Inspec USA, Inc. - Executive Summary

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Introduction and General Information 
SITE INFORMATION 
Plant Site 
INSPEC USA, Inc. (INSPEC), a wholly owned subsidiary of Laporte Chemical Corporation, owns and operates a batch specialty chemical manufacturing facility near Galena, Kansas. The Inspec facility is located within the boundaries of a larger industrial complex, portions of which are owned by other corporations. The industrial area within which Inspec's property and manufacturing operations are located is known locally as the "Jayhawk Plant", dating back to its creation in the 1940's. That portion of the Jayhawk Plant Site containing INSPEC's property, buildings and equipment will be referred to hereinafter as the "Facility".  
The Facility is located on approximately 54 acres of a 2,200-acre industrial complex. INSPEC's Unit 1 encompasses approximately 29 acres and Unit 2 encompasses approximately 25 acres. The Facility is located approximately 3.5 miles northwest of the incorporated city of Galena, Kansas, lying 1.5 miles e 
ast of U.S. Highway 69 Alternate (69A), in Cherokee County, Kansas, and approximately 3.1 miles north of the junction of Kansas Route 66 and U.S. Highway 69A at Riverton, Kansas.  
The Jayhawk Site can be characterized as flat with a typical base elevation on the order between 830-852 feet above mean sea level (MSL). Mean elevation of INSPEC's property is approximately 850 feet. The facility is located at latitude 37o06'59.4" North and longitude 094o:40':27.6" West. The terrain in the local vicinity is flat to gently rolling land surface in a rural agricultural setting. The Spring River is located east and south of the facility. The land use immediately surrounding the facility is industrial with agricultural uses beyond the immediately adjoining land. Approximately 3.5 miles southeast of the facility is the town of Galena, KS., and approximately 22 miles to the north is the incorporated city of Pittsburg, KS. 
The facility stores five chemicals in excess of the threshold quantities list 
ed in the US EPA Accidental Release Protection Regulations in the Clean Air Act Section 112(r) (RMP). These chemicals are as follows: 
1.    Acetaldehyde    CAS #: 75-07-0 
2.    Ammonia (water solution) 24%    CAS #: 7664-41-7 
3.    Chlorine    CAS #: 7782-50-5 
4.    Isopropyl chloroformate    CAS #: 108-23-6 
5.    Methyl chloride    CAS #: 74-87-3 
According to the 1992 data for the Springfield Regional Airport in Springfield, MO, (nearest data source), the prevailing wind in the vicinity comes out of the southeast to south (approximately 120o to 180o). The average wind speed is 8.44 Knots (9.71 miles per hour). The stronger winds come out of 150 to 180o with velocities of as much as 17 to 21 Knots, and on limited occasions (<1%) the wind velocities exceed 21 Knots. The prevailing wind appears to be out of approximately 165o. Winds are calm approximately 2.58% of the time. This data is based on 24 hours a day, 365 days per year for the year 1992.  
In computing and modeling the worst case scenarios the atmospheric st 
ability class was set to "F" and the wind speed was set at 1.5 meters per second in accordance with the US EPA guidance. For the alternative scenarios, a wind speed of 1.5 meters per second and an atmospheric stability class of "D" or "F" was used in accordance with the US EPA guidance. This was necessary due to the lack of the most recent three-year meteorological data. 
WORST CASE AND ALTERNATIVE SCENARIOS 
Worst Case Scenarios 
Worst case scenarios were developed for each regulated chemical. The assumptions made included that the chemical was instantaneously released through catastrophic failure of the container, and if there were multiple containers of a single chemical within the same proximity, the release included the entire contents of all of the containers. 
For all worst case scenarios, the following assumptions were made: 
Wind Speed:     1.5 meters/second (3.4 miles/hour) 
Stability Class:     F 
Air Temperature:     77 degrees F (25 degrees C) 
Residential population, public receptors and  
environmental receptors were assessed for each chemical within the radius of its associated endpoint. In all cases there was residential population, no environmental receptors, and the only public receptor that appears in the available data is the Boston Mills School located one-half mile east. This school was investigated and no longer exists. Therefore, there are no public receptors within the maximum endpoint radius of the worst case scenarios. 
