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HomeMy WebLinkAboutPWPB-RMP-2005PACIFIC WOOD PRESERVING OF NA w9m, M--OK ova RISK MANAGEMENT AND PREVENTION PROGRAM (RMP) Original Submitted January, 1990 Updated Version February, 2001 Updated Version June 2004 Updated Version March 2005 PWPB /RMP /2005 TABLE OF CONTENTS CERTIFICATION NOTICE FACILITY DESCRIPTION ACCIDENT HISTORY SAFETY SYSTEMS RECORDKEEPING PROCEDURES INTEGRATED CONTINGENCY PLAN* HAZOP, DESCRIPTION AND RESULTS OF THE HAZARD AND OPERABILITY STUDY OFFSITE CONSEQUENCE ANALYSIS IMPLEMENTATION OF THE RMP Personnel Training and Auditing /inspection Programs are located under the current Integrated Contingency Plan PWPB /RMP /2005 RECORD OF REVISIONS PWPB/RMP/2005 Change Number Date of Change Description of Change Signature 1 001 1997 Creosote Process Discontinued 2. 002 1999 Start up of Preserve@ Process 3. 003 June 2004 RMP Update to meet 5 Year Update Requirement 4. 004 March 2005 Change of personnel, Harold Brown replaced by Casey Ziemer 5. 6. PWPB/RMP/2005 CERTIFICATION NOTICE Based on the criteria in Section 2735.4 of Title 19 of CCR, the distance to the specified endpoint for the worst-case accidental release scenario for the following process is less than the distance to the nearest public receptor: CCA wood preservation process. Within the past five years, the process has had no accidental release that caused offsite impacts provided in the risk management program Section 2735.4 (c)(1). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process, entry within the distance to the specified endpoints may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RIVIP. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete. Signature Title Dam; / -G , t M, . C" Printed Name Emergency Contacts: Rick McCullough, Plant Manager — Primary Contact rick.mccullough(c)pacificwood.com Casey Ziemer, Asst. Plant Manager — Secondary Contact casey.ziemerCcb-pacificwood.com Pacific Wood Preserving of Bakersfield 5601 District Blvd. Bakersfield, CA 93313 (661) 833-0429 Plan Reviewed and Updated March 2005 by Rick McCullough and Roland Mueller of the Pacific Wood Preserving Companies. PWPB/RMP/2005 FACILITY DESCRIPTION The RMP should include a report specifying the nature, age and condition of the equipment used to handle acutely hazardous materials at the business or facility and any schedules for testing and maintenance. The only product that is required under the RMP program is CCA, but a description of all processes has been included in this section. A. GENERAL DESCRIPTION OF FACILITY The CCA plant, the first treating facility to be built at this location, was completed as a new facility in 1979. In 1985, the creosote plant was constructed to provide a second means of treating wood. Both plants were designed and constructed according to the applicable laws, ordinances, regulations and standards in effect at the time. In 1997 the creosote process was shut down and two new processes were added. Both the Borates and Dricon® Fire Retardant processes were operated in the former creosote plant. In 1999 the Preserve® wood preservation process was installed and is operating in the same retort with the Borates and Dricon® processes. In 2001 the Borates were moved and began operating in the same retort as the CCA. B. DESCRIPTION OF PROCESSES AND EQUIPMENT CCA Process The CCA product is delivered as a 60% concentrate solution, the remaining 40% is water. A 6,000 gallon fiberglass tank is designated as the storage container for the CCA concentrate. Normal delivery is approximately 3,000 to 3,400 gallons. The CCA concentrate is re- ordered when the storage tank contains approximately 600 gallons. A working solution of approximately 2% CCA is produced by adding concentrate and water in one of the two work tanks through an electronically controlled, pneumatically actuated mixing station. Once the mixing is complete, the work tank is tested to determine if the concentration meets specifications. A charge of wood is then loaded into the retort cylinder via railroad type trams. The wood is initially subjected to a vacuum in the cylinder. Once the vacuum process is complete, the working solution is pumped into the cylinder. Once the cylinder is completely filled with liquid, the hydraulic pressure in the cylinder is increased by a liquid pump to force the CCA fluid into the wood. After the pressure cycle is complete, the working solution is removed from the cylinder and placed back into the work tank. Another vacuum is then applied to the wood to assist in liquid removal from the cylinder and decrease drippage on the pad. The working solution is then checked to determine the concentration and water and /or CCA concentrate is added to replenish the solution for its next use. Dricon® Process The Dricon® product is delivered as a dry product in 2,000 pound super sacks. The Dricon® product is lifted and open into a tank which contains heated water (120F to 140F) and 2 -5 gallons of Hydrogen Peroxide 50 %. Once mixed and cooled, this concentrated solution is diluted again with water to produce a working solution. A working solution is produced by adding the