ALL-PURE CHEMICAL - SANTA FE SPRINGS - Executive Summary

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   Introduction 
The All-Pure Chemical Company (APC) is committed to the safety and well being of its employees, neighboring community, and the environment. APC is an active member of the Chlorine Institute, an industry group that develops technology for the safe handling and management of Chlorine, and participates in the Chemical Manufacturers Association Responsible Care initiative.  Responsible Care is the industrys effort to reach out and dialogue with the public regarding our environmental, health and safety programs and to receive input from the community on issues of concern. We are also a participating member of the Santa Fe Springs area Community Awareness and Emergency Response (CAER) group. Our products include chlorine, sodium hypochlorite(bleach),  sodium hydroxide(caustic) and sulfur dioxide.  These chemicals provide important benefits in critical applications such as water purification and household disinfectants.  APC's policy is to implement reasonable measures to pre 
vent a release of hazardous material from occurring, to provide early detection of a release in the unlikely event that one would occur, and to have in place a contingency plan to respond promptly yet safely to such a release. 
    
   Regulated Substances 
This Risk Management Plan has been prepared to address the handling of the following regulated substances at the APC facility located at 11600 Pike Street, Santa Fe Springs, CA 90670: - 
 
       Chlorine 
       Sulfur Dioxide 
 
Chlorine, as a liquid is received in 90-ton rail cars and repackaged into tank trucks, ton containers and 150 lb. cylinders. It is also used in the manufacture of sodium hypochlorite (bleach). Both chlorine and bleach are used by customers in treating drinking water, wastewater, swimming pool water and industrial water to eliminate and/or prevent growth of harmful organisms in the water. 
 
Sulfur dioxide is received in ton containers and 150 lb. cylinders and is stored for supply to customers. No repackaging takes place. Sulfur  
dioxide is also used in water treatment. 
 
   Worst Case & Alternate Scenarios 
The Environmental Protection Agency (EPA) has defined the Worst Case Scenario as the hypothetical rupture and full release of  all contents of the facilities largest storage vessel in 10 minutes, assuming all safeguards have failed, during extremely stable weather conditions.  Our scenario would involve a full 90-ton rail car of chlorine.The EPA has also specified in the RMP rule that each facility must define a specific Alternate or Realistic Scenario that could also have off site impact, based on plant operations. The Realistic Scenarios may be modeled using the actual active and passive mitigation systems that are in place if they are capable of withstanding the event that triggered the release, during typical weather conditions. The realistic scenario selected and modeled for chlorine was the release that would result from a 1/16 pinhole in a pipe containing chlorine or in the fusible plug of a ton contain 
er of chlorine.The realistic scenario selected and modeled for sulfur dioxide was the release that would  result from a 1/16 pinhole in a fusible plug of a ton container of sulfur dioxide. All scenarios modeled have offsite impacts. No credit for measures in place to prevent and/or mitigate such a release were taken. 
 
Accidental Release Prevention Program 
APC has a comprehensive release prevention program, meeting the California Accidental Release Prevention plan, and exceeding the Federal RMP Prevention Program and OSHA Process Safety Management (PSM) requirements. We have in place, physical safeguards to prevent a release of chlorine or sulfur dioxide.  We also follow best industry practices for the design and construction of equipment, piping and instrumentation. Our process design includes expansion bottles and/or rupture disks and pressure switches to safeguard against hydrostatic overpressure of equipment and piping. 
 
   Five Year Release History 
An accident involving the release  
of chlorine occurred on July 28, 1995. Trained APC personnel supported by Santa Fe Springs Fire Department (SFSFD) personnel responded promptly yet safely to halt the release of chlorine. Some employees from a neighboring facility were sent to a local hospital for precautionary observation. However, there were no injuries to onsite or offsite personnel and no onsite or offsite damages to property or the environment.  
    
   Emergency Response 
APC has a comprehensive emergency response program that includes the installation of detection, alarm, shutdown, containment and scrubbing systems to halt and/or mitigate a release. In the unlikely event that a release cannot be controlled completely with these systems, APC has an Emergency Response Team trained and equipped to respond safely to a release in accordance with a written Emergency Response Plan. APC has worked closely with SFSFD in developing its Emergency Response Plan and the SFSFD Hazmat Unit has participated with APC in several traini 
ng exercises at the APC facility in SFS. 
 
   Safety Improvements 
APC undertook a major upgrade of the facility in 1995 that resulted in the installation of various detection, alarm, shutdown and other systems. APC performed a new Process Hazard Analysis in 1999 as part of the development of the Risk Management Program. The following additional steps have been made or are planned to improve safety: - 
 
   -  Installation of additional automatic shutdown devices. 
   -  Implementation of various seismic upgrades. 
-    Revision of procedures to incorporate additional safety requirements. 
 
Y2K Sensitivity 
We are aware and sensitive to the year 2000 software issue.  We have a plan in place to conduct an assessment. However, as an additional precaution, the facility will be closed and all processes secured on December 31st and January 1st and we will conduct a pre-startup safety review prior to our next operating day.
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