AXCHEM, INC. - Executive Summary

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                      EXECUTIVE SUMMARY 
This Risk Management Plan (RMP) has been prepared to meet the requirements of the Risk 
Management Program Rule.   
As part of complying with the Risk Management Program Rule, the AXCHEM, Inc. (AXCHEM) 
facility in Wayne, Michigan has reviewed and enhanced previously existing accidental release 
procedures and emergency response policies.  A formal Emergency Action Plan has been 
developed and implemented that includes the following: 
    Emergency Notification and Communication Procedures  
         Fire / Explosion 
         Bomb Threat 
         Severe Weather Conditions and Natural Phenomenon 
         Environmental Chemical Spill / Release 
         Power and / or Equipment Failure 
         Interruption or Failure of Fire Protection Equipment 
         Civil Disturbance 
    Plant Emergency Alarm          
         Recognition, Initiation, Evacuation, and Assembly 
    Plant Emergency Plan Responsi 
         Emergency Action Coordinator 
         Site Operating Procedure 
    Fire and Hazard Area Identification 
         Site Plot Plan / Map      
    Emergency Evacuation Exits and Points of Assembly 
         Rescue Procedures 
    Emergency Procedures 
         Electrical Power Failure 
         City Water Failure 
         Hazardous Material Spill Response 
              Documentation Procedure 
              First Responder Operations Level Spill Containment and Disposal  
              Public and Private Spill Containment and Disposal Services including  
                   CHEMTREC / CHEMNET 
         Bomb Threat 
         Crowd Control 
         Public Disturbance 
         Tornado, Flood, Earthquake, Severe Storms 
    Fire and Hazardous Material Spill Emergency Pre-Plan 
         Cooperative Community Efforts, Drills, Tours (LEPC) 
         Material Safety Data Sheets for Chemical Subst 
         Emergency Procedures and Equipment 
         Life Safety 
    Emergency Equipment, Supplies and Material List (Inventory) 
         Emergency Action Plan 
         Incipient Fire Fighting 
    First Responder Operations Level Spill Containment and Disposal 
There are two substances at the AXCHEM facility that are regulated by the Chemical Accident 
Prevention Provisions defined at 40 CFR Part 68.  These substances are used in various 
processes throughout the facility to produce water treatment polymers. Substances that are used by 
AXCHEM that are regulated as either toxic substances or flammable substances by 40 CFR Part 68 are 
as follows: 
Toxic Substances: 
    Formaldehyde: Formaldehyde is received and stored as a 37 percent solution in water.  
    The maximum amount of 37 percent formaldehyde stored on-site is 56,000 pounds 
    (21,000 pounds pure formaldehyde). 
Flammable Substances: 
    Dimethylamine: Dimethylamine is 
received and stored as a 60 percent solution in  
    water.  The maximum amount of 60 percent dimethylamine stored on-site is 57,000  
    pounds (37,000 pounds pure dimethylamine). 
Worst-case Scenarios: 
As required by the Risk Management Program Rule, worst case and alternative release scenarios were 
evaluated and are discussed in this RMP.  As required, worst case scenarios are presented in the RMP 
for one toxic substance and one flammable substance.  Alternative scenarios were prepared for each 
of the toxic substances with worst case endpoints located offsite and for one flammable substance.  
The endpoint represents the distance at which a released substance must travel before it disperses 
sufficiently to no longer pose a hazard to the public.   
For the worst case scenario, EPA has defined a worst-case release as the release of the largest 
quantity of a regulated substance from a vessel or process line failure that results in the greatest 
distance to a specifie 
d endpoint.  For the worst-case analysis, the possible causes of the 
worst-case release or the probability that such a release might occur are not considered.  The 
release is simply assumed to take place and the greatest amount held in a vessel is suddenly 
released.  The results of the worst case scenario analysis were as follows: 
         Toxic Substances: The formaldehyde storage tank was assumed to fail and subsequently 
produce an instantaneous release of the entire tank contents.  The release was assumed to evaporate 
over a 10-minute time period.  The passive mitigation control of the tank dike were considered in 
limiting the release impacts.  The distance to the toxic endpoint was estimated to be less than 0.06 
miles.  The release rate was calculated to be 0.01 pounds per minute.  However, a release rate of 
0.2 pounds per minute was entered into the RMP Submit document since this is the lowest value that 
can be entered into the program. 
         Flammable Substanc 
es: The dimethylamine storage tank was assumed to fail and subsequently  
produce an instantaneous release of the entire tank contents that results in a vapor cloud 
explosion.  No passive mitigation controls were considered in limiting the release impacts.  The 
distance to the explosion endpoint was estimated to be less than 0.24 miles. 
Alternative Release Scenarios: 
Alternative release scenarios are more realistic scenarios that result in endpoints that affect 
public receptors. For formaldehyde the release was assumed to occur as a result of the uncoupling or 
rupture of a  transfer hose during unloading operations into a contained area.  For flammable 
materials, the alternative release scenario assumed that dimethylamine was released as a result of 
the uncoupling or rupture of a hose during unloading operations. The durations for releasing these 
materials from a vessel/pipe for the alternative release scenarios were assumed to occur over a 
0.5-minute time period for bo 
th formaldehyde and dimethylamine since the unloading operations are 
supervised.  With the exception of considering that these transfer operations  are monitored by 
personnel at all times, no other active mitigating controls were assumed to limit the releases. The 
results of the alternative release scenario analysis were as follows: 
         Toxic Substances: 
                   Formaldehyde, 37 percent - 0.06 miles 
         Flammable Substance: 
                   Dimethylamine, 60 percent - 0.06 miles 
Prevention Program: 
To address potential accidental releases, an accidental release prevention program along with 
chemical specific prevention steps have been developed. The key parts to the program are:   
    Formal Company Risk Management Procedure that includes: 
         Management System Responsibilities 
         Risk Management Plan Coordinating Review Team 
         Risk Management Plan Changes and Updating 
         Communication and Coordination of Risk Management Information 
    DOT Hazardous Material Training 
    Contractor Performance Selection Process 
    Operating Procedures 
    Emergency Procedures 
    New Employee Environmental Health and Safety Orientation Training Program 
    Process Safety Program Auditing 
    24-hour Emergency Communications 
Additionally, the facility has programs to address the OSHA Process Safety Management (PSM) 
requirements for the chemicals formaldehyde and dimethylamine such as: 
    Mechanical Integrity - Preventive Maintenance of Equipment 
    Pre-startup Safety Reviews 
    Management of Change 
    Process Hazard Analysis 
    Incident Investigation 
Emergency Response Program: 
The facility also has an emergency response program (ERP) that has been enhanced as part of 
implementing the Risk Management Program.  The ERP has historically been coordinated with 
the City of Wayne LEPC and the local emergenc 
y dispatcher (i.e., 911). 
As part of preparing the RMP, the facility's five year accident history was reviewed. No 
accidental releases from covered processes have occurred that resulted in deaths, injuries, or 
significant property damage on-site or off-site; or resulted in off-site evacuations or sheltering 
in place.  
Safety Improvement: 
AXCHEM is committed to continuous improvement of safety.  AXCHEM plans to periodically review the 
policies, procedures, and activities associated with the RMP as required by the regulations.
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