Advance Research Chemicals, Inc. - Executive Summary |
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ADVANCE RESEARCH CHEMICALS, INC RISK MANAGEMENT PROGRAM EXECUTIVE SUMMARY June 16, 1999 Introduction Advance Research Chemicals, Inc. (ARC) is committed to operating in a manner that is safe for ARC workers, the public, and the environment. As part of this commitment, ARC has established a system to help ensure safe operation of the processes at this facility. A component of this system is a risk management program(RMP) that helps manage the risk at ARC and that complies with the requirements of the Environmental Protection Agency's (EPA) regulation 40CFRPart 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan(RMPlan) describing the risk management program at ARC. This plan is intended to satisfy the RMPlan requirement of the RMP rule (:68.150 through :68.185) and to provide the public with a description of the risk management program at ARC. Accidental Release Prev ention and Emergency Response Policies ARC is committed to the safety of ARC workers and the public, and to the preservation of the environment, through the preservation of accidental releases of hazardous substances. ARC implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, ARC controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. ARC Facility and Regulated Substances ARC processes a variety of compounds and uses hydrofluoric acid (HF) in its processes. HF acid at solution concentrations of 50 wt% or greater are regulated by the RMP rule. Although many products that ARC produces are neutralized in our process or contain low concentrations of HF, hydrofluoric acid is stored in storage tanks for use in our process. A maximum of 5000 gallons of anhydrous hydrogen fluoride is stored in one 8,000 gallon tank located at the ARC 1 110 West Keystone Ave. Site. The weight of the solution is 40,000 lbs, which exceeds the RMP rule threshold quantity for HF acid in a process(1,000 lbs). Because the HF acid storage process is covered by the requirements of the Occupational Safety and Health Administration's process safety management regulation and because the potential exists for offsite consequences resulting from an accidental release of HF acid, the process falls under the RMP Program 3 prevention program. Offsite Consequence Analysis The RMP rule requires ARC to perform an offsite consequence analysis for one worst-case and alternative release scenario for anhydrous hydrogen fluoride, a toxic substance. The worst case scenario and alternative release scenario are included in the contents of the attached RMP. The worst case scenario is failure of the 8,000 gallon storage tank, which releases 40,000 lbs of HF to a toxic endpoint distance of 0.81 miles with a total population of about 180 people. No environment al receptors are in distance. The alternative case scenario uses a tank truck hose loading at a velocity of 500 lbs/min and develops a 1" hole. This scenario was picked because transfer hoses are considered the weakest link in the process. These calculations and distances are also included in the contents of the attached RMP. The HF released is 139 lbs, to a toxic endpoint distance of 0.31 miles with about a total population of 33 people. No environmental receptors are in distance. Accidental Release Prevention Program and Chemical-specific Prevention Steps The RMP rule requires a Program 3 prevention program for anhydrous hydrogen fluoride acid storage. The following paragraphs describe the prevention program elements at ARC that apply to these units. Safety Information and Process Hazards Analysis(PHA) ARC maintains a variety of technical documents that are used to help ensure safe operations of the ARC processes. Material safety data sheets document the physical properties of hazardous substances handled at ARC, including HF acid. ARC performs and periodically updates hazard reviews of the HF acid storage process to help identify and control process hazards. Checklist are used to guide the hazard review. These checklists are used to help ensure that ARC operates and maintains the equipment in a manner consistent with the applicable standards. Operating Procedures ARC develops and maintains operating procedures to define how task related to process operations should be performed. These operating procedures are used to train employees and to serve as reference guides for normal operation. Training ARC trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks. Maintenance ARC properly maintains the process equipment. The ARC maintenance program includes an inspection and testing program to help identify equipment deterioration and damage before equipment fails. Management of Change (MOC) and Compliance Audits ARC performs MOC and compliance audits of covered processes to verify that the processes are operating in compliance with the requirements of the RMP rule. Incident Investigation ARC investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment. An investigation team is assembled, and the investigation in initiated within 24 hours of the accident. The results of the investigation are documented and recommendations are resolved, and appropriate process enhancements are implemented. HF acid-specific steps Industry standards are followed at ARC to help ensure safe handling of anhydrous hydrogen fluoride (HF) acid. The vendor supplies HF via a Department of Transportation (DOT) approved tank truck and follows DOT standards when loading HF acid storage tanks. The storage tank design and construction are consistent with American National Standards Institute standards. Workers who perform operati ons involving HF acid receive training emphasizing safe handling procedures for HF acid developed by ARC. Five Year Accident History ARC maintains a 5-year accident history that fulfills the requirements of the RMP rule (:68.42). This history indicates a good record of accidental release prevention over the past 5 years. No releases of regulated substances have occurred from ARC in the last 5 years that have resulted in consequences of interest. Emergency Response Programs ARC has established a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations. This plan has been communicated to local emergency response officials through the local fire department. Planned Changes to Improve Safety ARC constantly strives to improve the safety of the processes at ARC through both incident investigation and from soliciting safety suggestions from workers. If there are any questions concerning RMP or if you have a question about o ur operations at ARC, please feel free to call me at (918) 266-6789. Thank you, Sanjay D. Meshri Senior Vice President |