concentrate solution and water into one of the work tanks. Once the mixing is complete, the work tank is tested to determine if the concentration meets specifications. A charge of wood is then loaded into the retort cylinder via railroad type trams. The wood is initially subjected to a vacuum in the cylinder. Once the vacuum process is complete, the working solution is pumped into the cylinder. Once the cylinder is completely filled with liquid, the hydraulic pressure in the cylinder is increased by a liquid pump to force the Dricon® fluid into the wood. After the pressure cycle is complete, the working solution is removed from the cylinder and placed back into the work tank. Another vacuum is then applied to the wood to assist in liquid removal from the cylinder and decrease drippage on the pad. The working solution is then checked to determine the concentration and water and /or Dricon® concentrate solution is added to replenish the solution for its next use. PWPB /RMP /2005 B. DESCRIPTION OF PROCESSES AND EQUIPMENT CONT'D Borate Process The Borates product is delivered as a dry product in 55 pound bags. The Borates product is lifted and opened into a tank that contains heated water (120F to 140F). Once mixed and cooled, this concentrated solution is diluted again with water to produce a working solution. A working solution is produced by adding the concentrate solution and water into one of the work tanks. Once the mixing is complete, the work tank is tested to determine if the concentration meets specifications. A charge of wood is then loaded into the retort cylinder via railroad type trams. The wood is initially subjected to a vacuum in the cylinder. Once the vacuum process is complete, the working solution is pumped into the cylinder. Once the cylinder is completely filled with liquid, the hydraulic pressure in the cylinder is increased by a liquid pump to force the Borates fluid into the wood. After the pressure cycle is complete, the working solution is removed from the cylinder and placed back into the work tank. Another vacuum is then applied to the wood to assist in liquid removal from the cylinder and decrease drippage on the pad. The working solution is then checked to determine the concentration and water and /or Borates concentrate solution is added to replenish the solution for its next use. Preserve® Process The Preserve® product is delivered as separate components. The quaternary amine solution is delivered in totes while the copper based amine solution is delivered in bulk. The tote and bulk solutions are then mixed in a concentrate work tank that contains water and boric acid. Once mixed, this concentrated solution is diluted again with water to produce a working solution. A working solution is produced by adding the concentrate solution and water into one of the work tanks. Once the mixing is complete, the work tank is tested to determine if the concentration meets specifications. A charge of wood is then loaded into the retort cylinder via railroad type trams. The wood is initially subjected to a vacuum in the cylinder. Once the vacuum process is complete, the working solution is pumped into the cylinder. Heat is applied through a coil system in the cylinder to maintain 120F. Once the cylinder is completely filled with liquid, the hydraulic pressure in the cylinder is increased by a liquid pump to force the ACQ fluid into the wood. After the pressure cycle is complete, the working solution is removed from the cylinder and placed back into the work tank. Another vacuum is then applied to the wood to assist in liquid removal from the cylinder and decrease drippage on the pad. The working solution is then checked to determine the concentration and water and /or ACQ concentrate is added to replenish the solution for its next use. C. EQUIPMENT INSPECTIONS AND MAINTENANCE While in operation, the process equipment is continually being inspected visually by operators for leaks, malfunctions or maintenance related problems. Other documented formal inspections is as follows: • Daily/Weekly 40 CFR 265, Subpart J inspections on the tank systems • Weekly 40 CFR 265, Subpart W inspections on the drip pad • Annual Independent Engineer Certification on drip pads D. PRODUCT STORAGE INFORMATION See the list following this page. PWPB /RMP /2005 O LL IZ U! (9 cn -j ct 0 Q Ix N 4:x X LO C) C) CL 2 w m a) a) a) a) 'a) a) a) Cl) 0 0) C: a) a) L) r cm C: a) cy) a) im cm 0 a) a) Q a) cm 0 0 c -E Q -0 0 L- C: 0 -0 0 &- =3 -0 C: L- 0 5 -0 C: L- 0 ma c L- C) 00 0 C) o o oi a) fl- .0 a) > ai > aj > ai > ai > aj > ai > 0) 0 0 a) 0 a) 0 -0 0 0 0 CO a) a) ch 0) m m m m m i. 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IT LO -�e -5 Z 0 m m m C) C) m m a) CU *� O 0 CD > m c W N a) cu 4� a) X s- U) U) w < cu -61.1 cu 4— cu 4— cu 1,- ca CD r— C: C: C: c 0 m cc cu cu m ca 0 a) a) a) a) a) a) cu = CO L- L- L- L- a) a) > a) > a) > E 0 cn 0 con 0 0 h 0 0 cn N E 0 0 0 0 EL CN 0 CD 1-0 .1 LO -0 >, E 7FD 0 E < .2 a) c,) 0) a) < cu C: 0 0 0 3: -. r-- LL U) L- " -1.