ChemTreat, Inc. - Ashland Plant - Executive Summary

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Executive Summary - Program 2 
ChemTreat, Inc.s plant in Ashland, Virginia  is a small blending facility of industrial water treatment chemicals for use in boilers, cooling systems, and wastewater systems.  The only regulated substance under the Risk Management Plan rule used by the facility is cyclohexylamine.  The inventory for this chemical never exceeds 57,800 pounds.       
ChemTreats mission regarding chemical safety is to manage our people and systems to protect the health and safety of employees, the community and the environment.  ChemTreat has developed and implemented an environmental, health and safety management program which consists of written safe work procedures, training, and periodic audits to ensure compliance. 
Worst-Case Scenario 
The worst-case scenario projects a complete failure of the cyclohexylamine storage tank and the subsequent vaporization of 57,800 pounds of released chemical.  According to the EPAs RMP-Comp (dispersion modeling software), t 
he off-site impact for this scenario is 0.2 mile (or ~1,000 feet) radius from the storage tank.  The possibility of this ever occurring is extremely remote as ChemTreat has implemented several layers of protection.  The cyclohexylamine storage tank is of the latest design meeting all applicable technical specifications and having been installed in the past two years.  Furthermore, the facility has put in place such passive mitigation systems as a concrete dike around the tank which limits the potential exposed surface of any pool of cyclohexylamine, thus, reducing the release radius from 1.4 miles to 0.2 mile.  In the event of a release, a drain pump in the contained area will directly route the chemical to a fully contained storage tank.  Other preventive measures include administrative controls such as daily tank inspections and a preventive maintenance program which is explained in further detail below under the Maintenance section. 
Alternative Scenario 
The alternative scenario con 
sists of a transfer hose failure during the process of unloading cyclohexylamine from a delivery tank truck to the storage tank.  The release is two minutes in duration and results in a release of 1,500 pounds, with an off-site impact of 0.1 mile (or ~500 feet).  Again, ChemTreat has put in place several layers of protection to ensure this scenario does not occur.  Passive mitigation systems, such as berms surrounding the unloading pad and a sump pump on the pad, are used to contain the chemical released and safely pump it directly to a fully contained storage tank.  Administrative controls have also been enacted.  For example, standard operating procedures require that an operator be in attendance at all times during the unloading process.  Thus, if a hose failure does occur, operator intervention and isolation of the chemical will significantly reduce the potential for off-site impact. 
Prevention Program 
ChemTreat, Inc. takes a systematic approach to preventing accidental releases o 
f hazardous chemicals.  Our management systems address each of the key features of an accidental release prevention program including safety information, hazard review, operating procedures, training, maintenance, compliance audits, and incident investigation. 
These individual elements of our accidental release prevention program work together to prevent accidental chemical releases.  ChemTreat, Inc. and our employees integrate these management systems into the way we do business and establish specific accountability for accident prevention into our process. 
Safety Information 
In accordance with Section 68.48 of the RMP rule, we systematically control the development, updating, and retention of documentation associated with our process chemicals, process technology, and process equipment.  This information is essential for supporting all of the other elements of our risk management program.  We also use this information directly to ensure that our equipment is suitable for its intend 
ed use. 
We maintain the chemical process information for each regulated substance in a covered process as well as for other hazardous materials in both covered and non-covered processes.  Chemical process information includes toxicity information, permissible exposure limits or threshold limit values, physical data, reactivity data, corrosivity data, thermal and chemical stability data and the hazardous effects of inadvertent mixing or different materials that could foreseeably occur.  This information may be found in the Material Safety Data Sheets (MSDS) which comply with OSHAs Hazard Communication Standard 29 CFR 1910.1200. 
Additionally, we maintain the following required process technology information:  manufacturing work orders (mixing instructions); process chemistry; maximum intended inventory; safe upper and lower limits for parameters such as temperature, pressure, flow, or composition; piping and instrument diagrams (P&IDs); electrical classification; design codes and stan 
dards employed; and equipment specifications 
Hazard Review 
In accordance with Section 68.50 of the RMP rule, we use hazard reviews to systematically identify, evaluate, and control process hazards.  The most important products of our reviews are recommendations for reducing the most significant risks of accidental chemical releases.  We ensure that all recommendations from our reviews are resolved appropriately, and we ensure that information from our reviews (including recommendation resolutions) is communicated to all potentially affected employees. 
We conduct systematic hazard reviews of the regulated process at our facility at least every five years (or more often if necessary because of process changes).  Hazard review reports are generated which document the required regulatory items and are maintained at the facility.  All issues identified in the hazard reviews are resolved prior to startup of the changed process.  
A cyclohexylamine handling and storage system hazard review  
document representing a walk through of the entire cyclohexylamine system, potential problems noted, alarm conditions, and emergency action steps which must be taken to ensure employee and public safety has been developed.  This walk through was conducted by several key plant employees with the assistance of an outside consultant who is very experienced in conducting hazardous operability studies (HAZOPs).  A HAZOP approach was used in the creation of the hazard review document. 
