AMVAC Chemical Corporation - Executive Summary

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This Risk Management Plan (RMP) has been prepared for AMVAC's pesticide manufacturing plant located at 4100 East Washington Boulevard in Los Angeles, California.  It has been prepared in accordance with section 112(r) of the Clean Air Act Standard (40 CFR Part 68), RMP.  The intent of this legislation is to protect the public health and safety and the environment from the accidental release of acutely hazardous materials (AHMs).  The preparation and implementation of this RMP by AMVAC Chemical Corporation, a handler of acutely hazardous materials, meets the intent of the RMP rule and relevant portions of the California Health and Safety Code. 
 
The Hazard and Operability Study (HazOps) and hazard analysis conducted for AMVAC's AHM handling units found these units to contain multi-layers of safeguards against the possibility of acutely hazardous material release, and concluded that these units are well designed. 
 
1.0 Accidental Release Prevention and Emergency Response Policies 
 
Mission  
Statement: AMVAC Chemical Corporation (AMVAC) is committed to the following: 
1.Providing its customers with environmentally friendly, cost-effective and high-quality products on time. 
2.Providing a safe and secure working environment for its employees. 
3. Operating in a manner which meets or exceeds existing laws and regulations and reflects the high level of concern and respect for the local community. 
4. Investing in its future through aggressive research and development of new products and markets. 
5. Providing its investors with higher than normal returns. 
 
Safety First Policy: Amvac will provide a safe and secure environment for its employees while maintaining a high level of concern and respect for the community.  Safe conditions and full environmental regulatory compliance will be maintained at all of its facilities. All unsafe conditions/actions will be immediately corrected and management notified. 
 
Environmental, Health and Safety Mission Statement: AMVAC Chemical Corporation 
's Environmental, Health and Safety (EH&S) departments are committed to ensuring that facility operations are conducted in full compliance with existing environmental, health and safety regulations.  To achieve this, we follow a four-point plan based on Training, Auditing, Reporting and Enforcement. 
 
2.0 Facility Description and Regulated Substances Handled 
 
AMVAC Chemical Corporation manufactures agricultural pesticides at its plant located at 4100 East Washington Boulevard in Los Angeles, California.  The facility consists of various type buildings, chemical reactors, aboveground storage tanks, truck loading/unloading stations, railcar loading/unloading stations, peripheral tanks, a warehouse and various ancillary equipment.  The plant typically employs one hundred and fifteen full-time employees and operates on a three shift, twenty four-hour basis. 
AMVAC Chemical Corporation has a North American Industrial Classification System (NAICS) Code of 32532 for Pesticides and Agricultural  
Chemicals Manufacturers.  The plant manufactures pesticides which require the handling of Acutely Hazardous Materials (AHMs) in quantities which make them subject to the Risk Management Plan Rule (RMPR) requirements of the Clean Air Act (40 CFR 68).   
 
* Toxic Substances: 
1. Chlorine, CAS 7782-50-5 used in the PCNB manufacturing process. 
2. Bromine, CAS 7726-95-6 used in the Naled manufacturing process. 
3. Carbon Disulfide, CAS 75-15-0 used in the Metam Sodium/DTC manufacturing process. 
* Flammable Substances:  
1. Dimethylamine, CAS 124-40-3 used in the DTC manufacturing process. 
2. Monomethylamine, CAS 74-89-5 used in the Metam Sodium manufacturing process 
 
PCNB Manufacturing Process: 
 
The AHM associated with the PCNB process is chlorine.  Chlorine is received at AMVAC's facility as a liquid, which is stored and vaporized in a containment building and used as a gas in the PCNB process. 
 
Naled Manufacturing Process: 
 
The AHM associated with the Naled process is Bromine.  Bromine is rec 
eived at AMVAC's facility as a liquid and used as liquid.  The production of Naled is accomplished via reaction in a batch reactor with Bromine injected under controlled conditions. 
 
Metam Sodium/DTC Manufacturing Process: 
 
AHMs associated with this process are methylamine (for Metam Sodium manufacturing), dimethylamine (for DTC manufacturing) and carbon disulfide (for both processes).  There are no by-products or off-gases produced in these reactions. 
 
