MG Industries - West Lake - Executive Summary |
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MESSER - MG INDUSTRIES - WEST LAKE AIR SEPARATION UNIT PRODUCTION FACILITY RMP EXECUTIVE SUMMARY INTRODUCTION - MESSER AMERICA'S LOSS PREVENTION PROGRAM Loss Prevention management refers to the prevention of potential losses to Messer through an effectively designed, administered and implemented Environmental, Health, Safety and Regulatory Compliance program. Incorporating an effective loss prevention program requires developing and integrating programs that will assist in reducing losses resulting from accidents. Messer GmbH has developed Safety, Health, and Environmental guidelines. These guidelines have been further refined and developed into a comprehensive program defined as Loss Prevention Policies (LPP) and are contained in this manual. These policies are the minimal standards for Messer America's (Central, North, South America and AGS) operations. The objective of this program is to achieve an acceptable level of performance in the prevention of losses to the organization , which include but are not limited to; accidents, injuries, illnesses, product liabilities, regulatory non-conformities, etc. To be effective, this management system must be totally integrated in which all levels of employment are involved and held accountable. The ultimate authority for instituting an effective Loss Prevention Program rests with the senior management of each operating Group. Through their words and more importantly through their actions, senior management sets the tone for loss prevention throughout Messer Americas. While senior management sets the tone, middle management must create the uniform support and nurture the desired culture to influence the Loss Prevention program. This strong management commitment culminates with the day to day responsibility of implementing and managing the Loss Prevention program by "line management" (supervisor and lead personnel). Local management is accountable for the effective management of this program through their organization 's performance as related to loss prevention and regulatory compliance (which includes company policies). In a healthy loss prevention culture, each member of the company participates fully in the program. Loss prevention is no longer an activity that someone else is in charge of. Each manager, supervisor, driver, and line worker is personally responsible for insuring "safe working conditions, safe product for all customers and a safe environment for the citizens of the communities in which Messer operates". SIMPLIFIED PROCESS DESCRIPTION The MG Industries West Lake facility is an air separation manufacturing plant. The natural gas portion of the plant process falls within the RMP requirements. Air is filtered and compressed in a centrifugal compressor to 90 psig. After compression, heat is removed from the air with the aid of a cooling medium. The process air is subsequently passed through a vessel containing molecular sieve material to remove carbon dioxide and water. There are multiple vessels that are automatically sequenced that facilitates regeneration of sieve material with the use of dry nitrogen/air by-products gas. Throughout each step of production the process air is analyzed for impurities, and monitored for control limits, thereby maintaining product quality standards. The next stage of production involves cryogenic separation and purification. After leaving the compression/filtration stage, the process air enters a network of heat exchangers and distillation columns, housed in an insulated structure. Initially heat must be removed from the incoming process air. This is accomplished via a mult-pass counter current heat exchanger designed to bring the air temperature down to cryogenic conditions, by way of passing outgoing gaseous products through adjacent heat exchanger fins. The cold air now enters a double rectification column due to pressure and temperature differences between the components of air. The separation process begins to oc cur. Oxygen and Nitrogen are circulated through both distillation columns which contain perforated trays stacked horizontally within the column. As the molecules filter through these trays, they become purer and concentrate at different levels in the column. Process control is accomplished through a series of detection points. Each component of air can be withdrawn at various standards of purity throughout the column. The final step in this process involves liquefaction of the separated gases. Inside the rectification column, a portion of pure gaseous nitrogen is continuously withdrawn and sent to an externally located liquefier section. This gaseous nitrogen is routed through several loops before arriving at its final destination, as liquid back into the distillation column. The first loop sends gaseous nitrogen through a series of heat exchangers and compression equipment in order to provide a heat balance and volume to the system. The second loop draws a portion of compress ed nitrogen and feeds this stream to an expansion turbine to achieve cryogenic temperatures in the liquifier section. The remaining unexpanded gas is liquefied by heat exchange with a turbine discharge streams and expanded back into the rectification column. This liquid nitrogen entering the column provides sufficient cooling to liquify the remaining gases. As liquid level are established and purity analysis is taken, quantities of liquid oxygen and nitrogen can be withdrawn for storage. The aforementioned part of the process that involves a RMP regulated substance is the regeneration of the mole sieve material. Natural gas (methane) is used as a fuel to heat the regeneration gas for the vessel. The methane exists in quantities large enough for RMP submission. The safety-related equipment/devices are described later in this summary report. WORST CASE RELEASE SCENARIO The first step in the worst-case release analysis was to determine the total amount of natural gas onsite. It was determined that there are 40,126 lbs of natural gas on-site. While there are safety devices and process controls on the equipment to prevent accidental releases, a large natural disturbance such as a tornado could rip through the facility and create a worst-case release of all of the natural gas. The determination of the