Industrial Chemicals Inc. - Executive Summary |
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68.155 Executive Summary Industrial Chemicals Inc. 1125 Roberts Industrial Drive Birmingham, AL 35208 April 1, 1999 Accidental Release Prevention and Emergency Response Policies The distribution facility is located adjacent to Interstate 59 between Arkadelphia Road and Bush Boulevard. The business has operated from this location for more than twenty years as a responsible contributor to the community. The company is a member of the National Association of Chemical Distributors dedicated to the code of management practice of the Responsible Distribution Process. The safe management of chemical products is considered priority to minimize the risk to our community, environment and personnel. Additionally, Industrial Chemicals Inc. manages the facility in compliance with all Occupational Safety & Health Administration (OSHA), Environmental Protection Agency (EPA), Alabama Department of Environmental Management (ADEM) and the United States Department of Transportation (USDOT) regulati ons. To ensure the facility continues to operate in a safe and responsible manner in compliance with all regulations, an extensive risk management system has been developed and integrated into our operating procedures. Significant components of the system include training, operating procedures for chemical handling, inspection, maintenance, emergency response and incident management. These procedures provided to responsible personnel and management's continual compliance oversight ensures safe chemical management. The Operations Director, Facilities Manager and Warehouse Manager are designated as having the primary responsibility and accountability to ensure the plan and all components are in compliance and implemented. Stationary Source Description and Regulated Substances Handled The facility is designed for receipt, storage and distribution of chemical products. There are no manufacturing activities conducted at the site. Both liquid and dry chemicals are received in bulk and small packages and placed in storage for shipment in smaller quantities to industrial customers. These include portable tanks, cylinders and drums. Some of the chemicals described are purchased and received from the manufacturer in small size containers and others are received in tankers and transferred to storage tanks or drums. Ammonium Hydroxide 30% (Aqua Ammonia) The liquid arrives at the facility in bulk transport tanker where it is transferred to a storage tank of 5600 gallon capacity located within a large concrete containment area for transfer to smaller containers. The storage tank is equipped with a vapor scrubber designed to capture vapors for return to the storage tank in solution form. Smaller packages include 55 and 15 gallon drums and 350 gallon portable tanks. These containers are stored in areas designed to prevent the spread of liquid should a container failure occur. Packaging is restricted to areas constructed of concrete with curbing to prevent the spread of li quid to other areas. Collection equipment is immediately available to capture liquid released during the packaging process and return it to storage. The maximum inventory for Ammonium Hydroxide in bulk is 5600 gallons. Smaller packages in up to 100 fifty-five gallon drums, 25 fifteen gallon drums and 5 portable tanks known as tote tanks of 350 gallon capacity or approximately 2400 pounds each. Only authorized and trained personnel are permitted to package and handle the containers. Cyclohexylamine This liquid also arrives at the facility by bulk transport tanker. The chemical is transferred directly to 55 gallon drums and placed in storage. The packaging area is designed to limit the amount of material packaged at one time. The area is constructed of concrete with curbing to prevent the spread of liquid within a larger area of the same type construction. The storage area for the chemical is located inside a building constructed of concrete floors and walls. The designated area fo r storage is situated away from equipment traffic to minimize the possibility of accidental container damage. There may up to 24 drums of 55 gallon capacity and three tote tanks of 250 gallon capacity or 2200 pounds each. Only authorized and trained personnel are permitted to package and handle the containers. Chlorine This gas is packaged in steel cylinders of 2000 and 150 pound size. The product is delivered to the facility on trailers specifically designed to transport the containers. The chemical is liquefied under pressure and release from the container is in the form of a gas. The cylinders are equipped with safety mechanisms to minimize the possibility of an accidental release and pressure relief devices are installed should the container be exposed to excessive heat from elevated temperature conditions such as that associated with a fire. Chlorine is shipped off site in small quantities to water treatment facilities using the gas to treat water for the public's use. The 150 pound containers are stored in secured racks to prevent accidental damage. The 2000 pound cylinders are stored in an area away from equipment traffic and chemicals that may, during an incident, contribute to a release from these containers. During the summer months when Chlorine use is at its peak there may be up to 25 cylinders of 2000 pound capacity and 200 cylinders of 150 pound capacity. Only authorized and trained personnel are permitted to handle the containers. Hydrofluoric Acid 70% Solution This liquid arrives at the facility in 55 gallon drums of 500 and 550 pound capacity. The containers are stored in a room within the warehouse building. Both are constructed of concrete floors with concrete curbing around the perimeter and a ramp at the entrance to prevent the spread of liquid to other areas of the building. The drums are palletized and single stacked in an area with limited access away from traffic. Each container is inspected daily to verify package integrity. Ma