Chem Lab Products, Inc. - Executive Summary
General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities |
1. Accidental Release Prevention and Emergency Response Policies
We at Chem Lab Products, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive 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.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass Manufacturing of bleach. We have 1 regulated substances present at our facility. These substances include and Chlorine. Chlorine is used for Manufacturing Bleach.
The maximum inventory of Chlorine at our facility is two Railcars @ 180,000 lbs. for a maximum of 360,000 lbs.
3. The Worst Cas
e Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To evaluate the worst case scenarios, we have used the EPA's OCA Guidance Reference Tables or Equations. For alternative release scenario analyses we have employed the EPA's RMP*Comp(TM). The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from Bleach Manufacturing. In this scenario 180000 lb. of Chlorine is released. The scenario involves the release of 180,000 lb. of Chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 25 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.
The alternative release scenario for Chlorine involves a release from Bleach Manufacturing. The scenario involves the release
of 15,000 lb. of Chlorine in a gaseous form over 10 minutes. The release is also assumed to be controlled by excess flow valve and emergency shutdown system. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 1.6 miles.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirement set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Chem Lab Products, 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
ity conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses was HAZOP. 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 at least once a year and more frequently as needed. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 04/29/1999.
For the purposes of safely conducting activities within our covered processes, Chem Lab Products, Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency 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.
Chem Lab Products, 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 two years and more frequently as needed.
Chem Lab Products, 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 needed. 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 C
hem Lab Products, Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/04/1999. 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-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Chem Lab Products, Inc. The most recent review was performed on 04/07/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Chem Lab Products, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent co
mpliance audit was conducted on 1/20/99. 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.
Chem Lab Products, 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.
Chem Lab Products, 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, includ
ing 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. Chem Lab Products, 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.
5. Five-year Accident History
Chem Lab Products, Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period.
6. Emergency Response Plan
Chem Lab Products, Inc. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan i
ncludes 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 response 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.
DISTRICT 5 is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.
7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Installing the detection systems and the emergency shutdown systems using improved technologies are some of the major steps we want to take to improve safety at our facility. These changes are expect
ed to be implemented by 2001.