Acetaldehyde 
Inspec's facility includes a tank that contains 108,000 pounds of acetaldehyde when full. It is used as a primary raw material in the production of one of the finished products in Unit 1. Acetaldehyde stored in the quantity indicated requires that the system comply with RMP Program Level III regulations. According to US EPA's RMP*Comp. Version 1.06 (RMPComp), that quantity of acetaldehyde results in a 0.3-mile radius to the one pound per square inch (p.s.i.) overpressure endpoint. The following is the RMPComp modeling results for 
the worst case scenario for acetaldehyde: 
Category:     Flammable Gas 
Liquefied     Under pressure 
Quantity Released:     108,000 pounds 
Release Type:     Vapor Cloud Explosion 
Estimated Distance to 1 psi overpressure:     0.3 miles 
The off-site consequence analysis indicates that there are no environmental receptors within the 0.3-mile radius of the acetaldehyde tank (worst case). The demographic data indicates that there are approximately 11 residential persons located within the radius of the worst case scenario. 
Aqua Ammonia 24% 
Inspec's facility includes a tank that contains 69,000 pounds of 24% (+/-) aqua ammonia. It is used as a scrubber media for the removal of nitrogen oxides from Unit 1 production processes. Aqua ammonia stored in the quantity indicated requires that the system comply with RMP Program Level III regulations. According to RMPComp, that quantity of aqua ammonia results in a 0.7-mile radius to the 0.14 mg/L toxicity endpoint. The following is the RMPComp modeling results for t 
he worst case scenario for aqua ammonia: 
Category:    Toxic Liquid 
Quantity Released:    69,000 pounds 
Release Duration:    10 min 
Release Rate:    1,660 pounds per min 
Liquid Temperature:    90 F 
Mitigation Measures:     NONE 
Topography:    Urban surroundings (many obstacles in the immediate area) 
Toxic Endpoint:    0.14 mg/L; basis: ERPG-2 
Estimated Distance to Toxic Endpoint:    0.7 miles 
The off-site consequence analysis indicates that there are no environmental receptors within the 0.7-mile radius of the aqua ammonia tank (worst case). The demographic data indicates that there are approximately 58 residential persons located within the radius of the worst case scenario. 
Chlorine 
Inspec's facility includes cylinders that contain 2,000 pounds of chlorine each. A maximum of four full and four empty cylinders are stored in separate areas. The full cylinders are stored in two separate areas precluding the catastrophic release of more than 4,000 pounds. It is used as a primary raw material in the production of se 
veral finished products in Unit 2. Chlorine  stored in the quantity indicated (8,000 pounds) requires that the system comply with RMP Program Level III regulations. According to RMPComp, that quantity of chlorine results in a 1.9-mile radius to the 0.0087 mg/L toxicity endpoint. The following is the RMPComp modeling results for the worst case scenario for chlorine: 
Category:     Toxic Gas 
Quantity Released:     4,000 pounds 
Release Duration:     10 min 
Release Rate:     400 pounds per min 
Mitigation Measures:     NONE 
Topography:     Urban surroundings (many obstacles in the immediate area) 
Toxic Endpoint:     0.0087 mg/L; basis: ERPG-2 
Estimated Distance to Toxic Endpoint:     1.9 miles 
The off-site consequence analysis indicates that there are no environmental receptors within the 1.9-mile radius of the chlorine cylinders (worst case). The demographic data indicates that there are approximately 497 persons located within the radius of the worst case scenario. 
Isopropyl Chloroformate 
Inspec's facility includ 
es refrigerated storage area that contains 55 gallon drums containing a total of 41,800 pounds of isopropyl chloroformate. It is used as a reactant in the production of one of the finished products in Unit 2. This chemical is normally used on-site for a single campaign to produce a specific product. It is normally not on-site more than 90 days per year. Isopropyl chloroformate stored in the quantity indicated requires that the system comply with RMP Program Level III regulations. According to RMPComp, that quantity of isopropyl chloroformate results in a 0.6-mile radius to the 0.10 mg/L toxicity endpoint. The following is the RMPComp modeling results for the worst case scenario for isopropyl chloroformate: 
Category:    Toxic Liquid 
Quantity Released:    41,800 pounds 
Liquid Temperature:    (Refrigerated Storage Area) 40 F 
Mitigation Measures:    Release into building with floor area of 50,000 square feet 
Release Rate to Outside Air:    21.1 pounds per minute 
Evaporation Time:    1,980 minutes 
Topography 
:    Urban surroundings (many obstacles in the immediate area) 
Toxic Endpoint:    0.10 mg/L; basis: EHS-LOC; LOC is based on IDLH-equivalent 
level estimated from toxicity data. 