ximum inventory levels set for this material are 80 drums of either 500 or 550 pound capacity. Only authorized and trained personnel are permitted to handle the containers. Formaldehyde 37% Solution The liquid arrives at the facility by bulk transport tanker. The chemical is transferred directly to 55 gallon drums and portable tanks then placed in storage. The packaging area is designed to limit the amount of material packaged at one time. The area is constructed of concrete with curbing to prevent the spread of liquid within a larger area of the same type construction. The storage area for the chemical is located inside a building constructed of concrete floors and wall. The designated area for storage is situated away from equipment traffic to minimize the possibility of accidental container damage. There may up to 200 drums of 55 gallon capacity or 475 pounds and 12 tote tanks of 350 gallon capacity or 2900 pounds each. Only authorized and trained personnel are permitted to p ackage and handle the containers. Sulfur Dioxide This material is packaged in steel cylinders of 2000 and 150 pound size. The product is delivered to the facility on trailers specifically designed to transport the containers. The chemical is liquefied under pressure and release from the container is in the form of a gas. The cylinders are equipped with safety mechanisms to minimize the possibility of an accidental release and pressure relief devices are installed should the container be exposed to excessive heat from elevated temperature conditions such as that associated with a fire. Sulfur Dioxide is shipped off site in small quantities to water treatment facilities using the gas to treat water for the public's use. The 150 pound containers are stored in secured racks to prevent accidental damage. The 2000 pound cylinders are stored in an area away from equipment traffic and chemicals that may, during an incident, contribute to a release from these containers. During high deman d periods inventory levels for this chemical are 15 ton cylinders at 2000 pounds each and 75 cylinders at 150# each. Only authorized and trained personnel are permitted to handle the containers. The worst-case scenario(s) and the alternate release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. Population estimates are from the Census Bureau and take into account all persons within the toxic distance to endpoint perimeter. It is important to recognize, however, that the regulations require the identification of the potentially impacted population using a circle with a radius that is the maximum distance to the toxic endpoint. In reality, the released material would most likely take the form of a cloud or plume, impacting only a portion of the circle located in the downwind direction from the source. Ammonium Hydroxide 30% Solution Worst Case Scenario for Bulk Storage Process ID 1 A release of the 5600 gallo n contents of the bulk storage tank as a liquid spill was used for this worse case scenario. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a ten minute period at 1260 pounds of liquid per minute. The atmosphere was relatively stable with little cloud cover and a wind speed of 3.4 miles per hour during night hours. The physical characteristics of the area are urban with many obstacles. The storage tank is situated within a concrete dike designed to restrict the spread of liquid to a limited area. The estimated toxic distance to endpoint would be 0.7 miles and involve a residential population of 4,785 persons including schools and the surrounding industrial area. No impact to environmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Bulk Storage Process ID 1 This alternate release scenario involved the failure of a transfer pipe attached to the 5600 gallon bulk storage ta nk. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release involved 3000 pounds (400 gallons) occurring over a 10 minute period at a rate of 90 pounds per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. The storage tank transfer line is located within a concrete dike designed to restrict the spread of liquid from a release to a limited area. The estimated toxic distance to endpoint would be 0.1 miles and involved 28 persons in the immediate area of the industrial park. No schools, residences, hospitals, corrections facilities or environmental receptors, such as wildlife refuges, were impacted by the release. Ammonium Hydroxide 30% Solution Worst Case Scenario for Container Storage Process ID 2 A release of 2400 pounds (320 gallons) of a tote tank as a liqui d spill in storage was used for this worse case scenario because it would be largest container of the chemical in storage. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a ten minute period at 72 pounds of liquid per minute. The atmosphere was relatively stable with little cloud cover and a wind speed of 3.4 miles per hour during night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the storage area situated on a concrete pad with to reduce the spread of liquid to a limited area. The estimated toxic distance to endpoint would be 0.2 miles and involved a residential population of 221 persons including the surrounding industrial area. No impact to environmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Container Storage Process ID 2 This alternate release scenario involved two 400 pound (53.5 gallons) containers d amaged by material handling equipment releasing the contents of both containers as a liquid spill in storage. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release involved 800 pounds (107 gallons) occurring over a 10 minute period at a rate of 13.2 pounds per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the storage area located within a building with concrete floors and large door openings to the outside atmosphere. The estimated toxic distance to endpoint was less than 0.1 miles and involved 28 persons in the immediate area of the industrial park. No schools, residences, hospitals, corrections facilities or environmental receptors, such as wildlife refuges, were impacted by the release. Ammonium Hydroxide 30% Solution Worst C ase Scenario for Container Packaging Process ID 3 A release of the same 2400 pound tote tank as a liquid spill was used for this worse case scenario because it would be largest container of the chemical handled during the packaging process. