Arch Specialty Chemicals, Inc. - Executive Summary |
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At Arch Specialty Chemicals Warehouse and Distribution Center, we are committed to operating and maintaining all of our processes 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 provides a brief overview of the comprehensive risk management activities that we have designed and implemented. This facility is a warehouse and chemical distribution center for Arch finished goods and raw materials and meets the criteria for a Program Level 1 as defined at 40 CFR 68.10(b). Among the chemicals we store and handle are aqueous ammonia and hydrochloric acid (37-38% solution). These chemicals have been identified by the Environmental Protection Agency as having the potential to cause significant offsite consequences in the event of a substantial accidental release. None of the flammable m aterials stored at the facility are in quantities sufficient to meet the reporting requirements as defined in the Risk Management List Rule, 40 CFR 68.130. The RMP rule requires that we provide information about the worst-case release scenario for the facility. The following brief summary describes this scenario, including information about the key administrative controls and mitigation measures to limit the exposure distance. The largest quantity of regulated material is 55 gallons. The worst case scenario is based on a spill of 55 gallons of hydrochloric acid inside the warehouse. The chemical is handled indoors at all times. Because the chemicals are always indoors, the potential to affect an off-site receptor is very low. The EPA OCA Guidance Document indicates that the toxic endpoint for this scenario is 0.05 miles (264 ft). The closest off-site receptor is approximately .13 miles (686 ft). There have been no accidents at the facility in the last five years. No alter nate release scenario is required for Program 1 facilities. Although the RMP Rule does not require a prevention program, we at the Arch Warehouse and Distribution Center take a systematic, proactive approach to preventing accidental releases. We have established a variety of systems to address key preventive and maintenance procedures. Examples of these are Process Hazard Analyses, incident investigations, employee training, and Hot Work Permits. We maintain spill response equipment such as absorbents, overpack drums, and SCBAs to be used in case of a spill inside the building. Selected employees have been trained in emergency response to contain localized spills. These individual efforts of the prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems establish for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our o wn high standards for accident prevention. We maintain an emergency response plan which complies with the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. We coordinate our plan with the local emergency planning committee. Neither our accident history nor our review of procedures has indicated a need for change to improve safety. In the event of fire, explosion, or a release of a regulated substance from the process, entry within the distance to the specified endpoints 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 Risk Management Plan. |