- CD :3 0-0 L- . R -.0 a) o cL -(6 E E V z a) CL CL Q--d off= 0 - >-- 0 r " a) 0 m E 0 < C) 0 CO < (n a) 0 0 co w 1--� Cl) O CD to to (a Lo cn V- co to 0 fi Z Q Q. W LO C) C) n m ACCIDENT HISTORY Section 25534 (c)(1) of the statue requires that the RMPP include "(a) description of each accident involving acutely hazardous materials which has occurred at the business or facility within three years from the date of the request (for the RMPP), together with a description of the underlying causes of the accident and the measures taken, if any, to avoid a recurrence of a similar accident." A. DECRIPTION OF ACCIDENT On July 26, 1987, PWPB had an accident in the Chromium - Copper - Arsenic (CCA) solution storage area. The accident caused a rupture in a CCA work tank inside the spill containment area. No chemicals were released offsite. The retort cylinder is usually filled and emptied through the use of a vacuum pump. During the fill cycle, the vacuum pump draws a vacuum on the retort cylinder dome and pulls the dilute CCA solution from the working tank into the retort cylinder. After the treating process, the discharge from the vacuum pump is then routed via a four way valve back to the retort cylinder to discharge the CCA through a pressure reducing valve back to the work tank. Retort Cylinder Vacuum Pump Suction Vacuum Pump Suction to nosphere Retort Cylinde Vent to Atmosphere Vacuum Pump Discharge Vacuum Pump Discharge Figure IV -1a Normal Fill Position Figure IV -1b Normal Discharge Position The accident occurred when an air supply line to the pneumatic four -way valve failed. Since the air supply line did not have sufficient pressure to operate the four -way valve, the valve position remained in the discharge position as the process controller timed in the fill cycle. With the four -way valve in the discharge position, the retort cylinder pressured up. When the work tank fill valve opened per the controllers normal sequence of events, the pressure from the retort cylinder accelerated the CCA fluid in the fill line. The CCA fluid hydraulically rammed the side of the work tank causing the tank rupture. B. ACCIDENT PREVENTION MEASURES To ensure that the accident would not recur, PWPB installed a spring loaded valve actuator that positions the valve in the fill position if there is a loss of air pressure. PWPB /RMP /2005 SAFETY SYSTEMS The RMP requires that this facility address design, operating and maintenance controls which minimize the risk of an accident involving acutely hazardous materials. The only product that is required under the RMP program is CCA, but a description of all process safety systems has been included in this section. A. CONTROL SYSTEMS High Pressure Switches The retort cylinders are equipped with a high pressure shut off switch that activates below the rated pressure of the cylinder. When activated, the pressure pump is shut off to prevent additional pressure being added to the cylinder. If this pressure switch operates, the system must be reset manually. Boiler Controls In addition to the system controls stated above, the boiler is equipped with many control functions. In addition to meeting ASME pressure codes, the permitted boiler has liquid level alarms and shut downs, pressure switch shut downs and pressure relief valves (All new in 2000). B. DETECTION SYSTEMS Level Gauges Direct readout tank level gauges are installed on all work and storage tanks for visual inspection of tank levels. C. SAFETY EQUIPMENT Pressure Relief Valves All of the pressure vessels (such as retort cylinders) are equipped with pressure relief valves. The pressure relief valves are set at or below the maximum allowable working pressure of the vessel. The pressure relief valves are piped to release the chemical into the containment area under the cylinders. Equipment Containment All bulk tanks and cylinders for each treatment plant is located within concrete containment areas which will hold a minimum of 110% of the largest tank. Eyewash and Shower Eyewash and safety showers are onsite for each plant. D. FIRE PROTECTION SYSTEM There are three fire hydrants located within the facility. Portable fire extinguishers are also available throughout the plant. PWPB /RMP /2005 E. OPERATING PROCEDURES Each operator goes through an extensive training period. The initial training covers the function and capability of each piece of equipment as it relates to the treatment process. An emphasis is placed on how to safely operated the equipment. A portion of this training involves new trainees working under a qualified employee that supervises every step of the new trainee's operation of the treatment process. This training continues until the qualified operator determines that the trainee is now qualified to operate the treatment process without supervision. Under this facility's operating procedures there are always two employees at the site when a treatment process is in operation. Along with this employees are required to manually read the tank gauges before, during and after each charge to ensure tank levels are maintained. PWPB /RMP /2005 RECORD KEEPING PROCEDURES Pursuant to section 25534 ©(7), Chapter 6.95, this section of the RMPP describes the record keeping procedures for the risk management and prevention program. It also discusses