Estimated Distance to Toxic Endpoint:    0.6 miles 
The off-site consequence analysis indicates that there are no environmental receptors within the 0.6-mile radius of the isopropyl chlorofarmate storage warehouse (worst case). The demographic data indicates that there are approximately 42 persons located within the radius of the worst case scenario. 
Methyl Chloride 
Inspec's facility includes a methyl chloride tank that contains 87,000 pounds of methyl chloride. Methyl chloride in that quantity requires that the system comply with RMP Program Level III regulations. According to RMPComp, that quantity of methyl chloride results in a 1.7-mile radius to the 0.82 mg/L toxicity endpoint. The following is the RMPComp modeling results for the worst case scenario for methyl chloride: 
Category:     Toxic Gas 
Liquefied     Under pressure 
 
Quantity Released:     87,000 pounds 
Release Duration:     10 min 
Release Rate:     8,700 pounds per min 
Mitigation Measures:     NONE 
Topography:     Urban surroundings (many obstacles in the immediate area) 
Toxic Endpoint:     0.82 mg/L; basis: ERPG-2 
Estimated Distance to Toxic Endpoint:     1.7 miles (3.2 kilometers) 
The off-site consequence analysis indicates that there are no environmental receptors within the 1.7-mile radius of the methyl chloride tank (worst case). The demographic data indicates that there are approximately 398 persons located within the radius of the worst case scenario. 
Alternate Scenarios 
The catastrophic failure of the containers, or simultaneous failure of all containers for a chemical, is highly unlikely. The tanks and cylinders have safety devices and systems to prevent or minimize the effect of any accidental release. An alternative scenario has been selected for each chemical that, although still very unlikely to occur, has a higher probability of occurrence than the wors 
t case scenario, in accordance with U.S. EPA guidance. 
For all alternative scenarios, the following assumptions were made: 
Wind Speed:    3 meters/second (6.7 miles/hour) 
Stability Class:    D 
Air Temperature:    77 degrees F (25 degrees C) 
Residential population, public receptors and environmental receptors were assessed for each chemical within the radius of its associated endpoint. In most there was residential population, no environmental receptors, and the only public receptor that appears in the available data is the Boston Mills School located one-half mile east. This school was investigated and no longer exists. Therefore, there are no public receptors within the maximum endpoint radius of the alternative case scenarios. 
Acetaldehyde 
A more likely scenario for acetaldehyde is the failure of the railcar unloading system. The chemical is transferred to the tank using nitrogen pressure and a closed loop system, and should a hose fail, the entire contents of the tank might escape. The alter 
native scenario for acetaldehyde is the failure of a 2-inch unloading line releasing all of the contents of a tank. Since the tank contains 108,000 pounds when full, the alternative scenario involves the release of 108,000 pounds of acetaldehyde through a 2-inch hose. The following is the RMPComp modeling results for the alternative scenario: 
Category:    Flammable Gas 
Liquefied     Under pressure 
Release Duration:     19.7 minutes 
Release Type:     Vapor Cloud Explosion 
Storage Parameters:     Release from Pipe 
Hole or puncture area:     6.5 square inches 
Release Rate:     5480 pounds per min 
Mitigation Measures:     NONE 
Estimated Distance to 1 psi overpressure:    0.1 miles 
The off-site consequence analysis indicates that there are no environmental receptors within the 0.07-mile radius of the acetaldehyde tank (alternative case). The demographic data indicates that there are approximately 1 persons located within the radius of the alternative case scenario. 
