Van Waters & Rogers Inc. - Executive Summary |
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RMP PLAN EXECUTIVE SUMMARY COMPANY OVERVIEW Van Waters & Rogers Inc. is a wholesale chemical distributor serving a number of U.S. industries. Founded in 1924, VW&R supplies the food industry, chemical compounders, pharmaceuticals, mining, forest products, oil and gas producers, electronics, coatings and many other key industries with the chemical raw materials required to produce or refine products used in numerous end-use markets. Van Waters & Rogers Inc. is a member of the National Association of Chemical distributors (NACD) and complies with the Responsible Distribution Process (RDP), an environmental, health and safety improvement initiative. Some of the products stored and handled by VW&R are subject to EPA's Risk Management Program rule (40 CFR Part 68). A key requirement of this rule is the preparation and submission of an RMP Plan, contained herein. The contents of the RMP Plan are prescribed by EPA, including this Executive Summary. CORPORATE PREVENTION AND EMERGENCY RESPONSE APPROACH 1. Prevention Program Processes that are subject to OSHA's Process Safety management (PSM ) standard AND are regulated under EPA's RMP rule are subject to the Program 3 Prevention program. Van Waters & Rogers Inc. has documented the Prevention Program in its Process Safety Management Manual. Briefly, this program includes provisions and requirements for: * Process Safety Information * Process Hazard Analysis * Operating Procedures * Training * Mechanical Integrity * Management of Change * Pre-Startup Review * Compliance Audits * Incident Investigation * Employee Participation * Hot Work permits * Contractors 2. Emergency Response Approach Van Waters & Rogers Inc. has an Emergency Contingency Plan in place. This Plan is shared with local emergency responders who have access to VW&R facility personnel (and up-to-date phone numbers). VW&R responds to minor incidents but will call in professional emergency responders in the event of all other incidents. VW&R in vites and encourages local emergency responders such as the fire department to visit and familiarize themselves with VW&R products and facilities. Joint emergency exercises are conducted when possible. STATIONARY SOURCE The primary activities at this facility include warehousing, repackaging and distribution of industrial chemicals in support of local industries. Included in our product base is one regulated substance, hydrofluoric acid (>50%). We warehouse hydrofluoric acid in their original packaging, and do not repackage the material in any way prior to sale. We must maintain enough inventory to meet customer demand, but for safety and business reasons we also attemt to keep those levels as low as possible. With regard to hydrofluoric acid, our typical inventory quantity would be approximately 10 - 55 gallon containers. WORST-CASE RELEASE SCENARIO(S) The worst case scenario for storage of hydrofluoric acid at this site would be the total release of the largest container on site (55 gallon drum, 385 lbs) within a 10 minute time frame. By using approved modeling software (EPA's RMPComp) we have determined that vapors from this worst case release would travel <0.1 miles before dispersing enough to no longer pose a hazard to the public, as determined by EPA guidance. ALTERNATIVE CASE RELEASE SCENARIO(S) The alternate case scenario related to this site would be the release of 175 pounds of hydrofluoric acid over a 5 minute time frame. Again, using the same modeling software, we have determined the vapors from this release would also disperse enough to no longer pose a hazard to the public at <0.1 miles. GENERAL PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS As outlined previously, VW&R is subject to OSHA's Process Safety Management regulation and utilizes this program to meet the prevention program requirements under RMP. Chemical-specific prevention steps include the following: * Maintaining minimal inventory * Standard operating procedures on safe handling of the chemical * Emergency response training to minimize the impact of a release * Storage of the product in appropriate D.O.T. approved containers and in designated locations based on compatability and safety. ACCIDENT HISTORY Over the past 5 years this facility has had no incidents involving hydrofluoric acid EMERGENCY RESPONSE PROGRAM We have an Emergency Contingency Plan which has been coordinated with the Phoenix Fire Department as well as the Maricopa County Local Emergency Planning Committee. Updates to this plan are distributed to appropriate agencies when information about our facility changes. Additionally, joint training and practice drills with the Phoenix Fire Department have been conducted, as well as annual site visits by the Phoenix Fire Department to ensure that they are familiar with this site. Page 1 of 1 |