inventory control programs and record keeping programs, per Section 25534 (k). As required by Section 25534 (f), the handler shall maintain all records concerning an RMPP for a period of at least five years. A. RECORD KEEPING Record keeping associated with RMPP is the responsibility of the Plant Manager. The Plant Manager will ensure that all of the appropriate records (i.e. safety training, treatment system inspection and testing) are kept. This individual is responsible for maintaining a record of revisions to each document and ensuring that all copies are properly distributed. B. RECORD RETENTION All documents relating to the RMPP shall be maintained for a period of at least five years. Records are kept in the main office at the PWPB facility. These records include the following: ♦ Hazardous material inventories ♦ Inspection records ♦ Daily operations reports ♦ Employee training records C. INVENTORY CONTROL AND RECORD KEEPING PROGRAMS Hazardous Materials Inventories As required by Chapter 6.95, Division 20, California Health and Safety Code, inventories of hazardous materials at the facility are submitted to the Bakersfield City Fire Department. Amendments to the inventories are submitted as required. These inventory records are kept for a minimum of five years. Inspection Records As noted in section C. Equipment Inspections and Maintenance, the process equipment is continually being inspected visually by operators for leaks, malfunctions or maintenance related problems. Other documented formal inspections is as follows: • Daily/Weekly 40 CFR 265, Subpart J inspections on the tank systems • Weekly 40 CFR 265, Subpart W inspections on the drip pad • Annual Independent Engineer Certification on drip pads Operations Records Daily operations reports, including preservative receipts, treatment and inventory records are kept for both treatment plants. Employee Training Records All records of employee training re maintained for at least five years. These files contain information on the employees trained, their respective duties, and the date and content of the training program. PWPB /RMP /2005 DESCRIPTION AND RESULTS OF THE HAZARD AND OPERABILITY STUDY This section of the RMPP addresses the requirement of Section 25534 (d)(1) that the RMPP include the "results of a hazard and operability study which identifies the hazards associated with the handling of an acutely hazardous material due to operating error, equipment failure, and external events, which may present an acutely hazardous materials accident risk ". Additionally, Section 25532 (g) specifies that the RMPP include programs, which include risk assessment for unit operations or operating alternatives. A. HAZOP TECHNIQUE The HazOp technique that was used for the PWPB facility was the "guide word" approach for a Hazard and Operability Study. The guideword HazOp was chosen since it allows a systematic and through review of every part of the facility that handles AHMs. This approach is described in the AIChE Guidelines for Hazard Evaluation Procedures', which is referenced in Section 25534 (1), Chapter 6.95, Division 20, California Health and Safety Code. Other publications further describe this technique, including A Guide to Hazard and Operability Studies'. Although the guide word approach was used for the HazOp, the procedures for conducting the study were adapted to accommodate the size of the facility and the limited staff available. A series of meetings were held at the plant site in order to adequately define the intended design o each of the treatment systems along with the normal operating parameters. Utilizing the schematic drawings of the treatment systems and the expertise of the panel, a HazOp matrix was generated for the components of both treatment systems. Each treatment system was evaluated separately to ensure a through hazard and operability investigation. 1 Guidelines for Hazard Evaluation Procedures, American Institute of Chemical Engineers, New York, 1985. ' Guide to Hazard and Operability Studies, Chemical Industry Safety and Health Council of the Chemical Industries Association, London, 1985. B. HAZOP REVIEW FOR PACIFIC WOOD PRESERVING OF BAKERSFIELD An analysis of the on site equipment and discussions with the plant operating personnel were used to generate the following subsystems for each treatment plant. CCA EQUIPMENT Fill Connections CCA Receiver Tank CCA Solution Mixing System Work Tanks Retort Cylinder Drip Pad CREOSOTE EQUIPMENT Fill Connections Boiler Retort Cylinder Creosote Solution Mixing System Heat Exchanger Emissions Building Each item (study node) was addressed systematically. The guide words (more, less, no) were applied at each node by the HazOp leader to identify potential deviations from the intended design. With each guide word, the deviation from the design, the probable cause, and any consequence was noted in the form of a matrix. The matrix was reviewed by and discussed with the Plant Manager to insure for accuracy and completeness. A series of brief follow up meetings were held to clarify any items of discussion and to review any comments. PWPB /RMP /2005 C. RESULTS OF HAZOP FOR PWPB In