General Chemical Corporation - Executive Summary |
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Executive Summary This Risk Management Plan (RMP) is submitted by General Chemical Corporation's Newark Works in compliance with the requirements of section 112(r)(7) of the Clean Air Act (CAA) and was prepared in accordance with tanked States Environmental Protection Agency (USEPA) regulations contained in 40 CFR Part 68, Accidental Release Prevention Provisions. The Accidental Release Prevention program requires the owner of a stationary source having listed substances present in quantities greater than the corresponding threshold quantities to develop and implement a risk management program. The program must consist of a hazard assessment, a release prevention program and an emergency response program. Additionally, the operator must describe the site's risk management program in a risk management plan (RMP). However, the regulation provides for 3 different programs of compliance dependent upon the eligibility criteria of covered processes including, but not limited to, the pote ntial impact of chemical releases as identified in the hazard assessment. For example, chemical processes which meet the criteria for program level 1 and program level 2 have very minimal requirements for release prevention programs and emergency response as compared to those for program level 3. At General Chemical's Newark Works, two listed chemicals are managed on-site in quantities greater than the threshold quantity under the program level 3 criteria. These chemicals are Oleum and Nitric Acid. No chemicals are managed on-site under program 1 or program 2 criteria. As identified in this plan, Newark Works is in compliance with the requirements of 40 CFR Part 68 for the management of Oleum and Nitric Acid. This RMP describes Newark Work's risk management program which includes a hazard assessment, release prevention program and emergency response program. The hazard assessment includes one worst case release scenario and two alternative case release scenarios. The hazard asses sment was conducted in accordance with 40 CFR Part 68, Subpart B (68.20-68.42), as well as the USEPA's Off-site Consequence Analysis Guidance Document. The release prevention and emergency response programs at this site were developed based on requirements of the CAA's Accidental Release Prevention Provisions, the OSHA Process Safety Management Standard and the New Jersey Toxic Catastrophe Prevention Act. This RMP was prepared in accordance with 40 CFR Part 68, Subpart G (68.150-68.190), which provides a format for a written RMP. The required elements of an RMP, as defined by the USEPA, are listed below along with the section in which they are located in this RMP. All information identified in the attached registration form is current as of May 1, 1999. * Section 1.0 - Accidental Release Prevention and Emergency Response Policies * Section 2.0 - Description of Stationary Source and Regulated Substances * Section 3.0 - Hazard Assessment * Section 4.0 - General Accidental Release P revention Program and the Chemical-Specific Prevention Steps * Section 5.0 - Five Year Accident History * Section 6.0 - Emergency Response Program * Section 7.0 - Planned Changes to Improve Safety 1.0 Accidental Release Prevention and Emergency Response Policies General Chemical Corporation recognizes that the responsible management of health, safety and the environment in and around its facilities is one of its highest corporate priorities and a key element in its successful business strategy. General Chemical Corporation is committed to implementing policies and procedures which ensure that its operations are conducted in compliance with applicable laws and regulations. Achieving responsible health, safety and environmental management will be accomplished by: operating our facilities safely and prudently; efficiently using energy and materials; seeking ways to minimize or reuse wastes; and otherwise complying fully with all applicable local, state, and federal laws and regulati ons. Our policy is to implement reasonable controls to prevent and/or mitigate foreseeable releases of regulated substances. However, if a release does occur, Newark Works has prepared employees in conjunction with local emergency response groups, to respond to a release. 2.0 Description of Stationary Source and Regulated Substances General Chemical's Newark Works produces Oleum and Sulfuric Acid for use in local and national markets. These chemicals are used in many applications including water treatment, papermaking, detergents, batteries, nylon and computer chips. Oleum is transferred off-site via tank truck and tank car. Nitric Acid is used as a raw material in the mixed acid process. Two production processes at Newark Works use one or more of the regulated chemicals identified above. The processes, and associated regulated chemicals, are outlined below: Process: Oleum Production Regulated Chemical : Oleum Use: Product Quantity stored per process (lbs.) : 5,000,000 Pro cess: Oleum Production Regulated Chemical : Sulfur Trioxide Use: Intermediate product Quantity stored per process (lbs.) : 620 Process: Mixed acids Regulated Chemical : Nitric Acid Use: Raw Material Quantity stored per process (lbs.) : 125,000 Process: Sulfuric acid production Regulated Chemical : Sulfur Trioxide Use: Intermediate product Quantity stored per process (lbs.) : 620 3.0 Hazard Assessment USEPA's Accidental Release Prevention Provisions require that General Chemical provide information about the worst case release scenario and alternative case release scenarios for Oleum and Nitric acid handled at its Newark Works. The following are brief summaries of these scenarios. 3.1 Worst Case Release Scenario The worst case release scenario as defined by the USEPA is a hypothetical accident for one of the chemicals at a site. It assumes that all safety systems in the facility simultaneously fail and that the entire contents of the largest tank holding it at a site is released in a very short time. A USEPA-designated table defines the distance the material will travel until it disperses so much that it is no longer hazardous. The worst case release scenario at General Chemical's Newark Works assumes that a storage tank containing Oleum fails. The USEPA requires us to assume that all safety and release prevention systems simultaneously fail, except for secondary containment currently installed around the Oleum storage tanks, and the contents are released in 10 minutes. The USEPA-designated table states that the material released would travel 11 miles before it reaches a non-hazardous concentration. 3.2 Alternative Case Release Scenarios The alternative case release scenario is a more credible hypothetical, site-specific chemical release. It takes into account safety and release prevention systems and procedures used at the plant to control releases. It is more realistic than the worst case release scenario; is calculated using USEPA-design ated table; and, is used to plan a facility's emergency response to accidents. 