BetzDearborn - WASHOUGAL Plant - Executive Summary
Executive Summary |
Accidental Release Prevention And Emergency Response Policies
Our company senior management and the facility personnel are committed to safety and implementation of safe procedures. We operate under our parent company, Hercules Incorporated, policy for Safety, Health & Environment. This policy states:
"...we are dedicated to and working towards continuous improvement in our operations to prevent pollution; to reduce risk; and to enhance safety, health and environmental performance."
"We will evaluate the safety, health, and environmental impacts of new and existing products and operations and will work to reduce adverse impacts."
"We will work to continually reduce workplace injuries; incidents with the potential for causing property damage, material loss, or interruption of our business; waste; and releases to the environment."
Facility Description And The Regulated Substances Handled
BetzDearborn Inc. manufactures specialty water-treatment chemicals, p
rimarily used for the treatment of water and wastewater in industrial process systems such as boilers and cooling towers. Most of our products are formulated by blending several raw materials within a mixing vessel and then packaging into various size containers. Depending on our customer's needs, our package types can range from small 5 gallon pails to 6000 gallon truckload quantities. Similarly, our raw materials which we receive from suppliers come in various size containers depending on customer demand for the product and the amount necessary to meet supply limitations and production demand.
The BetzDearborn - Washougal Plant covers 3.3 acres of property, of which 1.4 acres is used for offices, warehouse(s), production facilities and outdoor material storage. The balance is used for access roads, parking lot or open lawn, or idle areas. At the facility, cyclohexylamine is a chemical raw material stored onsite as a liquid in 55 gallon drums. It acts as a corrosion inhibitor
by neutralizing acids and elevating pH in steam condensate, which makes it particularly useful as a component of our product line and to our customers. This material is stored in a protected area and removed from any combustion sources.
The Worst-Case Release Scenario(s) And The Alternative Release Scenario(s)
Within the cyclohexylamine drum storage process, our "Worst Case" event involves a scenario where the contents of several drums are lost as an instantaneous release to an uncontained pavement outdoors during material transfer. Using the U.S. EPA Offsite Consequence Guidance modeling data, this scenario would have an offsite consequence. Although this material is normally stored in a protected containment area when not in transit, for the purposes of meeting the EPA requirements we did not consider any "passive" controls. We also conservatively viewed that an amount of several drums would be released without any intervention by plant personnel to stop the release or to cont
rol the spread of the release, even though our facility personnel are capable of responding to mitigate a release of this chemical in various ways. Because all plant operators are well trained in hazardous chemical handling procedures, forklift operation, and spill response, we think that a release event of this sort is unlikely to occur.
As an "Alternative Scenario" an event more likely to occur than the "Worst Case" involving cyclohexylamine, we considered a release event of a single drum, again using the EPA methodology. Mitigation systems were not included in this scenario. The analysis indicates that this scenario would have an offsite consequence but it would be limited to a distance slightly less than that of the "Worst Case" scenario. We chose to evaluate this scenario because the EPA required an "Alternate Scenario" that extended beyond the fenceline, although we feel an event involving a minor drum puncture of substantially less than a drum quantity would be more likely
and would have no offsite consequences.
The General Accidental Release Prevention Program And Chemical-Specific Prevention Steps
The purpose of the program is to define steps that are taken to identify, evaluate, and prevent or mitigate releases of hazardous chemicals that could occur as a result of failures in processes, procedures, or equipment. The prevention program includes elements that cover the compilation of process safety information related to the process, performance of process hazard review to identify and evaluate potential release scenarios, development and use of operating procedures, processes for insuring proper training of employees who are involved in handling hazardous chemicals, preventive maintenance for key equipment to limit the potential for failures that could cause releases, processes for managing changes in the process and conducting incident investigations for any release events that may occur. The prevention program also includes requirements for per
forming compliance audits of the implementation of the prevention program.
The Five-Year Accident History
At the BetzDearborn - Washougal Plant we have not had any accidental releases that resulted in significant death, injury, property damage on-site or known offsite deaths, injuries, evacuations, sheltering-in-place, property or environmental damage in the past 5 years due to the use or handling of cyclohexylamine.
The Emergency Response Program
Our chemical release response program contains these elements:
- Identification of emergency organization personnel structure and functional responsibilities
- Quarterly inspections to determine any new sources of ignition and a check of safety control devices
- Fire extinguisher training
- Fire drills conducted by our facility
- Spill and release control instructions
- Evacuation procedures and external response notifications
- Incident coordination with local emergency responders
- Incident analysis and review with all plant personn
el, and identification of procedure changes
- Annual program review and re-training
Planned Changes To Improve Safety
Our plans for safety improvement include: implementing a single layer-only operating practice, when transporting RMP-regulated substances on-site via forklift truck. Also, we intend to evaluate the feasibility of additional fire protection equipment to service RMP regulated processes.