Helena Chemical Company, Cordele Facility - Executive Summary |
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The Helena Chemical Company Cordele Facility has submitted this electronic RMP in compliance with the provisions of the Clean Air Act Section 112(r). This electronic submittal provides conservative estimates of the offsite consequences of an accidental release of isopropylamine from Helena's facility located at 434 Fenn Road in Cordele, Georgia. The electronic RMP summarizes the policies and procedures implemented by the Helena-Cordele Facility to minimize the likelihood of an accident. The electronic RMP also summarizes the actions that the Helena-Cordele Facility has taken to ensure that a response to a release (even though a release is unlikely) will be implemented in a proper and timely manner. FACILITY Helena Chemical Company engages in the formulation, distribution, and sale of agricultural chemicals. The Cordele Facility operates two covered agricultural chemical formulation processes - the Arsenal Process and the Butoxone Process. Both processes use flammable substances that are listed in 40 CFR 68.130. The Arsenal Process uses isopropylamine (CAS No. 75-31-0) and the Butoxone Process uses a 60% solution of dimethylamine (CAS No. 124-40-3). OFF-SITE CONSEQUENCE ANALYSIS Worst case and alternative consequence analyses were completed for both the Arsenal and Butoxone processes. However, pursuant to 40 CFR Part 68.25(2)(ii), only the consequence analysis for the Arsenal Process has been submitted to the U.S. EPA because the Arsenal Process has the greatest distance to flammable endpoint. The worst-case scenario release for the Cordele facility assumes that a 100,000 lb quantity of isopropylamine is involved in a vapor cloud explosion resulting from a large warehouse fire. The worst-case scenario is overly conservative because it is very unlikely that Helena-Cordele would ever store this quantity of isopropylamine, and because the warehouse sprinkler system would extinquish a fire before it proceeded to the point where the isopropylamine drums e xploded. The estimated distance to the worst case flammable endpoint of 1 pound per square inch (psi) overpressure, calculated in accordance with U.S. EPA guidelines, is 0.34 miles. The alternative (or more likely to occur) scenario also assumes a vapor cloud explosion. However, the average daily quantity of isopropylamine (24,848 lb) and a 3% TNT yield factor is assumed instead of 100,000 lb and a 10% TNT yield factor. (According to EPA, a 3% yield factor is more representative of actual vapor cloud explosions than a 10% yield factor). The estimated distance to the flammable endpoint was estimated to be 0.14 miles and extends less than 328 feet east from the facility property boundary that runs along the railroad right-of-way. ACCIDENT PREVENTION PROGRAM The Helena-Cordele Facility complies with U.S. EPA's accidental release prevention rule and with all applicable state codes and regulations. The accident prevention actions undertaken by the Helena-Cordele Facility include the development of this RMP for the Arsenal process and compliance with a process safety managmenet plan (PSM) for the Butoxone Process. The Helena-Cordele Facility provides safety information relevant to the processes including MSDS documentation, storage and process limits, equipment specifications, and relevant codes and standards. The Helena-Cordele Facility has conducted a hazard review to ensure that potential safety problems are identified and addressed. The Helena-Cordele Facility has developed standard and consistent operating procedures that all of its employees follow when working with isopropylamine or dimethylamine. The Helena-Cordele Facility ensures that all of its employees working with or around either chemical participate in a training program. The training program teaches employees how to avoid and respond to accidents. Helena Chemical Company has also established integrated operation and maintenance procedures, inspection requirements and schedules, compliance audits, management of change, and incident investigation procedures. EMERGENCY RESPONSE PROGRAM The Cordele Facility will rely on emergency response capabilities from local emergency response agenices. Helena-Cordele will support agency efforts through coordination and implementation of proper notification and evacuation procedures as outlined in the Contingency Plan. If an accident occurs that could impact offsite areas, the Cordele Facility will immediately notify the plant emergency coordinator, plant and corporate health and safety personnel, the Crisp County Fire Department, and the Crisp County Sheriff's Department. FIVE YEAR ACCIDENT HISTORY The operation of the Arsenal and Butoxone Processes at the Cordele Facility in the past five years has not resulted in any on-site deaths, injuries, or significant property damage; or off-site deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place. CONCLUSION The Risk Management Plan Implement ed by Helena Chemical Company at the 434 Fenn Road Cordele Facility complies with the requirements of the Clean Air Act, Section 112(r). The RMP will be updated as the Cordele Facility adds, deletes, or changes processes. The Emergency Response Program has been coordinated with the Crisp County Fire Department. |