3.0 The Worst-Case Release Scenario(s) and the Alternative Release Scenario(s): 
 
Several release scenarios for each of the acutely hazardous materials of concern, Chlorine (CL2), liquid Bromine (BR2), Carbon Disulfide (CS2), Methylamine (MMA) and Dimethylamine (DMA)were considered.  Releases of any of these materials would normally require failure of at least three levels of safety devices.  For the purpose of conducting Offsite Consequence Analysis, absolute worst case and alternative release scenarios were selected.  Worst case scenar 
ios are mandated by the RMP rule.  For the regulated chemicals used at AMVAC, these scenarios do not consider the real physical limitations of nature, hence produce a severity of results in excess of that which would actually occur.  The criteria used to choose alternative release scenarios is an attempt to more closely define a serious release episode that could conceivably occur, but is still more substantially severe than any documented release episode or "near miss" in Amvac's history of handling those materials.  These scenarios include the following: 
 
Worst Case Scenario for Covered Toxic Substances: 
 
Based on the evaluation and analysis of worst case scenarios for each of the covered toxic substances, chlorine presented the largest distance to end point(s).  The worst case scenario for covered toxic substances at AMVAC results from an instantanuous and complete rupture of the 55 ton (110,000 lb.) chlorine railcar housed in a concrete containment building.  The concrete building  
limits the release rate to 55% of an unmitigated release.  The event would have offsite consequences.  An event of this nature has never occured in the history of chlorine handling and would be very unlikely.  
 
Worst Case Scenario for Covered Flammable Liquids: 
 
Based on the evaluation and analysis of worst case scenarios for each of the covered flammable liquids, Dimethylamine (DMA) presented the largest distance to end point(s).  The worst case scenario for covered flammable substances results from failure of a storage tank containing an aqueous solution of  DMA resulting in a vapor cloud explosion.  The event would have offsite consequences.  This event assumes total liquid vaporization in a very short time and does not address the natural physical limitations associated with that assumption.  An actual DMA spill would be into a concrete dike area, which would significantly reduce the impact of the release. 
 
Alternative Release Scenarios for each covered Toxic Substance: 
 
Chlorine: 
 
A flange gasket on the top of one of the reactors where chlorine vapor is introduced fails.  The chlorine vapor leaks through an area between the flange bolts.  The vapor jet release continues for 30 minutes before it is stopped.  The release assumes the most dispersive point of release and long discovery time, even though detection  and response would almost be immediate and prevention/mitigation measures are in place.  Such scenario would be unlikely to occur. 
 
Bromine: 
During metering of Bromine into the bromination reactor, an upper level seismic event causes reactor to move substantially and break piping connections.  A quantity of Bromine is pumped into the area around the reactor and released out of the building to the atmosphere.  The evaporating pool release continues for 60 minutes before it is stopped.  This release scenario assumes a slow discovery time and very long response time, which would not be the case since detection and response would almost be immediate and preven 
tion/mitigation measures are in place.  Such scenario would be unlikely to occur. 
 
Carbon Disulfide: 
During reactor charging, a leak of liquid CS2 occurs on the discharge side of the transfer pump.  About 1.1 gallons per minute of CS2 is discharged to the surface between the pump and the Metam Sodium/DTC plant.  It takes the operator 5 minutes to respond to the leak and as much as 8 minutes to contain the leak and stop volatilization by covering the pooled CS2 with water.  This scenario is very conservative since it assumes long discovery time and very long response time, which would not be the case since response would almost be immediate and prevention/mitigation measures are in place.  Such scenario would be unlikely to occur. 
 
Alternative Release Scenario for Covered Flammable Substances: 
 
Storage tank is filled with aqueous MMA and under nitrogen padding when a leak develops in the pipe on the bottom outlet of the tank.  The MMA solution leaks out for 10 minutes into a concrete co 
ntainment dike before the leak is isolated and flow stopped.  MMA evaporates from the pool and forms a vapor cloud, which catches fire.  
 
After these releases were selected, a hazard scenario was developed for each, a mass release rate was calculated and appropriate Levels of Concern (LOC) were identified.  These LOCs are concentrations of the chemicals giving known health effects.  They are set by the American Industrial Hygiene Association (AIHA) Emergency Response Planning Guidelines (ERPG).  It was determined that the risks presented by each of the three alternative  releases examined in the Offsite Consequence Analysis is low.  The combination of low event probability and minimal offsite consequenses for these extreme event scenarios is considered to be an acceptable risk at this time. 
 