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a ten minute period at 72 pounds of liquid per minute. The atmosphere was relatively stable with little cloud cover and a wind speed of 3.4 miles per hour during night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the packaging area situated on a concrete pad with curbing to reduce the spread of liquid to a limited area. The packaging station is designed to restrict the filling to one tote tank limiting the amount of liquid released. One container is filled, closures installed and then moved to the storage area before filling the next. The estimated toxic distan ce to endpoint would be 0.2 miles and involve a residential population of 221 persons including the surrounding industrial area. No impact to environmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Container Packaging Process ID 3 This alternate release scenario describes one 400 pound (53.5 gallons) drum releasing the contents of the container as a liquid spill while being filled. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a 10 minute period at a rate of 6.6 pounds per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the packaging area located under a roof in direct contact with the atmosphere. This area limits the quantity of full drums to no more than 4 or 1600 pounds at o ne time and only one container can be filled at a time reducing the amount of liquid released during the filling process. The packaging station is located within concrete containment with curbing designed to limit the spread of liquid. The estimated toxic distance to endpoint was less than 0.1 miles and involved 28 persons in the immediate area of the industrial park. No schools, residences, hospitals, corrections facilities or environmental receptors, such as wildlife refuges, were impacted by the release. Cyclohexylamine Worst Case Scenario for Container Storage Process ID 4 A release of the contents from a tote tank involving 275 gallons as a liquid spill was used for this worse case scenario because it would be largest container of the chemical in storage. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a 20.5 hour period at a release rate of .538 pounds of liquid per minute. The atmosphere was rel atively stable with little cloud cover and a wind speed of 3.4 miles per hour during night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the storage area situated within a building reduce the spread of liquid to a confined space. The estimated toxic distance to endpoint would be 0.1 miles and involve 28 persons in the surrounding industrial area. No impact to environmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Container Storage Process ID 4 This alternate release scenario involved two 396 pound (55 gallons) containers damaged by material handling equipment releasing the contents of both containers as a liquid spill in storage. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The total amount released was 792 pounds (109 gallons) occurring over a 10 minute period at a rate of 80 pounds per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the storage area located within a building with concrete floors and large door openings to the outside atmosphere. The estimated toxic distance to endpoint was less than 0.1 miles and involved 28 persons in the immediate area of the industrial park. No schools, residences, hospitals, corrections facilities or environmental receptors, such as wildlife refuges, were impacted by the release. Cyclohexylamine Worst Case Scenario for Container Packaging Process ID 5 A release of the contents from the same 275 gallon tote in storage as a liquid spill was used for this worse case scenario because it would be largest container of the chemical handled during the packaging process. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release oc curred over a 44 minute period at a release rate of 50 pounds (6.5 gallons) of liquid per minute. The atmosphere was relatively stable with little cloud cover and a wind speed of 3.4 miles per hour during night hours. The physical characteristics of the area are urban with many. Consideration was given to the packaging area situated on a concrete pad with curbing to limit the area of the spill reducing the spread of liquid. Four drums can be full at one time and only one container can be filled at a time. The estimated toxic distance to endpoint would be 0.1 miles and involve 28 persons in the surrounding industrial area. No impact to environmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Container Packaging Process ID 5 This alternate release scenario involved the filling of one 396 pound (55 gallons) container as a liquid spill during the packaging process. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct th e modeling. The total amount released was 396 pounds (55 gallons) occurring over a 10 minute period at a rate of 40 pounds per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the packaging area located under a roof in direct contact with the atmosphere. The containers are filled in a containment area with curbing designed to limit the number of full drums to four. One drum is filled and then closed before the filling of the next container. The estimated toxic distance to endpoint was less than 0.1 miles and involved 28 persons in the immediate area of the industrial park. No schools, residences, hospitals, recreation areas, corrections facilities or environmental receptors, such as wildlife refuges, were impacted by the release. Chlorine Worst Case Scenario for Container Storage Process I D 7 A release of the contents from a 2000 pound cylinder in storage as a gas release was used for this worse case scenario because it would be greatest amount of one container in storage. