Olympic Chemical - Executive Summary

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                                               Executive Summary 
 
1.  Accidental Release Prevention and Emergency Response Policies 
 
We at Olympic Chemical 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 liquid sodium bisulfite..  We have 1 regulated substances present at our facility.  The substances is Sulfur dioxide (anhydrous) used for the manufacturing of sodium bisulfite.                                         . 
 
The maximum inventory of Sulfur dioxide (anhydrous) at our facility is 180000 
.00 lb.. 
 
3.  The Worst Case Release Scenario(s) and the Alternative Release Scenario, including      administrative controls and mitigation measures to limit the distances for each reported      scenario. 
 
To perform the required offsite consequence analysis for our facility, we have used the EPA's RMP*Comp(TM).  The following paragraphs provide details of the chosen scenarios. 
 
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from manufacturing.  In this scenario 180000 lb. of Sulfur dioxide (anhydrous) is released.  The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to evaporate over 10 minutes.  At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 16 miles is obtained corresponding to a toxic endpoint of 0.0078 mg/L. 
 
The alternative release scenario for Sulfur dioxide (anhydrous) involves a release from man 
ufacturing.  The scenario involves the release of 100 lb.. The toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to have evaporated after 10 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0078 mg/L of Sulfur dioxide (anhydrous) is 0.1 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 requirements 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 
Olympic Chemical maintains a detailed record of safety information that describes the chemical hazards, operating par 
ameters and equipment designs associated with our process. 
 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our process are identified and controlled efficiently.  The methodology used to carry out these analyses is "The What If" scenario.  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 3 years.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update was performed on 05/19/1999. 
 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Olympic Chemical 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. 
 
Training 
Olympic Chemical 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 annually and more frequently if needed. 
 
Mechanical Integrity 
Olympic Chemical 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.  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 Olympic Chemical to manage changes in p 
rocess chemicals, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 06/01/1999.  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-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Olympic Chemical.  The most recent review was performed on 5/19/1999.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
 
Compliance Audits 
Olympic Chemical conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  The most recent compliance audit was conducted on 5/19/1999.  These audits ar 
e 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. 
 
Incident Investigation 
Olympic Chemical 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. 
 
Employee Participation 
Olympic Chemical 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, including information resulting from process hazard analyses in particular. 
 
 
Contractors 
On occasion, our company may hire 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.  Olympic Chemical 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 
 
Olympic Chemical 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 
 
Olympic Chemical carries a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response including adequate first aid and medical tr 
eatment, 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. 
 
Tacoma Fire Department is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
 
7.  Planned Changes to Improve Safety 
 
As a  result of our most recent review of our accidental  release prevention program, it is planed to install six additional sulfur dioxide sensors. These changes are expected to be implemented by 7/30/1999.
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