Prillaman Chemical, Martinsville Division - Executive Summary

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Policy Statement 
 
Prillaman Chemical Corporation, a wholly owned subsidiary of Ellis and Everard, was originally founded in 1939.  Prillaman Chemical is an industrial chemical distributor that provides products in support of industries, ranging from food and water treatment to textiles and furniture.  Activities include warehousing, packaging, bulk transfer and formulation of many common industrial chemicals.  We serve Virginia, North Carolina, South Carolina and Tennessee.     
 
We are members of the National Association of Chemical Distributors (NACD) and as members, we pledge to manage our business according to the principles of the NACD's Responsible Distribution Process.  This process provides a system that promotes continuous improvement in the health, safety and environmental performance of our company and is designed to be sensitive and responsive to community needs and public concerns.  In addition, Prillaman Chemical has a Quality improvement process that makes safety and envi 
ronmental concerns an on-going priority. 
 
We as team members of Prillaman Chemical and as members of our communities are committed to the safe handling of the products that we distribute as well as the safe operation of our facilities, but we also recognize that emergencies relating to those activities can occur. It is our policy to ensure that emergency response units and the public will have adequate information to allow them to react properly to emergencies, which could result from our activities. Accordingly, we have written procedures, which we will take to minimize the effects of such events. 
 
Facility Description 
 
Prillaman Chemical Corporation, Martinsville Division, operates two chemical warehouses, a drum reconditioning facility, a Part B Permitted storage facility, and a chemical distribution facility located at 825 Fisher Street, Martinsville, VA. Prillaman stores and distributes 150 pound cylinders of chlorine and sulfur dioxide at the 906 Fisher Street warehouse, These tw 
o chemicals are regulated as toxics under EPA's Risk Management Programs (RMP), 40 CFR Part 68 and OSHA's Process Safety Management (PSM), 29 CFR 1910.119. 
 
Release scenarios  
 
Chlorine and sulfur dioxide are both stored as a gas liquefied by pressure in 150-pound cylinders. Release scenarios were modeled using EPA's RMP*CompTM.  
 
A worst case scenario was run using 150 lbs. of a gas being released at a rate of 15 lbs./min. for 10 min. This scenario assumed a wind speed of 1.5 meters/sec. with an "F" atmospheric stability class in an urban area. Using data from the LandView IIITM   software developed by EPA's Chemical Emergency Preparedness and Prevention Office (CEPPO), it was determined that there would be public receptors effected by a release of this nature. The receptors consisted of residences and light industry. There were no schools, hospitals, correctional facilities, recreational areas, or environmental receptors found within the distance to the endpoints. 
 
The most likely ty 
pe of release from this facility would be from a fuse plug or valve failure. In this scenario 150 lbs. of gas being released at a rate of 1.0 lbs./min. for 150 min. was used. The scenario assumed a wind speed of 1.5 meters/sec. with an "F" atmospheric stability class in an urban area. Although the distance to the end point was 75% less in the alternative release than the worst case there would still be some residences and light industry within the distance to the endpoint. 
 
Release prevention 
 
The Martinsville Division of Prillaman Chemical stores and distributes 150 pound cylinders of chlorine and sulfur dioxide at the 906 Fisher Street warehouse. 
Each cylinder valve is covered with a steel protective cap to prevent damage to the valve during the handling of the cylinders. All cylinders are checked during the unloading and loading process for damage in transportation. All cylinders are stored in an area away from constant forklift traffic to prevent the cylinder from potentially being 
damaged by forklift traffic.  
 
All personnel handling cylinders receive training in the proper handling of cylinders. These procedures include proper use of material handling equipment, transportation bracing and blocking for transportation, and forklift training. 
 
All cylinders are visually inspected and are chemically checked for leaks on a daily basis. If a leak is detected it is immediately reported and corrected action taken by on-site personnel trained in emergency response. 
 
Five-year accident history 
 
There has been no release from a process covered by 40 CFR Part 68 involving a regulated substance that has caused: 
 
X On-site deaths, injuries, or significant property damage;                 or 
 
X Known offsite deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place. 
 
Emergency Response 
 
Prillaman Chemical Corporation has adopted a policy of providing emergency response information concerning the products that it handles. 
 
At all times, there is at lea 
st one employee either on the Facility premises or on call and able to reach the Facility in a short time, with the responsibility for coordinating all emergency response measures.  This emergency coordinator is thoroughly familiar with all aspects of the Facility contingency plan, all operations and activities at the Facility. In addition this person has the authority to commit the resources needed to carry out the contingency plan. Any person discovering an abnormal situation should contact the emergency coordinator or the alternate if the primary emergency coordinator is unavailable. 
 
This plan will be implemented whenever there is an imminent or actual emergency situation involving fire, explosion, spill, or other release of materials to air, soil, and groundwater or surface water.  The Emergency Coordinator or alternate has the responsibility for implementing this plan.  Situations that may initiate implementation of the plan include: 
 
-    Any spill that could result in a fire, 
-     A 
ny spill that could escape containment, 
-    Any spill that could produce toxic fumes in sufficient quantity to cause environmental impairment or present a threat to humans, 
-     Any fire, and 
- Any explosion that could occur causing flying fragments or shock waves. 
 
All personnel working at the Facility will be notified by the sounding of alarms and/or by intercom.  If the fire alarm is sounded, employees are to evacuate the Facility by preplanned routes. In the event of extreme emergencies, neighboring facilities may be notified by telephone. 
 
After notifying Facility personnel, the Emergency Coordinator will notify all appropriate local, State, and Federal emergency response groups, as needed. 
 
The Emergency Coordinator will immediately identify the character, exact source, amount, and extent of the release. Should site conditions indicate that evacuation of local areas may be necessary, the Emergency Coordinator will immediately notify local authorities and the State Emergency Response  
Team by telephone. 
 
After assessing the nature and extent of the emergency situation, the Emergency Coordinator will initiate response procedures with the assistance of plant emergency personnel and the assistance of any available outside group. 
 
A copy of this plan and all revisions to the plan shall be: 
 
1. Maintained at the Facility; 
 
2. Submitted to the local police department, fire department, hospital and local emergency planning committee, Virginia State Hazardous Waste Emergency Response Team; and 
 
3. Submitted to outside remediation companies in the event their services are required.  
 
Review and Testing of the Emergency Plan 
 
We annually review, test and assess the operability of our Emergency Contingency Plan. The plan is tested by using one or more of the following techniques. 
 
1. By conducting evacuation and response drills based upon realistic emergency scenarios. 
2. By conducting a scheduled tabletop exercise with local officials. 
3. By conducting a scheduled or unschedu 
led actual exercise including responding organizations. 
 
Assessment reports will be issued and corrective deficiencies documented. The employees are reviewed trained on any resulting changes.
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