4.0 The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
 
The plant is equipped with an emergency power generator and back up air supply in the event of power or 
air failure. 
In addition to the capabilities, design features and back up of the systems handling the regulated chemicals, AMVAC recognizes that the safe operation of the plant requires a thorough understanding of the physical and chemical properties of all materials and the implementation of safe handling practices. 
 
Impact of Year 2000 (Y2K) on the facility: 
Electronic process control equipment and process-related equipment in place at AMVAC have been identified as falling in to one of the following categories 
1.Y2K compliant by design 
2.Y2K compliant through "time unawareness" 
3.Y2K non-compliant, but upgradable through software 
4.Y2K non-compliant 
Equipment in categories 1 & 2 are safe from the Y2K problem.  Steps are in progress to upgrade category 3 equipment.  Category 4 equipment has been identified and tested to define its deficiencies.  Category 4 equipment will be replaced or operated with procedures that overcome the deficiencies. 
AMVAC does not believe that its processes  
and safety thereof will be affected by the Year 2000 issue in any material respect.  Possible disruptions in services from providers should not lead to an accidental release of any kind. 
 
5.0 The Five Year Accident History 
 
Two accidents/incidents involving Acutely Hazardous Materials have occurred within the past five years; one involved a chlorine release of less than one pound and the other involved a release of methylamine of less than 80 pounds.  Neither of the incidents resulted in significant onsite or offsite injuries or consequences.  Corrective measures and procedures have since been implemented to further reduce the risk of releases. 
 
6.0 The Emergency Response Program 
 
All units are equipped with multiple levels of protection.  The potential for spills or releases  is low.  However, in the event that a spill or release occurs, there are established written procedures for the handling of emergencies. 
 
These include the Emergency Response Plan and the Operating Procedures Man 
uals.  The Emergency Response plan for the AMVAC facility (last revised 2/5/1999) includes written procedures for handling releases and spills of hazardous materials in any area and contains more specific emergency response procedures, including procedures for earthquake, bomb threat, riot, offsite emergencies, evacuation procedures, evacuation routes, fire prevention, emergency equipment, portable radio use and neighborhood information.  The operating procedure manual for each process contain more specific emergency responce information for each area. 
 
To maintain and upgrade our emergency response capability, AMVAC conducts regularly scheduled inspections of this facility and equipment, and conducts emergency response drills for personnel.  The Emergency Response Plan is reviewed annually and/or when: 
 
A. There is a major change in the facility operation that changes the potential for fires, explosions, release of hazardous substances, such that changes in the response are necessary  
for any emergency. 
B. The plan fails in an emergency. 
C. There is a change of emergency coordinators/responders. 
D. There is a change of emergency equipment. 
 
Any incident or emergency, which results in a chemical release  is reported to the following or corresponding agencies, as applicable: 
 
Los Angeles County Fire Department, Los Angeles Fire Prevention-Conservation Bureau, Department of Toxic Substance Control (DTSC), National Response Center, South Coast Air Quality Management District (SCAQMD), Cal-OSHA, Los AngelesCounty Sanitation District, California Office of Emergency Services, U.S. Environmental Protection Agency (EPA), U.S. Department of Fish and Game, Los Angeles County Department of Public Works (Environmental Programs and Flood Maintenance), and State Warning Center for Release Reporting.  Any serious work-related injury, illness or death is reported to the Cal-OSHA office immediately, but no longer than 8 hours after employer's knowledge of incident.  All incidents wil 
l be reviewed and investigated as to its cause and methods for future prevention. 
 
All plant personnel receive training on the implementation of the emergency response plan upon hire and periodic refresher training on the various aspects of the plan. 
 
Copies of the Emergency Response plan have been submitted to the local Fire Department, City of Commerce Emergency Preparedness Officer, Los Angeles County Sheriff's Department and the nearby hospitals. These agencies are therefore informed of and in agreement with the content and approach of the plan. 
 
7. Planned Changes to Improve Safety 
 
AMVAC currently has no additional detailed or defined plans for any changes such as installation of additional mitigation or control equipment, technology, organizational changes, etc.  However, there is an on going program that identifies such improvement opportunities as part of the safety committee, which formally addresses any and all employyee safety related issues and suggestions.  AMVAC will con 
tinue to improve the safety performance accordingly.
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