Aqua Ammonia 24% 
A more likely scenario for aqua amm 
onia is a failure during a tank trailer unloading. The chemical is transferred to the tank using air pressure, and should a hose fail, the entire contents of the tank trailer could escape. The alternative scenario for aqua ammonia is the failure of a 2-inch unloading line releasing all of the contents of a tank trailer. The volume of a single tank trailer is approximately 40,000 pounds. Therefore, the alternative scenario involves the release of 40,000 pounds of 24% aqua ammonia through a 2-inch hose. The following is the RMPComp modeling results for the alternative scenario: 
Category:     Toxic Liquid 
Quantity Released:     40000 pounds 
Release Duration:     10 min 
Release Rate:     960 pounds per minute 
Liquid Temperature:     90 F 
Mitigation Measures:     NONE 
Topography:     Urban surroundings (many obstacles in the immediate area) 
Toxic Endpoint:     0.14 mg/L; basis: ERPG-2 
Estimated Distance to Toxic Endpoint:     0.3 miles 
The off-site consequence analysis indicates that there are no environmental recept 
ors within the 0.3-mile radius of the aqua ammonia tank (alternative case). The demographic data indicates that there are approximately 11 persons located within the radius of the alternative case scenario. 
Chlorine 
A more likely scenario for chlorine is the failures of a single cylinder during handling. Therefore, the alternative scenario involves the release of 2,000 pounds of chlorine through a 2-inch rupture in a cylinder. The following is the RMPComp modeling results for the alternative scenario: 
Category:     Toxic Gas 
Release Duration:     10 minutes 
Storage Parameters:     Hole or puncture area: 6.5 square inches 
Tank Pressure:     50 psi 
Tank Temp:     90 F 
Release Rate:     539 pounds per min 
Mitigation Measures:     NONE 
Topography:     Urban surroundings (many obstacles in the immediate area) 
Toxic Endpoint:     0.0087 mg/L; basis: ERPG-2 
Estimated Distance to Toxic Endpoint:     0.4 miles 
The off-site consequence analysis indicates that there are no environmental receptors within the 0.4-mile radius of 
the chlorine cylinders (alternative case). The demographic data indicates that there are approximately 19 persons located within the radius of the alternative case scenario. 
Isopropyl Chloroformate 
A more likely scenario for isopropyl chloroformate is the failure of tank R-10 during process operations. In preparing to operate the batch process, approximately 5,225 pounds of isopropyl chloroformate is charged to tank R-10. Should that reactor fail the contents could be released inside the building. Therefore, the alternative scenario involves the release of 5,225 pounds of isopropyl chloroformate through a 2-inch rupture in pipe going to the reactor. The following is the RMPComp modeling results for the alternative scenario: 
Category:     Toxic Liquid 
Quantity Released:     5,225 pounds 
Release Duration:     1.5 minutes 
Storage Parameters:     Tank under Atmospheric Pressure 
Hole or puncture area:     6.5 square inches 
Release Rate:     3,700 pounds per min 
Liquid Temperature:     90 F 
Mitigation Measures: 
    Release into building with floor area of 50,000 square feet 
Release Rate to Outside Air:    50.9 pounds per minute 
Evaporation Time:    109 min 
Topography:     Urban surroundings (many obstacles in the immediate area) 
Toxic Endpoint:     0.10 mg/L; basis: EHS-LOC; LOC is based on IDLH-equivalent 
level estimated from toxicity data. 
Estimated Distance to Toxic Endpoint:     0.2 miles 
The off-site consequence analysis indicates that there are no environmental receptors within the 0.2-mile radius of the isopropyl chloroformate tank (alternative case). The demographic data indicates that there are approximately 5 persons located within the radius of the alternative case scenario. 
Methyl Chloride 
A more likely scenario for methyl chloride is the failures of the railcar during unloading system. The chemical is transferred to the tank using nitrogen pressure, and should a hose fail, the contents of the tank could escape. The alternative scenario for methyl chloride is the failure of a 2-inch unloading line 
releasing all of the contents of the tank. The tank contain 87,000 pounds of methyl chloride when full . The alternative scenario involves the release of 87,000 pounds of methyl chloride through a 2-inch hose. The following is the RMPComp modeling results for the alternative scenario: 
Category:     Toxic Gas 
Liquefied     Under pressure 
Release Duration:    13.6 minutes 
Storage Parameters:    Release from Pipe  
Hole or puncture area:    6.5 square inches 
Release Rate:    6,400 pounds per min 
Mitigation Measures:     NONE 
Topography:     Urban surroundings (many obstacles in the immediate area) 
Toxic Endpoint:    0.82 mg/L; basis: ERPG-2 
Estimated Distance to Toxic Endpoint:    0.9 miles 
The off-site consequence analysis indicates that there are no environmental receptors within the 0.9-mile radius of the methyl chloride tank (alternative case). The demographic data indicates that there are approximately 96 persons located within the radius of the alternative case scenario. 
