Van Waters & Rogers Inc. - Executive Summary
RMP PLAN |
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 Executive Summary.
CORPORATE PREVENTION AND EMERGENCY
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
* Mechanical Integrity
* Management of Change
* Pre-Startup Review
* Compliance Audits
* Incident Investigation
* Employee Participation
* Hot Work permits
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. VW&R responds to minor incidents but will call in professional emergency responders in the event of all other incidents.
VW&R invites and encourages local eme
rgency responders such as the fire department to visit and familiarize themselves with VW&R products and facilities. Joint emergency exercises are conducted when possible.
The Twinsburg Ohio site stores, handles and delivers a variety of hazardous and non-hazardous chemical products to wholesale customers in Ohio, northwestern New York, Pennsylvania and West Virginia. Prepackaged containers of 37% formaldehyde solution are handled at inventory levels above the threshold planning quantity of 15,000 lbs. The typical inventory level for formaldehyde is 25,000 lbs. in drums or intermediate bulk containers.
WORST-CASE RELEASE SCENARIO
The Worst-Case Release Scenario for the site would involve a total container failure releasing 330 gallons of formaldehyde solution according to the EPA proscribed release protocol. This would result in a release of 1070 pounds of formaldehyde in 10 minute time period. Air dispersion modeling projects an affected area and distance to end
point of approximately 530 feet or .1 mile.
ALTERNATIVE CASE RELEASE SCENARIO(S)
The Alternate Case Release Scenario would involve a partial container failure with release of 25 gallons of formaldehyde solution resulting in a release of 80 pounds of formaldehyde in a 5 minute time period. Air dispersion modeling projects an affected area and distance to endpoint of up to 530 feet or .1 mile.
GENERAL PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
As outlined previously, VW&R is subject to OSHA's Process Safety Management regulation and utilizes this program to meet the prevention program requirements under RMP.
Chemical-specific prevention steps include the following:
1.The maintenance of minimal practical inventories.
2. Employee training and operating procedures.
3. Employee release detection and mitigation activities.
4. Equipment and containers designed to meet appropriate regulatory guidelines
The site has experienced no accidents as specified
in 40 CFR Part 68 related to the containerized storage of formaldehyde solution in the previous 5 years.
EMERGENCY RESPONSE PROGRAM
An emergency contingency plan has been prepared and made available to local emergency response agencies. The Twinsburg fire department is familiar with and periodically visits the site. A contract has been formalized with Clean Harbors Inc, an emergency response contractor to provide on site and off site emergency response services in the event of a release.