George Mann & Company, Inc. - Executive Summary |
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Risk Management Plan George Mann & Co., Inc. Executive Summary George Mann & Co., Inc. has been doing business as a chemical manufacturer and distributor in Providence County for 78 years. We handle a variety of chemicals that are used in general industry, waste water treatment, and agriculture. Among the chemicals that we handle are chlorine and ammonia, chemicals that are listed in CAA 90 112(r) as toxic chemicals by the Environmental Protection Agency (EPA). The properties that make these chemicals valuable commodities also dictate that specific safety precautions are used during the handling of these chemicals to insure the safety of our employees, neighbors, and the public at large. As such, we adhere to local, state, and federal rules and regulations with regard to the handling and storage of these chemicals. Safety depends upon the manner in which we handle these chemicals, the safety devices designed into our facility, the safe handling practices and procedures that we u tilize, and the training of our personnel. Access to this site is restricted to authorized facility employees, authorized management personnel, and authorized contractors. The facility is surrounded by a six foot high chain link fence topped with barbed wire and is subject to video surveillance and 24 hour security patrol. Chlorine is received at our facility in 90 ton rail cars as a liquid under pressure. It is used in the manufacturing of sodium hypochlorite, more commonly known as bleach. Bleach is widely used in waste water treatment, as a disinfectant, and as a household laundry cleaner. Anhydrous Ammonia is received in 70 ton rail cars as a liquid under pressure. It is distributed to our customers via tank trucks and cylinders, and is also used in the manufacturing of Ammonium Hydroxide, or Aqua Ammonia. Ammonia is used as an aide in the heat treatment of metal hardening, as a fertilizer for agriculture, and as an ingredient in household cleaning products. Our worst c ase release scenario would involve the failure of a 90 ton rail car containing chlorine, resulting in the release of 180,000 pounds. Computer modeling makes the assumption that the entire contents of the rail car will be released to the air in 10 minutes time and that the distance to the endpoint of 0.0087 mg/l will be approximately 14 miles and will effect a population of approximately one million people. An alternative release scenario would involve the failure of a transfer pipe of chlorine, with a distance to the endpoint of 0.0087 mg/l of approximately 0.2 mile. However, due to the procedures and practices that are in place at our facility, the likelihood of either of these occurrences is extremely low. Although the EPA requires that we assume that the entire contents of a rail car can be released into the air in 10 minutes, this assumption is technically unlikely. All rail cars are subject to safety checks on a regular basis. All pipes, valves and connections are similarly checked, and connections made to a rail car with our own equipment are inspected and checked every time a hook-up is made. Since normal operations using chlorine and ammonia occur for 10 to 12 hours daily, 5 days per week, valves on chlorine and ammonia rail cars are closed when our process is not running. Lines, pipes, valves and hoses are bled down and do not remain under pressure when the process is stopped. Only one rail car of each of these chemicals is connected to our process at any one time. Rail cars are subject to constant video surveillance, and chlorine and ammonia "sniffers" are located at the rail car parking area. The sniffers can detect the first sign of a chlorine or ammonia leak, and will immediately sound an alarm and alert our personnel on site, as well as ADT Security Systems via telecommunications. This will allow us to take immediate corrective action to mitigate a release. In the event of the failure of a transfer line, automatic pressure shut-offs would activate to arrest the flow of chlorine or ammonia from escaping into the environment. This equipment and these procedures have been extremely effective in preventing any off-site releases of chlorine and ammonia, and our safety record of no off-site releases of any toxic chemical is a testimony to our on going safety efforts. Nevertheless, we have developed a comprehensive Emergency Response Program in the event of a chlorine or ammonia leak in a line, valve, rail car, tank truck, or that would occur during processing and that could develop into an off-site release. Our Emergency Response Program is based upon established practices and procedures developed in coordination with the Providence Fire Department, LEPC #5 for Providence, and the State Emergency Response Commission. It includes procedures for notification of all appropriate local, state, and federal authorities, as well as any potentially affected neighbors. Our Emergency Response Program has been developed in accordan ce with the Chlorine Institute's Pamphlet 64, "Emergency Response Plans for Chlorine Facilities", and with the Emergency Planning Rules published by The Bureau of National Affairs, Inc. The Providence Fire Department and LEPC #5 for Providence have been provided copies of our Emergency Response Program and are familiar with its contents. The Program includes step by step procedures for our plant workers and management personnel to follow in minimizing the effects of a release. In the event that an evacuation is necessary, our employees have been trained regarding our evacuation procedures. Our Plan also includes a telephone call list of emergency telephone numbers so that government agencies and all responsible management personnel will be properly informed in the event of an off-site release or spill of a reportable quantity of a dangerous chemical. A representative of the Providence Fire Department last visited this facility on August 26, 1998. This facility complies with EPA's Accidental Release Prevention Rule, and with state codes and regulations. We strive to remain abreast of any changes to these rules, and adjust our internal standards accordingly. We have had no off-site releases of any hazardous chemical in 46 years of operation at this facility. It is the goal of George Mann & Co., Inc., to continue to improve our operations in accordance with Responsible Distribution Guidelines while we maintain compliance with local, state, and federal regulations. Towards this end, we keep our employees well trained regarding safe work practices and emergency response procedures. An internal safety committee consisting of both union and management personnel meets on a regular basis as a way of constantly evaluating and updating any safety issues relating to our operations. We actively participate in local safety associations, environmental associations, and the Local Emergency Planning Committee so that we can maintain communication regarding all environmen tal, health and safety aspects of maintaining a responsible operation. |