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a 10 minute period at a rate of 200 pounds of liquid released as a gas per minute. The atmosphere was relatively stable with little cloud cover and a wind speed of 3.4 miles per hour during night hours. The physical characteristics of the area are urban with many obstacles. The estimated toxic distance to endpoint would be 1.3 miles and involve 17,932 persons including residences, schools, hospitals, recreation areas and the surrounding industrial area. No impact to environmental receptors, such as wildlife refuges, was identified. Chlorine Alternate Scenario for Container Storage Process ID 7 This release scenario involved a damaged valve on a 2000 pound cylinder in sto rage releasing half of the contents as a gas release. This amount of gas released for the duration was selected because it is expected that the leak can be stopped within this period of time using equipment designed to repair leaks. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a 30 minute period at a rate of 33 pounds of liquid released as gas per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. The estimated toxic distance to endpoint would be 0.1 mile and involved 28 persons in the surrounding industrial area. No residences, schools, hospitals, recreation areas and the surrounding industrial area were impacted by the release. No impact to environmental receptors, such as wildlife refuges, was identified. Hydrofluoric Acid 70% Solution Worst Case Scenario for Container Storage Process ID 8 This scenario describes a release of the contents from two drums involving 110 gallons occurring from damage by material handling equipment as a liquid spill. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a 10 minute period at a release rate of 38.5 pounds (10.6 gallons) of liquid per minute during night hours. The atmosphere was relatively stable with little cloud cover and a wind speed of 3.4 miles per hour. The physical characteristics of the area are urban with many obstacles. Consideration was given to the storage area situated in a room within a building with doors that can be closed to reduce the spread of liquid and restrict vapors to a confined space. The estimated toxic distance to endpoint would be 1.0 miles and involve 11,202 persons in residences, schools, hospitals, recreation areas and the surrounding industrial area. No impact to e nvironmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Container Storage Process ID 8 This alternate release scenario involved one 500 pound (47 gallon) container that was found to be defective releasing the entire contents. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The total amount released was 500 pounds (47 gallons) occurring over a 10 minute period at a rate of 19.3 pounds per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the storage area located in a room within a building. This room has concrete floors with curbing and doors that can be closed to reduce the spread of liquid and restrict vapors to a confined space. The estimated toxic distance to endpoint was less than 0.2 miles and involved 221 persons including residences and the immediate area of the industrial park. No schools, hospitals, corrections facilities or environmental receptors, such as wildlife refuges, were impacted by the release. Formaldehyde 37% Solution Worst Case Scenario for Container Packaging Process ID 9 A release of the contents from a tote tank containing 310 gallon (2900 pounds) was used for this worse case scenario as a liquid spill because it would be largest container of the chemical handled during the packaging process. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a 10 minute period at a release rate of 59 pounds (7.9 gallons) of liquid per minute. The atmosphere was relatively stable with little cloud cover and a wind speed of 3.4 miles per hour during night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the packaging area situated on a concrete pad with curbing to limit the area of the spill reducing the spread of liquid. The estimated toxic distance to endpoint would be 2.1 miles involving 39,413 persons in residences, schools, hospitals, recreation areas and the surrounding industrial area No impact to environmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Container Packaging Process ID 9 This release scenario involved one 475 pound (52 gallons) container as a liquid spill during the packaging process. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The total amount released was 475 pounds (52 gallons) occurring over a 10 minute period at a rate of 9.67 pounds per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the packaging area located un der a roof in direct contact with the atmosphere. The containers are filled in a containment area with curbing designed to limit the number of full drums to four. One drum is filled and then closed before the filling of the next container. This method restricts the quantity of material released from a single container to no more than 475 pounds. The estimated toxic distance to endpoint was less than 0.3 miles and involved 583 persons in residences and the immediate area of the industrial park. No schools, hospitals, recreation areas, corrections facilities or environmental receptors, such as wildlife refuges, were impacted by the release. Formaldehyde 37% Solution Worst Case Scenario for Container Storage Process ID 10 A release of the contents from the same tote tank containing 310 gallon (2900 pounds) was used for this worse case scenario as a liquid spill because it would be the largest container in storage. