Polypure Inc. - Los Angeles - Executive Summary |
|
EXECUTIVE SUMMARY This Risk Management Plan (RMP) has been prepared to meet the requirements of the Risk Management Program Rule. As part of complying with the Risk Management Program Rule, the Polypure Inc. facility in Los Angeles, California (Polypure) has reviewed and enhanced previously existing accidental release procedures and emergency response policies. These policies include developing and implementing a formal Emergency Action Plan that includes the following: Emergency Phone Numbers Incident Notification Policy Los Angeles County Fire Department Plant Emergency Alarm Recognition, Initiation, Evacuation, and Assembly Plant Emergency Plan Responsibilities Emergency Procedures - General Fire Incident Earthquake Flooding Bomb Threat Off-site Leaks and Spills (T ransportation Incidents) Emergency Procedures - Chemical Spills/Releases (General Information) Section I - Chemical Spills/Releases (Other than Acutely Hazardous Materials) Section II - Chemical Spills/Releases (Acutely Hazardous Materials) Emergency Procedures - Employee Training Employee Safety Training (General Overview) New Employee Training Basic Operator Training and Continuous Training Emergency Drills Training Records Plant Inventories and Equipment Information Site Map Hazardous Material Plot Plan and Tank Designations Emergency Safety Equipment List Chemical Inventory There are two substances at the Polypure facility that are regulated by the Chemical Accident Prevention Provisions defined at 40 CFR Part 68. These substances are used in various processes throughout the facility to produce water treatment polym ers. Substances that are used by Polypure that are regulated as either toxic substances or flammable substances by 40 CFR Part 68 are as follows: Toxic Substances: Formaldehyde: Formaldehyde is received and stored as a 37 percent solution in water. The maximum amount of 37 percent formaldehyde stored on-site is 66,000 pounds (24,000 pounds pure formaldehyde). Flammable Substances: Dimethylamine: The maximum amount dimethylamine stored on-site is approximately 70,000 pounds. Worst-case Scenarios: As required by the Risk Management Program Rule, worst case and alternative release scenarios were evaluated and are discussed in this RMP. As required, worst case scenarios are presented in the RMP for one toxic substance and one flammable substance. Alternative scenarios were prepared for each of the toxic substances with worst case endpoints located offsite and for one flammable substance. The endpoint represents the distance at which a released substance must travel before it disperses sufficiently to no longer pose a hazard to the public. For the worst case scenario, EPA has defined a worst-case release as the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to a specified endpoint. For the worst-case analysis, the possible causes of the worst-case release or the probability that such a release might occur are not considered. The release is simply assumed to take place and the greatest amount held in a vessel is suddenly released. The results of the worst case scenario analysis were as follows: Toxic Substances: The formaldehyde storage tank was assumed to fail and subsequently produce an instantaneous release of the entire tank contents. The release was assumed to evaporate over a 10-minute time period. The passive mitigation control of the tank dike were considered in limiting the release impacts. The distance to th e toxic endpoint was estimated to be less than 0.19 miles. Flammable Substances: The dimethylamine storage tank was assumed to fail and subsequently produce an instantaneous release of the entire tank contents that results in a vapor cloud explosion. No passive mitigation controls were considered in limiting the release impacts. The distance to the explosion endpoint was estimated to be less than 0.31 miles. Alternative Release Scenarios: Alternative release scenarios are more realistic scenarios that result in endpoints that affect public receptors. For formaldehyde the release was assumed to occur as a result of the uncoupling or rupture of a transfer hose during unloading operations into a contained area. For flammable materials, the alternative release scenario assumed that dimethylamine was released as a result of the uncoupling or rupture of a hose during unloading operations. The durations for releasing these materials from a vessel/pipe for th e alternative release scenarios were assumed to occur over a 3-minute time period for formaldehyde and a 5- minute period for dimethylamine since the unloading operations are supervised. With the exception of considering that these transfer operations are monitored by personnel at all times, no other active mitigating controls were assumed to limit the releases. The results of the alternative release scenario analysis were as follows: Toxic Substances: Formaldehyde, 37 percent - 0.06 miles Flammable Substance: Dimethylamine - 0.06 miles Prevention Program: To address potential accidental releases, an accidental release prevention program along with chemical specific prevention steps have been developed. The key parts to the program are: Formal Company Risk Management Procedure that includes: Management System Responsibilities Risk Management Plan Coordinating Review Team Risk Management Plan Changes and Updating Recordkeeping Requirements Communication and Coordination of Risk Management Information DOT Hazardous Material Training Contractor Performance Selection Process Operating Procedures Emergency Procedures New Employee Environmental Health and Safety Orientation Training Program Process Safety Program Auditing Engineering Controls that Include Automatic Level and Interlock Alarms and Shutdowns 24-hour Emergency Communications Additionally, the facility has programs to address the OSHA Process Safety Management (PSM) requirements for the chemicals formaldehyde and dimethylamine such as: Employee Participation Process Safety Information Process Hazard Analysis Operating Procedures Training Contractor Safety Pre-startup Safety Reviews Mechanical Integrity Hot Work Permit Management of Change Incident Investigation Emerge ncy Planning and Response Compliance Audits Emergency Response Program: The facility also has an emergency response program (ERP) that has been enhanced as part of implementing the Risk Management Program. The ERP has historically been coordinated with the Los Angeles County Fire Department, Hazardous Materials Division. As part of the community involvement efforts, the facility's management participates in the local CAER group efforts. As part of preparing the RMP, the facility's five year accident history was reviewed. No accidental releases from covered processes have occurred that resulted in deaths, injuries, or significant property damage on-site or off-site; or resulted in off-site evacuations or sheltering in place. Safety Improvement: Polypure is committed to continuous improvement of safety. Planned changes and policies to promote this improvement include the continuous review and update of the plant safety program and annual emergency drills to determine and improve upon deficiencies. Efforts to update and implement additional safe work practices and policies are ongoing and include areas such as: Hazard Communication Confined Space Entry Line Breaking Procedures Lock-out Tag-out |