Hisco Inc. - Executive Summary
Hisco, Inc. (Hisco) owns and operates a warehouse and distribution facility in the City of Austin, Travis County, Texas. Hisco has reviewed its obligations under EPA's Risk Management Program Rule (RMP Rule, Section 112(r) of the Clean Air Act). In response to these requirements, Hisco notes that there are two obligations incumbent on the operations at its facility: |
1. '112(r)(1) - Purpose and General Duty Clause - The essence of the general duty clause is that an owner/operator that stores and uses hazardous chemicals in any quantity has a fundamental obligation to ensure a safe operation, and to have plans in place in the event of an accident to appropriately manage the situation. Hisco takes this obligation very seriously, and intends to be not only a good neighbor but also a leader in community safety and emergency preparedness.
2. Risk Management Plan - Hisco stores hydrochloric acid and ammonium hydroxide in excess of thresholds specified in '112(r). Even prior to the promulga
tion of the RMP Rule, Hisco management has been very aware of the potential hazards posed by the storage of hydrochloric acid and ammonium hydroxide, and has established programs to prevent any accidental releases and training for emergency response in the event of a release. These programs are documented and described in this Risk Management Plan.
Chemicals are stored at Hisco prior to being distributed to other companies. Hydrochloric acid and ammonium hydroxide are delivered as liquids in 55-gallon drums, and there are currently 200 drums of ammonium hydroxide and 34 drums of hydrochloric acid at the facility at any one time. Hisco anticipates that hydrochloric acid storage could increase to 60 drums. For planning purposes, Hisco has considered the impact of a sudden release of the entire contents of one 55-gallon drum of hydrochloric acid and one 55-gallon drum of ammonium hydroxide within a ten-minute period of time. Very conservative (i.e., "worst case") assumptions about p
ossible weather conditions and a predictive model indicate a potential radius of impact extending to 0.2 miles for hydrochloric acid and 0.1 miles for ammonium hydroxide. A consideration of this radius has been incorporated into our notification and emergency response planning.
Hisco also considered the impact of a more likely release, based on a five-year accident history. In the past five years, Hisco has not experienced any accident involving an RMP chemical at its facility.
Hisco has implemented safety precautions to prevent and mitigate a release of hydrochloric acid or ammonium hydroxide. Hisco has extensively coordinated with local emergency responders including the Austin Fire Department. Hisco's management is committed to:
7 Preventing accidents;
7 Training our employees in correct response procedures in the event of an accident;
7 Providing leadership to the community with respect to emergency preparedness;
7 Addressing any citizen concerns by fully explaining potential
hazards associated with facility operations and all steps being taken to prevent and mitigate accidents; and
7 Being a good corporate citizen of Travis County.
With these objectives in mind, this Risk Management Plan provides information about Hisco's management of the risks associated with the warehouse and distribution process, but more importantly Hisco stresses their commitment to ensuring a safe operation for employees, visitors, and the community.