order to meet the requirements of the statue, a Hazard and Operability study was performed to identify the hazards associated with the systems that handle the AHMs. The HazOp team tried to focus on the "worst credible events" as opposed to "most likely events ". The term "most likely events" typically represents very minor releases with no public consequence. For this reason, the "worst credible events" were investigated for the offsite consequence analysis. These worst credible events are described briefly below. Such events could be caused by operating error, equipment failure or external events (including earthquakes). Release of CCA Concentrate Potential releases of CCA (copper- chromium - arsenic) concentrate were reviewed. A release of the heavy, viscous CCA concentrate was determined to be most likely to occur during the delivery process. Delivery of the CCA concentrate is by a dedicated carrier, which uses specialized vehicles, designed for this type of delivery. The sole purpose of these trucks is to deliver CCA concentrate. The trucks are manned by a crew trained in the necessary safety requirements. Delivery personnel wear personal protective equipment during the CA deliveries. Buckets are placed under the hose fittings and valves to catch drips and drains. CCA concentrate is delivered by pressurizing the vehicle's cargo tank via an onboard compressor. This pressurization forces the contents through the hoses into the CCA concentrate tank. The pressure required to fill the tank is approximately 9 psi (20 ft). A worst case failure of the filling system would be a hose or fitting failure during the delivery of the CCA concentrate. All of the treatment tanks in the CCA treatment facility have secondary containment. The entire tank area is surrounded by a three -foot high concrete wall with a concrete floor. The secondary containment area is design to allow spilled fluids to cascade internally in the containment area and eventually flow into the retort cylinder pit. This pit is capable of containing 1.5 times the volume of the largest tank (mixture tanks have a capacity of 36,092 gallons). A separate release event associated with the delivery of the CCA concentrate was the possibility of a vendor overfilling the receiver tank. PWPB's operating procedures ensure that this event could not take place. CCA concentrate is ordered only when the storage tank is nearly empty. Only 3000 gallons of CCA concentrate are ordered to replenish the inventory. The CCA concentrate tank capacity is 6,000 gallons. This operating practice results in the CCA concentrate tank rarely reaching the halfway mark. As an added safety measure, the tank is always gauged before delivery to double -check the inventory system. Additionally, the operators are always aware of the tank levels since they are required to log in tank volumes every time they complete a treatment or make a batch of treatment fluid. Buildup of CCA Concentration on Drain Pad After a charge of wood has been treated, it is pulled out of the retort cylinder and stored on the surrounding drain pad. The purpose for the storage is to allow the excess CCA compound to drain off the wood and to allow the wood to dry. The drain pad is sloped toward the retort cylinder pit to collect the treatment fluid. A sump pump is located into a working tank. Since the working CCA compound is approximately 98% water, a great deal of evaporation takes place during the summer months. As the water evaporates, the concentration of the CCA compound increases in the residual treatment fluid on the drain pad. PWPB has incorporated an operational procedure to hose down and squeegee the drip pad area regularly during the summer; thus preventing any build up of CCA compound on the pad. During the winter months, evaporation is much slower due to the cooler weather. Although the CCA concentrations will not be as high due to the lack of evaporation, somewhat elevated concentrations could exist. However, PWPB has implemented an operational procedure to squeegee the drip pad into the pit area as needed. These procedures should substantially reduce the possibility of the buildup of CCA concentration. PWPB /RMP /2005 Summary of the CCA treatment Facility The HazOp team reviewed the possibility of an offsite release associated with operation of the CCA treatment facility. Since the CCA compound is used in a very dilute form and does not have a vapor pressure high enough to form a gas, the only routes for an offsite exposure does not represent a health risk to workers or the surrounding community. Higher concentrations of the CCA compound may represent a slight increase in health risk if good personal hygiene is not practiced. Exposures to any elevated concentrations of CCA compounds were effectively eliminated when PWPB implemented the drip pad clean up practices. As an added measure of protection, a forklift was dedicated to the drip pad and employees working on the drip pad are required to wear chemical resistant foot wear. Both the tires on the forklift and the chemical resistant foot wear is triple rinsed if it leaves the drip pad. Release of Creosote A worst case failure of the