| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

Van Waters & Rogers Inc. is a wholesale chemical distributor serving a number of U.S. industries.  Founded in 1924, VW&R supplies the food industry, chemical compounders, pharmaceuticals, mining, forest products, oil and gas producers, electronics, coatings and many other key industries with the chemical raw materials required to produce or refine products used in numerous end-use markets. 
Van Waters & Rogers Inc. is a member of the National Association of Chemical distributors (NACD) and complies with the Responsible Distribution Process (RDP), an environmental, health and safety improvement initiative. 
Some of the products stored and handled by VW&R are subject to EPA's Risk Management Program rule (40 CFR Part 68).  A key requirement of this rule is the preparation and submission of an RMP Plan, contained herein.  The contents of the RMP Plan are prescribed by EPA, including this Execut 
ive Summary. 
1. Prevention Program 
Processes that are subject to OSHA's Process Safety management (PSM) standard AND are regulated under EPA's RMP rule are subject to the Program 3 Prevention program.  Van Waters & Rogers Inc. has documented the Prevention Program in its Process Safety Management Manual.  Briefly, this program includes provisions and requirements for: 
* 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 permits 
* Contractors 
2. Emergency Response Approach 
Van Waters & Rogers Inc. has an Emergency Contingency Plan in place.  This Plan is shared with local emergency responders who have access to VW&R facility personnel (and up-to-date phone numbers).  VW&R responds to minor incidents but will call in professional emergency respond 
ers in the event of all other incidents. 
VW&R invites and encourages local emergency responders such as the fire department to visit and familiarize themselves with VW&R products and facilities.  Joint emergency exercises are conducted when possible. 
Our facility's primary activities encompass Chemical Storage & Distribution.  We have one RMP regulated substances present at our facility.  The substance is Hydrogen Fluoride/Hydrofluoric Acid (Hydrofluoric) 70%.  Listed below is the way the RMP regulated substance is stored/handled on site and the maximum inventory present at any one time. 
1. Hydrogen Fluoride/Hydrofluoric Acid (Hydrofluoric) 70% is received in 55 gal drums which are stored in our warehouse for distribution to end use customers. The estimated maximum inventory of Hydrofluoric Acid 70% onsite at any one time will be 16,989 lbs 
(including administrative control 
s 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 look-up, tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenarios submitted for Program 2 and 3 substances as a class involves separate catastrophic releases from each of the RMP substances in inventory onsite. Each RMP liquid is assumed to be immediately released to form a pool of 1 cm height, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. By using Class F atmospheric stability and 1.5 m/s wind speed .Listed below are the maximum distances in miles and the corresponding toxic endpoint of mg/L for each individual RMP substance inventoried onsite using the above conditions. For each Alternate Release Scenario onsite Emergency Response Pe 
rsonnel and Equipment were considered for active mitigation. RMP COMP software was used for modeling purposes.  
1. Worse Case Scenario release of 385 lbs Hydrogen Fluoride/Hydrofluoric Acid 70%, the maximum distance of 0.1miles is obtained corresponding to a toxic endpoint of .016 mg/L. 
2. Alternate Case Scenario release of 175 lbs Hydrogen Fluoride/Hydrofluoric Acid 70%, the maximum distance of 0.1 miles is obtained using Class D stability and 3m/s wind speed.        
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 Standard, 1967 Edition.  A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119.  The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 

rocess 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       the "What-If" technique. 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 five years.  Any findings related to the hazard analysis are addressed in a timely manner. 
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, emer 
gency 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. 
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 year 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, 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 need 
ed.  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.  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.  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.  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. 
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. 
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, no accidental release of Hydrofluoric Acid 70% has occurred during this period. 
Van Waters & Rogers Inc is strongly committed to employee, public and environmental safety.  This commitment is demonstrated by our comprehe 
nsive 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.  Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release.  We are also completely coordinated with the local Fire Department which provides additional emergency response expertise. 
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 resp 
onse 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 undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
Name:        ________________________________________ 
Signature:    ________________________________________ 
Title:        ________________________________________ 
Date signed:    ________________________________________
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