Harcros Chemicals Inc - Kansas City - Executive Summary |
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HARCROS ORGANICS DIVISION OF HARCROS CHEMICALS INC. RISK MANAGEMENT PLAN 1.0 Executive Summary Harcros Organics is committed to the safe operation of its plants for our employees, the public and the environment. Harcros Organics has demonstrated this commitment through a system of management practices which help to ensure safe operations at this facility. The Risk Management Program is a part of our system which helps us manage risks at Harcros Organics. The requirements of the Risk Management Program can be found in the Environmental Protection Agency's regulation 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Program (the RMP rule). It is the intention of this executive summary to provide the public with a description of Harcros Organic's Risk Management and to satisfy Risk Management Plan requirements of the Risk Management Plan rule. 1.1 Accidental Release Prevention and Emergency Response Policies. At this facility, we handle ethylene oxide and propylene oxide which are hazardous substances. The same properties that make ethylene oxide and propylene oxide valuable as commodity chemicals also make it necessary to observe certain safety precautions to prevent unnecessary human exposure, to reduce the threat to our health and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and State regulations. Safety depends upon the manner in which we handle ethylene oxide and propylene oxide, the safety devices inherent in the design of this facility, the safe handling procedures that we use and the training of our personnel. Harcros Organics implements controls to prevent foreseeable releases of hazardous substances. We will determine for each situation whether evacuation of employees is required. We have an Emergency Response Plan for spills. We will rely on public and private agencies to supplement our own response personnel. The public agencies will notify any potentially affected neighbors. 2.0 The stationary source and regulated substances handled. Ethylene oxide and propylene oxide are received by railcar. The chemicals are transferred to reactors where they are consumed in the process to make less hazardous products. The ethoxylation and propoxylation unit produce surfactants which are used in detergents, emulsifiers, hard surface cleaners, plastics, personal care products and agricultural applications. This facility has controlled access at all times. The maximum storage quantity of ethylene oxide is 1.4 million pounds. The maximum storage quantity of propylene oxide inventory is 360,000 pounds. The average monthly inventories are much less. The average monthly inventory of ethylene oxide is 500,000 pounds. Propylene oxide monthly average inventory is 71,000 pounds. 3.0 Offsite Consequence Analysis. An offsite consequence analysis was performed to estimate the potential for an accidental release of a Risk Management Plan r egulated substance to affect the public or the environment. Evaluation of both the worst-case scenario and alternative release scenarios are used for the offsite consequence analysis. Harcros Organics does not expect a worst-case release scenario to ever occur. An alternative release scenario is considered a more likely scenario. Offsite consequence analysis determines the distance (called the end point distance) at which an accidental released regulated toxic substance could reach under a predetermined set of conditions. The worst-case scenario and the alternative release scenarios. Alternative release scenarios include administrative controls and mitigation measures to limit the distance for each reported scenario. Worst-case scenario - Failure of a full 85 ton (170,000 pound) railcar of ethylene oxide. It is assumed that the entire contents are released and vaporized in 10 minutes. The distance to the toxic end point of 0.09 mg/L is 8.7 miles as determined by the EPA's " RMP Comp" computer program. Within the circle of the 8.7 miles radius is a population of 360,000 people (1990 census-landview program.) Public receptors include schools, residences, public recreational areas, an arena, hospitals, office and industrial areas. No environmental receptors are within this distance. Alternative Release Scenario (ethylene oxide) - A runaway reaction releases 1,000 pounds of ethylene oxide in 10 minutes through the vessel's pressure relief valve. The distance to the toxic endpoint (as determined by RMP Comp) is 0.30 miles. There are no residences or schools within this distance. Public receptors include industrial areas. Alternative Release Scenario (propylene oxide) - A hole in the bottom of the propylene oxide railcar releases 4160 pounds of propylene oxide in 10 minutes. This scenario is not based on any actual event. The distance, to the toxic endpoint of 0.059 mg/L, is 0.30 miles as determined by RMP Comp. There are no residences or schools w ithin this distance. Public receptors include industrial areas. There are no environmental receptors within this distance. 4.0 The general accidental release prevention program and the specific prevention steps. This facility complies with EPA's Accidental Release Prevention Rule, and with all applicable State codes and regulations. The processes which use ethylene oxide and propylene oxide are not only subject to the Risk Management Plan Rule but also subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standard. This standard addresses each of the OSHA (PSM) elements and describes the management system in place to implement the Accident Prevention Program. Employee Participation Harcros Organics encourages employees to participate in process safety management and accident prevention. Employee participation ranges from updating and compiling technical documents and chemical information to participating as a member of a proce ss hazard analysis (PHA) team. Information created as part of our plant accident prevention program is available to all employees. Process Safety Information Harcros Organics maintains a variety of technical documents and information concerning process chemicals and process equipment which is essential to an effective process safety management program and to process hazard analysis. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemicals specific information, including exposure hazards and emergency response exposure treatment consideration is provided in material safety data sheets. Harcros Organics ensures that the process is maintained within limits using process controls, highly trained personnel and protective instrument systems (e.g., automated shutdown systems). Process Hazard Analysis Harcros Organics has a comprehensive program to help ensure that hazards associated with ethylene oxide and propylene oxide processes are identified and controlled. Each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. We have used the hazard and operability (HAZOP) analysis method to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation technique. The process hazard analysis for the processes are carried out by a team with expertise in engineering and process operations. The HAZOP team identifies and evaluates hazards of the process and makes recommendations which are addressed. All approved mitigation options which are being implemented in response to HAZOP team findings