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a 10 minute period at a rate of 59 pounds (6.5 gallons) of liquid per minute. The atmosphere was relatively stable with little cloud cover and a wind speed of 3.4 miles per hour during night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the storage area situated in a room within a building reducing the spread of liquid and vapor to a confined space. The estimated toxic distance to endpoint would be 2.1 miles and involve 39,413 persons in residences, schools, hospitals, recreation areas and the surrounding industrial area No impact to environmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Container Storage Process ID 10 This alternate release scenario involved two 475 pound (52 gallon) containers that were damaged by material handling equipment resulting in a liquid spill. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Gui dance) was used to conduct the modeling. The total amount released was 950 pounds (104 gallons) occurring over a 10 minute period at a rate of 19.3 pounds per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. Consideration was given to the storage area located in a room within a building. This room has concrete floors with curbing and doors that can be closed to reduce the spread of liquid and restrict vapors to a confined space. The estimated toxic distance to endpoint was less than 0.3 miles and involved 583 persons including residences and the immediate area of the industrial park. Due to the ability to close the storage area a more realistic endpoint would be 0.1 miles involving 28 persons in the immediate area of the industrial park. No schools, hospitals, corrections facilities or environmental receptors, such as wildlife refuges, were impacted by the release. Sulfur Dioxide Worst Case Scenario for Container Storage Process ID 11 A release of the contents from a 2000 pound cylinder in storage as a gas release was used for this worse case scenario because it would be greatest amount of one container in storage. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a 10 minute period at a release rate of 200 pounds of gas per minute. The atmosphere was relatively stable with little cloud cover and a wind speed of 3.4 miles per hour during night hours. The physical characteristics of the area is urban with many obstacles. The estimated toxic distance to endpoint would be 1.3 miles and involve 17,932 persons including residences, schools, hospitals, recreation area and the surrounding industrial area No impact to environmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Container Storage Process ID 11 This release scenario involved a damaged valve on a 2000 pound cylinder in storage releasing half of the contents as a gas release. This amount of gas released for the release duration was selected because it can be expected that leak will be stopped within this period of time using equipment designed to stop leaks. The EPA's RMP Offsite Consequence Analysis Guidance (OCG Guidance) was used to conduct the modeling. The release occurred over a 30 minute period at a rate of 33 pounds of liquid released as gas per minute. The atmosphere had moderate incoming solar radiation and thinly overcast skies with winds of 6.7 miles per hour during the night hours. The physical characteristics of the area are urban with many obstacles. The estimated toxic distance to endpoint would be 0.1 mile and involved 28 persons in the surrounding industrial area. No residences, schools, hospitals, recreation areas and the surrounding industrial area were impacted by the release. No impact to environmental receptors, such as wildlife refuges, was identified. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The facility has an aggressive accidental release prevention program that is based upon employee training, chemical safety awareness, equipment and facility management. Training includes both the classroom environment and observation by management to verify competency. Classes are designed to achieve maximum results within the time period and knowledge is determined by verbal and written test. Management follows a yearly schedule issuing course work on a weekly basis to the facility manager. Classes are held at the facility on a weekly basis for one to two hours. Attendance is mandatory for all employees including drivers and warehouse personnel and is verified by the Operations Director. New employees are required to receive an extensive orientation to the operating procedures for each phase of the operation including material han dling equipment, transportation vehicle loading and unloading, transportation equipment operations, liquid material transfers, personal protection, hazard recognition and safe work practices. Employees not having worked in a process receive an introduction by thorough procedural documentation review and pairing the employee with a person familiar with the process for an unspecified period. Management within the guidelines of the program verifies competency of safe operating practices. The company provides training according to the following regulatory and association requirements: Occupational Safety and Health Administration Hazardous Waste Operations Worker Right-To-Know laws Powered Industrial Trucks Material Handling and Storage Hazardous Materials Toxic and Hazardous Substances Personal Protection Equipment Environmental Protection Agency Chemical Accident Prevention National Pollution Discharge Elimination System Solid Waste Management Guidelines Standards for Hazardous Was te Generators Superfund, Emergency Planning and Community Right-To-Know Program United State Department of Transportation Federal Highway Administration Federal Motor Carrier Safety Regulations Research and Special Programs Administration Transportation Regulations for Hazardous Materials Employee Training Requirements for Hazardous Materials Federal Railroad Administration Hazardous Materials Transportation Regulations Hazardous Materials Regulations Alabama Department of Environmental Management Hazardous and Non-hazardous Waste Management Programs National Association of Chemical Distributors Responsible Distribution Process Facility Management Employee Training Product Stewardship Waste Management Community Outreach Carrier Selection Maintenance Systems The program includes an aggressive maintenance and process inspection