Emergency Assistance 
Emergency assistance 
is provided by the Galena, KS Fire Department with mutual aid assistance agreements with Columbus, and Baxter Springs, KS Fire Departments. Columbus is located approximately 10 miles northwest of the facility, and Baxter Springs is located approximately 10 miles southwest of the facility. There is a Local Emergency Planning Commission (LEPC) for Cherokee County, KS. Mutual aid response times are approximately 30 minutes from the initiation of the notice. Inspec has trained its personnel in emergency response and emergency operations. Each supervisor is trained to provide the immediate response to an emergency with the personnel assigned to work in the area. There is an Inspec staffed fire brigade which has training only in minor fire response using fire extinguishers. Additional support is provided through coordination of the emergency with outside agencies through use of the plant telephone and emergency notification system. 
Accident History 
Inspec operates a modern facility with sta 
te of the art safety policies, practices and systems. There have been no off-site consequences involving regulated processes, or regulated chemicals, at the facility. There is no five-year accident history involving either regulated processes or chemicals that involve personnel injury, death or significant property damage. 
Process Safety Information 
Inspec maintains all of the safety information required by RMP. This includes Material Safety Data Sheets (MSDS), maximum intended inventories of regulated chemicals, safe upper and lower temperatures, pressures and flows, and equipment specifications and manufacturing codes. The facility has been designed by industry-accepted standards and good engineering practices. Updates to the safety information are made through the management of change procedures.  
Process Hazard Analyses 
Inspec performs process hazard analyses on covered systems and has a program to address any deficiencies noted during the review. These reviews are performed by fac 
ility personnel that are thoroughly familiar with the processes, using generally accepted procedures. Reviews are repeated at least every five years.  
Operating Procedures 
All operations at the facility are conducted using standard operating procedures by operations personnel that are thoroughly trained on system normal and emergency operations. The operating procedures cover steps for each operation, initial startup, normal operations, temporary operations, emergency shutdown, emergency operations and startup after turn-around or emergency shutdown. 
Training 
Inspec provides all personnel with the appropriate training. This includes initial and annual refresher training for all facility personnel. 
Mechanical Integrity 
Maintenance is assured by a computerized Work Order System for preventative and corrective maintenance. All maintenance personnel are trained to perform the various functions required at the facility. Process equipment is inspected in accordance with generally accepted go 
od engineering practice consistent with the industry standards. 
Management of Change 
The facility has a management of change policy that requires a review of all proposed changes except for replacement in kind. Management of change requires that those employees affected by the change be informed of, and receive training on, the change prior to its startup. 
Pre-Startup Review 
The facility performs pre-startup reviews and provides employees training in the new or modified process prior to its startup. 
Compliance Audits 
The facility has a policy requiring an audit by a person familiar with the processes at least every three years. There is also a policy to address the audit findings on a timely basis. 
Incident Investigations 
The facility has an incident investigation policy. All investigations are documented and reviewed to determine the appropriate preventative measures. These investigations occur within forty-eight hours of the incident and involve an incident investigation team that co 
nsists of representatives of the facility operations staff, management and any contractors that might be involved in the incident. Any recommendations made by the investigation team are acted upon by the facility as soon as possible. All incident investigation reports are maintained for at least five years. 
Employee Participation 
The facility has a written Employee Participation Plan, and employees are customarily consulted on all changes and the development of process hazard analyses. 
Hot Work Permits 
The facility has a Work Permit Policy that includes a hot work permitting procedure. This policy complies with the requirements of the RMP. 
Contractors 
The facility has a Contractor Safety Policy. This policy complies with all of the requirements of the RMP. 
Emergency Response 
The facility has an Emergency Response Plan intended to protect human health and the environment. There is a procedure for the notification of local emergency response agencies and the public. Training is provided  
to all employees on the Emergency Response Plan and the emergency equipment available at the facility. This Emergency Response Plan is updated as often as necessary, but not less than once every three years. 
Conclusions 
Inspec operates a modern, well-managed facility with ample maintenance, training and emergency planning to minimize the possibility of adverse effects on human health and the environment. Should an accident occur, the Facility is fully capable of responding in a manner that will minimize the possibilities of off-site consequences. Management is committed to proper and safe operations and has the full support and cooperation of the operation and maintenance staffs.
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