Velsicol Chemical Corporation - Executive Summary |
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The Velsicol Chemical Corporation's Chattanooga,TN manufacturing plant has prepared this Risk Management Plan (RMP) in accordance with U.S. Environmental Protection Agency (USEPA) regulations under the federal Clean Air Act. The elements of this RMP, dealing with the safe handling and management of chemicals, have been in place and in practice at the Plant for many years. Policies and procedures regarding the prevention of accidental releases, as well as those describing how we respond to accidental releases and other types of potential emergencies, are well established at the Plant. These are described in detail in the Plant Emergency Response Plan and are also summarized in Sections 4.1.5 and 4.1.6 of the RMP. The chemical substance handled at the plant addressed in this RMP (i.e. "Regulated Substances") is Chlorine. The area in the Plant where this chemical is handled in the largest quantities (i.e. "Covered Process" as defined in 40 CFR 68.3) is: One (1) to two (2) ninety (90 )-ton Chlorine railcars located at the chlorine unloading area in the center of the Plant. The "worst-case release scenario" required to be prepared by the USEPA regulations for the purpose of this RMP for the Chlorine accidental release is described as follows. An instantaneous rupture of a ninety (90)-ton railcar releasing the entire contents of the tank over a period of ten (10) minutes. Active mitigation systems such as automatic valve closures or alarm systems are not to be considered, in accordance with the RMP regulations, when constructing the hypothetical worst-case release scenario. There are no passive mitigation systems in place that were considered in the worst-case scenario. The "alternative release scenario" required to be prepared and made a part of this RMP is as follows. For Chlorine, the scenario is a transfer hose failure resulting in a release of 4.2 lb/sec. and for a duration of one (1) minute. A comprehensive program described in a number of manuals and p rocedures designed to prevent accidental releases of any chemicals used at the Plant has been in place for many years and includes: Process safety information located througout the Plant; Process hazard reviews conducted on all manufacturing processes; Detailed written operating procedures that provide clear instructions for safe operation of each process; Regular employee training on process operating procedures, safety, emergency operation/shutdown, and chemical hazard commucation; Maintenance of mechanical integrity of process equipment through regular inspection, Testing and preventive maintenance; Management of changes to process chemicals, technology, equipment and procedures to insure continued safe operation; Pre-start up safety reviews for new or modified processes; Periodic compliance reviews to evaluate whether procedures and practices to prevent accidental releases are adequate and are being followed; Routine investigation of any incidents which resulted in, or could have resulted in, a release of chemicals; Employee participation in process hazards analyses, development of process safety procedures, and full access to all information required under RMP. Over the past five (5) years, the Plant has had no accidental releases from the process covered in this RMP that resulted in deaths, injuries, lost time or OSHA recordable injuries, or significant property damage on or off the Plant site. In the event of an accidental releases, the Plant would activate its Emergency Response Plan. This plan specifies actions to be taken in response to any release. The plan includes procedures for making notifications to parties outside the Plant and is fully coordinated with the Hamilton County Local Emergency Planning Committee's (LEPC) plan. The Plant continuously strives to improve the safety of its operations through its Responsible Care Leadership Team which meets on a regular basis. |