Our hazard review team is composed of personnel with engineering and process operating experience, including at least one person who has knowledge and experience in the process to be evaluated and a team leader trained in the application of the HAZOP technique used for the hazard review. 
Operating Procedures 
In accordance with Section 68.52 of the RMP rule, we use operating procedures to define how process-related job tasks assigned to our personnel should be performed to avoid incidents.  We use these proced 
ures to (1) train our employees/contractors before they performs tasks in the field, (2) serve as a reference guides for personnel performing tasks, and (3) specify what to do if a process upset or operating emergency occurs.  The facility maintains documentation which show operator and mechanic certifications for those who are responsible for the cyclohexylamine system. 
Standard Operating Procedures have been developed and revised to reflect the findings of the hazard reviews.  These procedures contain the required steps to run the process for all modes of operations. These Operating Procedures shall be updated at least annually or whenever a change in the operation of the system occurs.  The Production Manager shall be the only employee who is authorized to make changes in these procedures with the guidance and approval of the remaining hazard review team members. 
In accordance with Section 68.54 of the RMP rule, we train our employees to safely perform their assigned task 
s.  Our training program includes initial training as well as refresher training every three years, or more often if major process or equipment changes are made.  As part of our training, we include provisions for ensuring that employees understand the training (field demonstrations, observation, etc.). 
ChemTreat currently has an employee training program in effect for all of its employees.  This program combines the training programs and materials available from ChemTreat, vendors and suppliers of the cyclohexylamine equipment and the knowledge and expertise of facility personnel.  The current outline of the training program is available. 
ChemTreats employee training program is administered by the Production Manager and the Maintenance Supervisor for each of their respective departments.  Both of these positions are under the direction and guidance of the Director of Operations.  The responsibility for ensuring that the employees are properly trained and aware of all safety practic 
es, hazards, emergency procedures, and maintenance procedures associated with their jobs is shared between the above individuals.  Keeping the employee informed and trained will only help to minimize the potential for an on site accident.  Important elements of the training program include initial training, refresher training, and documentation. 
In accordance with Section 68.56 of the RMP rule, we maintain our process equipment using an inspection and testing program and we ensure that our equipment is designed and installed correctly so that it operates properly.  We train our maintenance personnel in the hazards of the process. 
An ongoing mechanical integrity program is used to ensure safe process operation.  The elements of the mechanical integrity program include the identification and categorization of equipment and instrumentation, inspections and tests, testing and inspection frequencies,  
Compliance Audits  
In accordance with Section 68.58 of the RMP rule, we con 
duct compliance audits to ensure that the facility is in compliance with the RMP rule.  Audits are conducted at least every three years, and more often if necessary to verify that the procedures and practices developed under the RMP are adequate and are being followed.  At the completion of each audit, a report is generated which documents any noncompliances. 
The Director of Operations promptly reviews the audit findings, determines an appropriate response for each finding, assigns responsibility for implementation of a corrective action, and assigns a target completion date.  The corrective actions are placed in a tracking system, using an electronic database, progress is monitored quarterly until open issues are resolved.  We retain the two most recent audit reports. 
Incident Investigations 
In accordance with Section 68.60 of the RMP rule, we perform incident investigations to help ensure that incidents with catastrophic magnitude or potential are thoroughly investigated, root caus 
es are identified and corrected, and relevant findings are communicated throughout our organization to help prevent a recurrence. 
An incident investigation team has been formed comprising of the following personnel:  a representative from the Regulatory Affairs Department, the Maintenance Supervisor, the Production Manager, and a production employee.  All incidents which caused or could have caused a release of cyclohexylamine shall be investigated no later than 48 hours of the incident.  At the conclusion of the investigation, a report shall be prepared by the Regulatory Affairs Department and reviewed by the team.  The report shall include at a minimum:  the date of the incident, the date the investigation began, a description of the incident, the factors that contributed to the incident, and any recommendations resulting from the incident. 
The recommendations resulting from the incident shall be presented to senior management who will review the final report and determine a course 
of action to resolve such recommendations. 
All recommendations and facts relevant to the incident shall be reviewed with all affected personnel whose job tasks are affected by the findings.  The incident investigation report shall supplement the supervisors incident report and be retained by the Regulatory Affairs Department for a period of five years. 
Five-year Accident History 
Since the plants origin in 1972, there have never been any releases or incidents involving cyclohexylamine that have resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 
Emergency Response Program 
ChemTreat is included in the Hanover County Emergency Planning Commissions community emergency response plan.  ChemTreat coordinates any chemical release response actions with the Hanover County Fire Department and has the appropriate mechanisms in place to notify emergency responders  
when there is a need for a response. 
Ongoing Efforts to Improve Safety 
ChemTreat continuously evaluates and improves upon its operating processes for environmental and safety improvements.
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