3.2.1 The alternative case release scenario for Oleum at Newark Works assumes Oleum would be lost due to failure of a loading hose during the transfer process. It takes into account plant safety systems designed to limit a release. . The USEPA-designated table states that the material released would travel 0.47 miles before reaching a non-hazardous concentration. 3.2.2 The alternative case release scenario for Nitric Acid at Newark Works assumes Nitric Acid would be lost due to failure of an unloading hose during the transfer process. It takes into account plant safety systems designed to limit a release. The USEPA-designated table states that the material released would travel 0.30 miles before reaching a non-hazardous concentration 4.0 General Accidental Release Prevention Programs and Chemical - Specific Prevention Steps General Chemical maintains a comprehensive release prevention program des igned to prevent accidental releases and ensure safe operations of our processes. The accidental release prevention program implemented at Newark Works includes procedures and practices which address each of the required elements of the risk management program including: * Process Safety Information - Information relating to the hazards of the chemical(s), process technology and equipment information is maintained to ensure proper operation. * Mechanical Integrity - Equipment is routinely inspected and maintenance activities are managed in a manner to maintain the integrity of the equipment. * Process Hazard Analysis - Processes are routinely analyzed to identify and correct potential hazards, as well as increase the safety of the operating conditions. * Standard Operating Procedures - Detailed procedures are in place identifying actions necessary for multiple phases of operation, operating limits and safety considerations. * Employee Participation - Employees at all levels are i nvolved in key roles of the release prevention program. * Training - Employees in the operating process are trained in detail to ensure proper operation of the plant. * Management of Change - Process parameters are maintained through a management of change system which documents the changes as well as evaluates changes for safety. * Pre-startup Safety Review - Significant changes to the processes are evaluated in detail in order to verify that the proper procedures for engineering, operations, emergency response and overall safety are addressed prior to start-up. * Incident Investigation - All incidents are investigated to ensure proper modifications are made to reduce or eliminate the potential for re-occurrence. * Safe Works Practices - Standard safety practices are in place to help insure worker safety including lockout/tagout procedures, control of entry into process areas, line breaking procedures, confined space entry procedures and hot work procedures. * Contractor Safet y - Contractors are evaluated and trained prior to performing work on-site to reduce the potential of an incident. * Compliance Audits - Audits are performed at a minimum of three-year intervals to verify procedures and practices are adequate and are being followed. * Emergency Response - Plans are made with the community emergency response groups as well as onsite emergency response teams to ensure procedures are in place in case an emergency situation occurs. In addition to this general accidental release prevention program, General Chemical's Newark Works has taken additional chemical-specific prevention steps designed to perform the following: * quickly detect a release of an extremely hazardous substance; * contain or control a release of an extremely hazardous substance; * and/or, reduce the consequences of a release of an extremely hazardous substance. The following types of safety features are used in various processes: Release Detection * High level alarms in Oleum storage tanks * Process temperature and pressure controls * Operator surveillance of all process areas * Area monitoring for early detection systems Release Containment and Control * Pressure relief devices on pressurized storage tanks and process vessels * Secondary containment for storage tanks * Check valves on unloading systems * Automatic and manual shutdown systems on process equipment Release Mitigation * Emergency shutdown procedures * Trained emergency response personnel * Notification procedures for plant personnel and local officials * Personal protective equipment for emergency response personnel * Emergency Response plans prepared with local emergency response officials 5.0 The Five Year Accident History Due to proactive actions taken to prevent accidents and the strong safety culture developed by General Chemical's Newark Works, there have been no incidents in the past 5 years that meet the reporting requirements for the USEPA's Accidental Release Preven tion Provisions. 6.0 Emergency Response Program General Chemical's Newark Works maintains an integrated contingency plan which consolidates all of the various federal, state and local regulatory requirements for emergency response planning. Our program provides the planning and training necessary to effectively protect workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the Essex County Office of Emergency Management (OEM). Newark Works, the OEM and the local fire departments have coordinated communication to notify the public quickly, if necessary, as well as facilitate quick response to an incident. In addition to periodic committee meetings, Newark Works conducts periodic emergency response drills that involve emergency response organizations. 7.0 Planned Changes to Improve Safety General Chemical's Newark Works facility performs periodic process hazard analysis to evaluate and to strive continuously to improve h ealth, safety and environmental performance as technical developments, scientific understanding, consumer and community needs, and regulatory requirements evolve and change, some of which result in process modifications. The Newark Works facility has been in the New Jersey Toxic Catastrophe Prevention Act program since 1986. As a result, the plant has undergone numerous hazard analysis reviews for the processes subject to this program . We have successfully implemented the recommendations identified during these reviews. The plant continues to operate using the release prevention program implemented at the site as identified above. Newark Works is currently implementing the rigorous QS-9002 and continues to optimize plant equipment through the use of a preventive/predictive maintenance program. 8.0 Certification The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inqui ry, the information submitted is true, accurate and complete. ____________________________________ Pasquale Prudente Director of Manufacturing _____________________________________ Date 4 1 |