affected distance to endpoint was made using the RMP*Comp software. The distance to endpoint was found to be 0.3 miles. The Landview III software package was used to determine the general environmental and community impact within this radius. There are approximately 60 people living within this radius. There is also one other business in the immediate area. There are no environmental receptors in the endpoint radius area. ALTERNATIVE RELEASE SCENARIO The best alternative scenario that could be developed that would have an offsite impact was modeling rupture in a 1" safety relief valve header resulting in natural gas escaping. A ten-minute time period was used for the release calculations. This is an estimate on the maximum amount of time required to close the upstream valve manually. The amount of natural gas released was calculated at 615 pounds using the RMP*Comp software. The distance to endpoint was found to be 0.1 miles. The Landview III software package was used to determine the general environmental and community impact within this radius. There are approximately 3 people living within this radius. There is also one business within the radius. There are no environmental receptors in the endpoint radius area. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS - LOSS PREVENTION WRITTEN POLICY SUMMARY The objective of the Messer Loss Prevention Program is to achieve an acceptable level of performance in the prevention of losses to the organization. The paramount importance of our Loss Prevention Program is assuring safe working conditions for our employees, safe product for our custom ers, and a safe environment for the citizens of the communities in which we operate. This program is integrated with a series of Loss Prevention Policies that are the cornerstone of Messer Loss Prevention efforts. These policies form our Loss Prevention Policies Manuals. These manuals are maintained by local management and are available for review by any employee upon request during normal business hours. In addition, compliance with local and federal regulations such as OSHA, DOT, EPA are required. AUTHORITY AND RESPONSIBILITY FOR PROGRAM IMPLEMENTATION Plant Manager has the overall site authority for implementation of the Loss Prevention Program. He or she is responsible for the day to day management of the Loss Prevention Policies as they directly relate to all operational activities. Terminal Manager is responsible for the day to day management of the Loss Prevention Policies as they directly related to distribution activities. Site Safety Advisor is responsible for conducti ng periodic inspections, serving as the facility spokesperson (on Loss Prevention issues) and participation on the Safety Committee. Regional Manager oversees the Loss Prevention activities of their region, conducts audits, introduces new and/or revised Loss Prevention Policies, participates in "Group" accident/incident investigations and assures that hazards are abated in a timely manner. SYSTEM FOR IDENTIFYING, EVALUATING, AND PREVENTING OCCUPATIONAL SAFETY AND HEALTH HAZARDS HAS BEEN DEFINED THROUGHOUT THE LOSS PREVENTION MANUAL WHICH INCLUDE, BUT ARE NOT LIMITED TO: () Review of applicable standards to the industry. () Review and availability of Material Safety Data Sheets. () Assure the proper labeling of potentially hazardous materials. () Safety work permitting systems. () Investigation of accidents/ incidents. () Periodic and scheduled inspections of the general work areas. EMPLOYEE COMMUNICATIONS AND TRAINING ARE ALSO DEFINED THROUGHOUT THE LOSS PREVENTION MANUAL WHICH I NCLUDE, BUT ARE NOT LIMITED TO: () Monthly poster program service by the National Safety Counsel on a variety of safety and health topics. () Site specific Safety Bulletin Board for the posting of all environmental, health and safety related information i.e. Loss Prevention Policy, Injury/Illness Logs, safety posters, etc. () Site specific Safety Committee made up of representative functional positions within the operation. () Monthly Safety Meetings are held on various environmental, health, and safety related topics. () Safety Orientation for all new hires and personnel transferred into new positions. () Regulation Compliance training as it may apply to specific operations and/ or exposures i.e. Hearing Conservation, HAZCOM, Respiratory Protection, Fire Extinguishers, etc. RECORDKEEPING Loss Prevention records are maintained in the facilities Loss Prevention and Regulatory files. Access to these files is controlled by the respective manager. Distribution of these records requir es authorization. PROCESS SAFETY FEATURES The MG West Lake facility has a Loss Prevention Program at both the local and corporate levels. The part of the process that is affected by RMP is natural gas. The natural gas system is protected by both safety relief valves and rupture disks. A manual emergency isolation shut off device is incorporated in the system. The facility is manned 24 hours a day with routine in-house inspections. In addition to the interlock systems, the entire process is equipped with emergency E-stops located throughout the entire facility. FIVE-YEAR ACCIDENT HISTORY In the past five years there was one reported accidental release at this facility. The substance released was anhydrous ammonia which is not part of this facility RMP because it is used and stored at below threshold levels. The release was the result of human error and involved the removal of a safety relief that was still under pressure. About 600 pounds of ammonia was released. The prop er emergency response groups were notified and the release was controlled shortly thereafter. Additional information is found under Section 6 of this report. EMERGENCY RESPONSE PROGRAM The local fire department performs periodic visits to the facility and is a part of the facility emergency action plan. The fire department plays a critical role in this plan. MG relies on the fire department to assist in the control and mitigation of an incident at this site, wheras MG provides the technical expertise with respect to the equipment and product. A comprehensive Loss Control Program exists at the facility that is managed both locally and at the MG corporate level. PLANNED CHANGES TO IMPROVE SAFETY Opportunities are continually reviewed to improve the safety and reliability of the facility. |