system to verify all systems are in proper working order and repairs are accomplished promptly to minimize the risk of release from equipment failure. Transportation equipment used to move product on the public roads and highways are inspected both before and after each trip by qualified and competent operators. The vehicles are maintained according to a strict schedule by a company with a strong reputation in transportation equipment maintenance. All portable tanks, know as tote tanks, are designed for and dedicated to specific products. Each container is inspected before filling using a systematic approach to verify that each and every component is in suitable condition. Material handling equipment such as fork lifts are inspected daily and each unit receives periodic maintenance according to a schedule. All equipment used in the handling of material are routinely inspected for defects and promptly removed from service when found defective. Packaging areas are designed to minimize impact to the environment from a release. All packaging and product transfers are accomplished in areas with dikes, curbs, collection systems and con crete surfaces. These areas are routinely inspected and maintained according to a schedule designed to uncover defects in advance of an incident. Unloading stations are designed to contain a spill from a bulk transport tanks. The stations are equipped with sumps and transfer pumps to collect and transfer product to vessels should a release occur. Grounding and bonding equipment is installed at each station to minimize risks associated with static electricity. Chemical transfer systems including piping, pumps, hoses and connections are dedicated to specific products and processes. Whenever possible, these components are installed in areas away and protected from material handling equipment to reduce the likelihood of damage. All parts are routinely inspected according to a schedule and defective or worn parts are promptly replaced. Storage vessels are installed in containment areas constructed of concrete walls and floors. The capacity of each area is of sufficient size to capture si gnificantly more than the contents of multiple vessels should a rupture occur from one tank compromising the integrity of another. Each storage vessel is routinely inspected according to the program schedule designed to reveal defects that may compromise safety. Materials stored within buildings are located in areas specific to their hazard class to prevent one group of hazard class from impacting another during an incident. All buildings are constructed of poured concrete walls and floors to minimize the possibility of a release contacting the ground and impacting the environment. Equipment used in the areas to move containers are designed for their intended use. Storage areas are routinely inspected according to a schedule to minimize risks associated with improper material storage. The local fire department routinely inspects all areas of the facility for code violations. Buildings are equipped with 24 hour monitoring systems to alert authorities of high heat, smoke and fire con ditions. Emergency responders are dispatched to the scene by a monitoring service. Intrusion is monitored after hours to prevent unauthorized access to the property. The grounds are secured to prevent unauthorized access and the company uses a security service present after hours to monitor the facility. Five-year Accident History There have been no accidents or incidents associated with the regulated chemicals during the past five years prior to the date of the plan. Emergency Response Program The emergency response program document and procedures were developed when the Environmental Protection Agency enacted the Superfund Amendment and Reauthorization Act known as the Emergency Planning and Community Right-To-Know Program or SARA Title III. This program requires facilities having certain regulated substances in amounts exceeding threshold quantities to notify the State Emergency Response Commission (ERC), Local Emergency Planning Committees (LEPC) and fire departments that wou ld respond to the facility in an emergency of the existence of these substances. This information is updated annually and made available to the public through the LEPC. Documentation includes the chemical inventory of regulated substances, the container types and storage conditions, maximum amounts at the site during the year, average daily amounts and the number of days on site. In addition, site descriptions, drawings of the facility, locations within the facility of each chemical, surface area, equipment locations as well as emergency equipment are included in the documents. The emergency response and contingency plan developed and coordinated with local responders includes a description of emergency response equipment on site, contacts names and phone numbers, procedures for public notice, guidelines for notifying emergency response agencies and personnel, information gathering forms and methods and reports that must be completed and filed with regulatory agencies. The employee emergency response training program is included with this document and is used by the facility to train personnel in response techniques. The program provides training for hazardous incident recognition, personnel protection equipment selection and use, characteristics of hazardous chemicals and the methods for response, cleanup and decontamination. Planned Changes to Improve Safety Plans are continually updated to improve management of chemicals and reduce the risks associated with handling chemical products. Plan updates are the result of coordination with local responders, inspections by regulatory agencies, training sessions, process changes and new risk management programs and regulations enacted by the government. Presently all areas are being studied to identify technically, procedurally and economically feasible passive and active risk management strategies to further enhance the safe operation of the facility. |