and recreational areas. To ensure that a scenario of this type never occurs, the following safety measures are taken: -Substantial construction of chlorine cars -Regular predictive maintenance of chlorine cars and ancillary equipment - Excess flow valve on chlorine car to stop the release -Chlorine monitors Alternate Release Scenarios: 1) Chlorine: This alternative release scenario assumes a leak and subsequent vaporization of chlorine from the 2-chloropyridene (2PCL) system. The entire contents of the chlorine process piping system would be released due to failure of a flange gasket just outside of the vaporizer building amounting to a quantity of 667 pounds. This flange is approximately 200 feet from the closest chlorine monitor; therefore, it is assumed that it would take an employee 5 minutes to notice the leak and an additional 3 minutes to close the emergency shut-off valve on the chlor ine car. Then, the emergency alarm would be manually activated and the response team would be on the scene with-in approximately 20 minutes from the time that the manual alarm is pulled. This scenario assumes that the entire pipeline contents would be released prior to the response team arrival on site, but if the rate of release is slower than 24 lb./min., the remaining chlorine in the pipeline could be neutralized by venting to the V-C-17 scrubber. 8522 public receptors would potentially be impacted within the 0.98 mile distance that the toxic plum could travel. Local businesses and neighbors would be notified to shelter-in-place by calling the 911 emergency response network within 10 minutes of the start of the release. 2) CHLOROFORM This scenario assumes a leak in the piping extending from the chloroform storage tank to the Terrazole (R) crop protection chemical sub-process called 2422. The leak would be active for the entire 30 minutes of the daily transfer of chlo roform from storage to the process. It would not be detected until the operator performs his routine line walk-down as required by plant operation policy. The operator would alert the in-house emergency response team by sounding the plant-wide alarm. Local businesses and neighbors would be notified to shelter-in place by calling the 911 emergency response network within 40 minutes of the start of the release. The emergency response team will arrive on the scene within 15 minutes and it will take an additional 15 minutes to control and clean up the spill. 105 pounds of chloroform would be release in this scenario. The resulting toxic plum could reach 30 public receptors within a 0.090 mile radius from the process site. 3) PCMM 0.2 pounds of perchloromethyl mercaptan (PCMM) would be released within a 5 minute period in this scenario. The leak would be incurred while unloading the bulk tank truck to the bulk storage tank. Since this operation is always attended by an operator , it would be detected and stopped within 5 minutes. Although this chemical has a very low volatility, it can pose a serious health hazard due to it's low OSHA permissible exposure limit (PEL) of 0.1 ppm. Therefore, the unloading operator would notify the response team to mitigate the spill by manually activating the emergency alarm system. Local businesses and neighbors would be notified to shelter-in-place by calling the 911 emergency response network within 10 minutes of the start of the release. 13 public receptors could potentially be impacted within 0.06 miles distance of the release. Mitigation measures: - Safety and Emergency Response Drills - Activation of Monroe County Emergency Action Plan - Prompt Notification To Citizens (Including What Action To Take, e.g. shelter-in-place, Evacuation, etc.) We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACC IDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors In addition to the above systems that are a part of the Arch Chemical employee's daily routine, we conduct thorough cross-functional hazard reviews on a step-wise basis from research all the way through to the operational phase. Introduction of a new chemical manufacturing process requires qualification/certification of both the physical plant and human elements. High standards are maintained throughout each stage in compliance with a ll applicable safety regulations. This process is called the "Safety in Engineering Technology Construction Operations" or SETCO hazard review. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years: Chlorine: - A total of (1) release: 1/20/98: (1) pound leak of chlorine from a transfer line; (1) employee received a minor inhalation injury. PCMM: - No releases Chloroform: - No releases We conducted a formal incident investigation for the above incident to correct the root causes of the event. EMERGENCY RESPONSE PROGRAM We maintain a comprehensive emergency response plan, which has been coordinated with the Monroe County, New York Emergency Response Plan. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we have conducted joint training and drills with the local fire department utilizing the county notification system. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of some improvements that were made at the facility to help prevent and/or better respond to accidental chemical releases since the original RMP was submitted: Numerous changes have been implemented over the past few years to further improve process safety. Some additional key improvements that the facility is implementing includes: >PHA recommendation follow-up. >Enhanced Contractor Safety Program. >Continued implementation of the "Goal is Zero" Initiative: zero injuries; zero environmental releases; zero community complaints. >Increased behavioral based safety observations which focuses on decreasing at-risk employee and contractor employee behavior and injuries. CERTIFICATIONS Within the past five years, the processes have had no accidental release that caused off-site impacts provided in the RMP rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent off-site impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process(es), entry within the distance to the specifi ed end-points may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RM Plan. 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. For all other covered processes, the undersigned also certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RM Plan is true, accurate, and complete. Signature: R.J. Stadalius Title: Plant Manager Date: 10/12/00 RMP DATA ELEMENTS The following pages present additional information about our risk management program that EPA's RMP rule requires us to provide. This information is categorized as follows: * Registration * Off-site consequence analysis * Five-year accident history * Program 2 prevention program * Pro gram 3 prevention program * Emergency response program |