are tracked until they are complete. The final resolution of each finding is documented and retained. At least every 5 years, the process hazard analysis is updated and revalidated. This assures the process haz ard analysis is consistent with the current process. Operating Procedures Written procedures are maintained that address various modes of process operations such as unit start up, normal operations, temporary operations, emergency shut down, normal shut down and initial start up of a new process. Procedures are reviewed periodically and annually certified as current and accurate. Training Each employee involved with operating a process and each employee before being involved in operating a newly assigned process is trained in an overview of the process and in the standard operating procedures. New operators are paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. Refresher training is provided at least every three years. All training is documented, including the means used to verify that the operator understood t he training. Contractors Harcros Organics has procedures in place to ensure that contractors (1) perform their working in a safe manner, (2) have appropriate knowledge and skills, (3) are aware of the hazards in the work place , (4) understand what they should do in an emergency, (5) understand site safety rules, including notifying Harcros Organics personnel of any hazards that they find during their work. This is accomplished by providing contractors with a process overview, information about safety and health hazards, emergency response plan requirements and safe work practices prior to beginning work. Pre-Startup Safety Review A pre-startup safety review is done for new or modified facilities when the modification is significant enough to require a change in the process safety information. The purpose of the pre-startup safety review is to ensure that safety features, procedures, personnel and the equipment are appropriately prepared for startup prior to placing the equipmen t into service. Mechanical Integrity Harcros Organics has practices and written procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, emergency shutdown systems in safe operating conditions. Maintenance employees involved in maintaining the on going integrity of process equipment are provided an overview of the process and its hazards and in the procedure applicable to the employees job tasks to assure that the employee can perform the job task in a safe manner. Safe Work Practice Harcros Organics has long standing safe work practices in place to help ensure worker and process safety. Example of these include (1) control of the entry/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of ethylene oxide and propylene oxide before equipment is opened, (4) a permit procedure to control spark-producing activ ities (i.e., hot work) and (5) a permit procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change Harcros Organics has procedures to manage change (except for "replacement in kind") of process chemicals, technology, equipment, and operating procedures that affect covered processes. Incident Investigation Harcros Organics investigates each incident which resulted in or could reasonably have resulted in a release of a highly hazardous chemical in the work place. Incident investigations are initiated as promptly as possible, but not later than 48 hours following the incident. The goal of each investigation is to determine the facts and develop correction actions to prevent a recurrence of the incident or a similar incident. The investigation team consist of at least one person knowledgeable in the process and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. A management committee is established to properly address and resolve incident report findings and recommendations. Compliance Audits To help ensure that the accident prevention program is functioning properly, compliance audits are conducted at least every three years. Corrective actions taken in response to the audit team's findings and are tracked until they are complete. Chemical - Specific Prevention Steps Through process safety management, the hazards associated with ethylene oxide/propylene oxide processes are managed to ensure continued safe operation. The prevention program summarized previously is applied to covered processes at Harcros Organics. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. In addition to the accident prevention program activities, Harcros Organics has safety features on the ethylene oxide and propylene oxide process units to help contain and control a release, (2) quickly detect a release and (3) reduce the consequences of (mitigate) a release. The following types of safety features used are: Release Detection Flammable Gas Detectors with alarms. Process alarms. Release Containment/Control Process relief valves Scrubber to solubilize ethylene oxide / propylene oxide Valves to permit isolation of the process. Automated shutdown systems for specific process parameters (e.g. high level, high pressure, high temperature). Trench system to contain liquid releases which flow to equalization tank. Back up fire water tank and fire water pump. Release Mitigation Deluge system for specific equipment. Trained personnel to assist emergency responders. Personal protective equipment (e.g. protective clothing, self-contained breathin apparatus. .Blast-resistant wall to help protect control systems and personnel. 5.0 Five year accident history No releases of ethylene oxide or propylene oxide have occurred in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries evaluations, sheltering-in-place, property damage, or environmental damage off site. On February 3, 1997 a pump which had been down for maintenance, was started to pump ethylene oxide to a reactor. A drain valve was not fully closed which allowed ethylene oxide leak approximately 100 pounds under the snow. An operator correctly isolated the pump and washed down the snow to the waste water treatment tank. On May 14, 1998, ethylene oxide was released from a reactor through a pressure relief valve which instantaneously released and resealed. The operator correctly vented excess pressure through the scrubber to eliminate any additional release. Although the investigation committee could not determine the exact amo unt of ethylene oxide released, it was estimated that over 10 pounds of ethylene oxide was released. 6.0 Emergency Response Program Harcros Organics has established a written emergency action plan and emergency response plan. We coordinate emergency response procedures with the local fire department. Harcros Organics employees will respond to minor events that do not have potential for significant effects (e.g. small fires or small leaks). In the event of a larger fire or release, employees evacuate the area and contact the local fire department. 7.0 Planned changes to improve safety Harcros Organics strive to improve the safety of our processes through periodic safety reviews, the incident investigations programs, and a program soliciting safety suggestions from employees. The follow types of changes are planned during the next 5 years. Revised process instrumentation and or control in the ethylene oxide/propylene oxide unit. Revisions to training programs. Revised written operating procedures. Emergency response drills. |