Van Waters & Rogers Inc. - Executive Summary |
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RMP PLAN EXECUTIVE SUMMARY COMPANY OVERVIEW 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 RESPONSE APPROACH 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. 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. STATIONARY SOURCE The Salem Massachusetts site stores, handles and delivers a variety of hazardous and non-hazardous chemical products to wholesale customers in New England. 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. Prepackaged containers of an isopropyl chloride containing solution are handled at inventory levels above the threshold planning quantity of 10,000 lbs. The typical inventory level for isopropyl chloride is 25,000 lbs. in drums. Prepackaged containers of ethylenediamine are handled at inventory levels above the threshold planning quantity of 20,000 lbs. The typical inventory level for ethylenediamine is 50, 000 lbs. in drums. WORST-CASE RELEASE SCENARIO The Worst-Case Toxic Release Scenario for the site would involve a total container failure with a release of a 55 gallons of formaldehyde solution according to the EPA proscribed release protocol. This would result in a release of 180 pounds of formaldehyde in a 10 minute time period. Air dispersion modeling projects an affected area and distance to endpoint of approximately 530 feet or .1 mile. The Worst-Case Flammable Release Scenario would involve a total container failure with a release of 55 gallons of isopropyl chloride containing solution. This would result in a release of 220 pounds of isopropyl chloride. Air dispersion modeling projects an affected area and distance to endpoint of approximately 260 feet or .05 miles. ALTERNATIVE CASE RELEASE SCENARIO(S) The Alternate Case Release Scenario for toxics would involve a partial container breach that released 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. The Alternate Case Release Scenario for flammables would involve a partial container breach of isopropyl chloride solution resulting in a release of 110 pounds of isopropyl chloride in a 5 minute time period. Air dispersion modeling projects and affected area and distance to endpoint of 30 feet or .006 miles, resulting in no offsite impact. 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 appropriat e regulatory guidelines ACCIDENT HISTORY The site has experienced no accidents as specified in 40 CFR Part 68 related to the containerized storage of ethylenediamine, isopropyl chloride or 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 Salem 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. |