filling system would be a hose failure from the shipping vehicle. Creosote is shipped to PWPB via rail car and is drawn out of the rail car by means of a 100gpm pump. There are always two operators in charge of running the creosote operation and one of them stands by to oversee the delivery. Since the hose is under a suction pressure, a leak in the hose would cause an influx of air into the system causing the pump to caviate. The operator would immediately notice this problem and take measures to correct it before resuming the delivery. Creosote flows from the rail car to the tank through a pipeline. This flow line is located in a larger diameter pipe, which functions as secondary containment. The secondary pipe drains into a containment area to allow an operator to deflect a leak in the primary pipe. Also, the tanks are surrounded by a 3 -ft. wall for secondary containment. As in the CCA plant, any significant spillage is funneled into the retort cylinder pit area. The floor in the containment area is concrete to prevent any contamination of the soil and groundwater. The receiver tank is equipped with overflow pipes connected to the pit. In the case of an oversupply of product, the excess product would simply flow into the overflow pipes and into the containment area. The pit is capable of holding one and half times the volume of the largest tank. The largest tanks are the working tanks (or mixing tanks) which hold 36,072 gallons. The receiver tank for the creosote is a 19,440 gallon tank. An overflow of product is prevented by several operational procedures. Creosote shipments are never ordered until the creosote tank is nearly empty. Since the shipments are transported by a 17,000 gallon rail car, a single shipment is unlikely to overfill a tank. The operators are always aware of the tank levels since they are required to log in tank volumes every time they complete a treatment or make a batch of treatment fluid. There are also fluid level indicators on every tank. The tanks are again measured before a shipment is ordered to double check the level. Summary of the Creosote Treatment Facility The HazOp team reviewed the possibility of an offsite release associated with operation of the creosote treatment facility. Since the creosote and the fuel oil carrier do not have vapor pressures high enough to form a gas, the only routes for an offsite exposure are again physical contact and perhaps a release associated with a fire. Fire hazards are minimized at the facility by good housekeeping practices. Exposure to the creosote compounds does not represent a significant health risk to the surrounding community. In the unlikely event of a fire, exposure to the community would be similar to the smoke from an oil fire. PWPB /RMP /2005 OFFSITE CONSEQUENCE ANALYSIS Section 25534 (d)(2), Division 20, California Health and Safety Code status that "[t]he RMPP shall consider ....... [f]or the hazards identified in the hazard and operability studies, an offsite consequence analysis which, for the most likely hazards, assumes pessimistic air dispersion and other adverse environmental conditions ". Additionally, Section 25534.1 requires that "[e]very RMPP...... shall give consideration to the proximity of the facility to schools, general acute care hospitals, and long term health care facilities ". The release cases identified in the HAZOP study did not generate an atmospheric release of the AHMs. Therefore, an air dispersion was not run. PWPB /RMP /2005 IMPLEMENTATION OF THE RMP A. ORIGINAL IMPLEMENTATION OF RMP The RMP program was originally implemented in 1990. At this time there were no physical revisions required and any operational procedure changes identified during the HAZOP study were implemented. B. CURRENT IMPLEMENTATION OF RMP With the removal of the creosote treatment process, PWPB has reduced their RMP applicable hazardous constituents to only one, arsenic pentoxide. In reality, PWPB does not have arsenic pentoxide on the site as their product CCA, is a liquid. Historically it has always been easier to analyze the arsenic portion of CCA as arsenic pentoxide and under AWPA standards, this was the method used. This analytical method resulted in using the term arsenic pentoxide for the actual contents. PWPB has decided to include in this RMP program all of the treatment processes currently in operation at the site. All of the Safety Systems and most of the Inspections under the RMP have also been implemented for the treatment processes not actually required under this program. C. PERSONNEL RESPONSIBLE FOR IMPLEMENTATION As of the date on this program, the following personnel are involved in managing and implementation of the RMP program: Roland Mueller Director of Environmental and Safety Compliance Updating RMP program, implementation overview, assist in determining effectiveness Rick McCullough Plant Manager Overview implementation of program, determine effectiveness, assist in changes of program Casey Ziemer Assistant Plant Manager Ensure implementation of program, assist in changes Shawn Nolan Treating / Q.C. Implement program, notify management of problems in implementation PWPB /RMP /2005