Hercules - Chicopee Plant - Executive Summary

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Hercules Incorporated is a member of the Chemical Manufacturer's Association and is committed to the principles of Responsible Care (R).  The Corporate Policy on Safety, Health, and Environment states: 
 Hercules Incorporated    
 A Responsible Care. Company 
At Hercules, we manufacture chemical specialty products. We do so with full commitment to the chemical industry's Responsible Care. initiative. In keeping with this commitment, we are dedicated to providing a safe and healthful environment for our employees, customers, and communities. To do this, we are dedicated to and working toward continuous improvement in our operations to prevent pollution; to reduce risk; and to enhance safety, health, and environmental performance. By incorporating these beliefs and attitudes into the way we do things at Hercules, we take a key step forward in minimizing the environmental impact of our operations, satisfying customer needs, and creating shareholder value. 
We will adhere to the  
following basic principles in managing our business worldwide: 
We will comply with the letter and spirit of all applicable safety, health, and environmental laws, regulations, and corporate guidelines. 
We will define strategic objectives, develop tactical plans, identify clear accountability, provide necessary resources, and measure our progress on safety, health, and environmental matters on an ongoing basis. Our planning will consider both business goals and significant safety, health, and environmental aspects of our products and operations. 
We will evaluate the safety, health, and environmental impacts of new and existing products and operations and will work to reduce the adverse impacts. 
We will provide for an open dialogue on safety, health, and environmental issues relating to our products and operations with our stakeholders, including shareholders, employees, customers, suppliers, government agencies, and communities. 
We will work to continually reduce workplace injuries 
; incidents with the potential for causing property damage, material loss, or interruption of our business; waste; and releases to the environment. 
We will emphasize product stewardship and advocate its importance to our suppliers, distributors, and customers. 
Every Hercules employee, worldwide, has a role to play. All of us are responsible and accountable for adhering to the letter and spirit of this policy. All of us must incorporate safety, health, and environmental considerations into our daily business activities. It takes a total team effort to truly be a Responsible Care company. 
Facility Description: 
The primary activity at the Chicopee Plant is the manufacture of chemical additives used in the pulp and paper industry.  The plant's two main processes are emulsion sizes (Hercons and Aquapels) and wet-strength resins (Kymenes).  The sizes prevent wetting and penetration of the pulp fibers and are used in a variety of products from writing paper to food packaging.  The wet-s 
trength resins are used in paper towels, napkins, tissues, etc. so that they will not come apart easily when they get wet.  
Epichlorohydrin is a raw material for the Kymene process and is consumed in a chemical reaction to make the wet-strength resin.  The plant receives epichlorohydrin in tank trucks and railroad tank cars and stores the material in a gallon storage tank that holds a maximum of 206,000 pounds.  The storage tank is provided with a containment dike to minimize the adverse impacts from any leaks or spills.  Spill containment capability is also provided for the area where tank trucks are unloaded. 
Worst Case Scenario: 
The worst case scenario for epichlorohydrin is the failure of an entire rail car containing 166,000 pounds of epichlorohydrin.  The distance to the EPA toxic endpoint, not taking into account any passive mitigation, is approximately 1.53 miles based on the use of the SLAB model.  The potential population that could be affected by such a release is approx 
imately 31,000 people (as calculated using EPA's Landview III database).  This distance is an "upper bound" for this release.  This scenario requires the extremely unlikely event of a catastrophic failure of the rail car.  The rail cars are unloaded from the top, which means that an unloading hose failure cannot cause a release of the entire car. 
Alternative Case Scenario: 
The alternative case scenario for epichlorohydrin is a line break outside of the containment dike that results in a release of 15,000 pounds of epichlorohydrin.  This scenario gives a distance to the EPA toxic endpoint of 0.26 miles based on the use of the ALOHA model.  The potential population that could be affected by such a release is approximately 1,100 people.  The impact from this scenario is limited by the operating procedures, which would limit the duration of the spill to no more than 10 minutes. 
Accident Prevention Program: 
The Chicopee plant is subject to the OSHA Process Safety Management standard ( 
29 CFR 1910.119) and has a complete process safety management system in place.  This includes the use of process hazards analysis to identify and address potential hazards, management of change procedures to control modifications, mechanical integrity procedures for minimizing mechanical failures, detailed operating procedures for process control, and operator training for the personnel involved in the process. 
Five Year Accident History: 
In the past five years, the Chicopee Plant has not had any accidental releases of epichlorohydrin that have resulted in on-site injuries or damage or any off-site impacts. 
Emergency Response Program: 
The Chicopee Plant has written emergency response plans and coordinates emergency response matters with the Chicopee Fire Department and the District Hazmat team.  The plant provides ongoing emergency response training for all plant employees. 
Planned Changes to Improve Safety: 
Recently, a project was approved to revise the epichlorohydrin railca 
r unloading facilities.  This project will provide containment for a spill from the railcar unloading system.  Completion is anticipated by years end.  Once completed, the alternative release scenario will be significantly reduced.  Taking the alternaive release scenario stated above and installing a containment dike as passive mitigation would significantly reduce the spill surface area and the subsequent vapor release.  This scenario gives a distance to the EPA toxic endpoint of 0.06 miles based on the use of the ALOHA model.  The potential population that could be affected by such a release is approximately 67 people.
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