Hickson DanChem Corporation - Executive Summary |
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General Executive Summary Risk Management Plan Hickson DanChem Corporation 1. Accidental Release Prevention and Emergency Response Policies We at Hickson DanChem Corporation 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 Custom chemical manufacturing.. We have 3 regulated substances present at our facility: Hydrochloric acid [Hydrogen chloride], Vinyl acetate monomer [Acetic acid ethenyl ester], and Vinyl methyl ether [Ethene, methoxy-]. Hydrochloric acid [Hydrogen chloride] is used for primarily for adju sting the pH of a portion of our wastewater effluent, and in small quantities for pH adjustment of some products . Vinyl acetate monomer [Acetic acid ethenyl ester] is used in the production of vinyl acetate polymers and copolymers. Vinyl methyl ether [Ethene, methoxy-] is used in the production of vinyl methyl ether copolymers. The maximum inventory of Hydrochloric acid [Hydrogen chloride] at our facility is 107,400 pounds while Vinyl acetate monomer [Acetic acid ethenyl ester] and Vinyl methyl ether [Ethene, methoxy-] are present at our facility in quantities of 86,000 pounds and 42,000 pounds respectively. 3. The Worst Case Release Scenario(s) and the Alternate 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 OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the cho sen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from a reactor. In this scenario, 1886 pounds of Vinyl acetate monomer [Acetic acid ethenyl ester] is released through a rupture disc as the result of over pressurization of a reactor. The vinyl acetate is released as a vapor cloud over period of 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.58 miles is obtained corresponding to a toxic endpoint of 0.26 mg/L. The alternate release scenario for Vinyl acetate monomer is the same as that for the worst case release scenario except that the release scenario parameters correspond to those for alternate release scenarios (i.e., Class D atmospheric stability and 3.0 m/s windspeed). Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.26 mg/L of Vinyl acetate monomer [Acetic acid ethenyl ester] is 0.22 miles. The alternate release scenario for Hydrochloric Acid (37% solution) involves a release of 437 pounds of Hydrochloric Acid from a transfer line. The Hydrochloric Acid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.030 mg/L of Hydrochloric Acid is 0.19 miles. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from a Methyl vinyl ether storage vessel. In this scenario 35,000 pounds of Vinyl methyl ether [Ethene, methoxy-] is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.23 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternate release scenario submitted for Program 2 a nd 3 flammable substances involves a release of Methyl vinyl ether from a reactor . In this scenario, 6639 pounds of Vinyl methyl ether [Ethene, methoxy-] is released through a rupture disc as the result of over pressurization of a reactor. The release is assumed to result in a Vapor Cloud Fire. Under neutral weather conditions, the maximum distance to the flammable endpoint of Lower flammability limit is <0.06 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. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Hickson DanChem Corporation 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 methodologies used to carry out these analyses include HAZOPs, What Ifs, and Checklists. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are at least every three years . Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA update was performed on 04/22/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, Hickson DanChem Corporation 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 a ccessible to operators involved in the processes. Training Hickson DanChem Corporation 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 three years and more frequently as needed. Mechanical Integrity Hickson DanChem Corporation carries out 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. 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. The most recent review/ revision of maintenance procedures was performed on 06/04/99. Management of Change Written procedures are in place at Hickson DanChem Corporation to manage changes in process chemicals, technology, equipment and procedures. 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 Hickson DanChem Corporation. The most recent review was performed on 05/11/1999. 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 Hickson DanChem Corporation conducts audits on a regular basis to determine whether the provisions set out under the RMP r ule are being implemented. The most recent compliance audit was conducted on 02/12/1998. 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 Hickson DanChem Corporation 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 Hickson DanChem Corporation 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. Hickson DanChem Corporation 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 Hickson DanChem Corporation 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 of chemicals covered by this Risk Management Plan during this period. 6. Emergency Response Plan Hickson DanChem C orporation 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. The Pittsylvania County Emergency Coordinator. is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Some of the steps we are taking to impro ve safety at our facility include installation of additional announcement speakers and purchase of additional two-way radios to facilitate communication within the plant and with outside emergency response personnel. These changes are expected to be implemented by December 31, 1999. |