Industrial Chemicals Inc. - Executive Summary |
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68.155 Executive Summary Industrial Chemicals Inc. 3212 Crichton Street Mobile, AL 36607-1411 April 1, 1999 Accidental Release Prevention and Emergency Response Policies The distribution facility is located off Western Drive north of US 98 on Crichton Street. The business has operated from this location for more than 10 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) regulations. To ensure the facility c ontinues 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 used 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 small packages and placed in storage for sh ipment to industrial customers. These prepackaged containers include portable tanks, cylinders and drums. 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 38 cylinders of 2000 pound capacity and 100 cylinders of 150 pound capacity. Only authorized and trained personnel are permitted to 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 s tored 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 demand periods inventory levels for this chemical are 15 ton cylinders at 2000 pounds each and 24 cylinders at 150 pounds 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 l ikely take the form of a cloud or plume, impacting only a portion of the circle located in the downwind direction from the source. Chlorine Worst Case Scenario for Container Storage Process ID 18 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 would involve 10,764 persons including residences, schools, hospitals and the surrounding industrial area. No impact to environmental receptors, such as wildlife refuges, was identified. Chlorine Alternate Scenario for Container Storage Process ID 18 This release scenario involved valve failure on a 2000 pound cylinder in storage 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 cylinder 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 25 persons in the surrounding industrial area. No residences, schools, hospitals or rec reation areas were impacted by the release No impact to environmental receptors, such as wildlife refuges, was identified. Sulfur Dioxide Worst Case Scenario for Container Storage Process ID 19 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 are urban with many obstacles. The estimated toxic distance to endpoint would be 1.3 miles and would have involved 10,764 persons in residences, schools and the surrounding industrial area. No impact to hospitals, recreation areas or environmental receptors, such as wildlife refuges, was identified. Alternate Scenario for Container Storage Process ID 19 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 on these containers. 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 25 persons in the surrounding industrial area. No residences, schools, ho spitals or recreation areas 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 the Operations Director verifies attendance. New employees are required to receive an extensive orientation to the operating procedures for each phase of the operation including material handling 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 Solid Waste Management Guidelines Standards for Hazardous Waste 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 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 in spected 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. The loading and unloading areas for transport vehicles are on concrete surfaces. A release occurring during the loading or unloading of packages can be contained to this area. Materials stored within buildings are located in areas specific to their hazard class to prevent on e group of hazard class from impacting another during an incident. All buildings are constructed of poured concrete floors to minimize the possibility of a release contacting the ground and impacting the environment. Equipment used in the areas to move containers is designed for their intended use. Storage areas are routinely inspected according to a schedule to minimize risks associated with improper material storage. Buildings are equipped with 24 hour monitoring systems to alert authorities of excessive heat, smoke and fire conditions. 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 to 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 pro gram 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 would 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 wel l 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 update s 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. |