Welland Chemical, Inc. - Executive Summary |
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WELLAND RMP EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES This facility has a long-standing commitment to worker, contractor, and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Welland Chemical, Inc. plant is located in Newell, Pennsylvania. This facility produces Nitric Acid, in various forms and mixtures to meet exacting customer specifications. Nitric acid goes into the production of many of the modern comforts we enjoy in today's society. These industries, amongst others, utilize nitric acid as part of their p roduction system; specialty steels, high-end electronics, plating, fertilizer, and explosives. The production of nitric acid starts with anhydrous ammonia and air. These two components are mixed together and reacted over a catalyst forming nitrogen dioxide. Nitrogen dioxide is then cooled, and condensed to form weak nitric acid. This weak nitric acid and remaining nitrogen dioxide then passes through an absorbing tower where nitrogen dioxide is absorbed in water to create more weak nitric acid. This weak nitric acid is then concentrated using sulfuric acid to absorb the water content of the weak nitric acid, leaving a concentrated or strong nitric acid. This strong nitric acid is then mixed with weak nitric to create blend acid solutions, or blended with oleum to create mixed acid solutions. The facility has propane as a regulated flammable, and anhydrous ammonia, Oleum (20%), and nitric acid above the threshold quantity as regulated toxic chemicals that are part of the RMP program. Anhydrous ammonia is delivered to the facility by barges. The unloading of these barges is completed while the towboat or motor force remains connected to the barges; for this reason, the unloading of ammonia is not covered. The model used for the Worst Case Scenario (WCS) and Alternative Case Scenarios (ACS) is the EPA's RMP*Comp(tm). It lists oleum as (30%) only; this facility utilizes Oleum (20% and 35%). Additionally, nitric acid is listed as 100%, this facility produces 98%. The facility's covered processes require the application of the RMP Program 3 criteria. HAZARD ASSESSMENT RESULTS The hazard assessments were completed utilizing the EPA's RMP*Comp(tm) modeling system. This system calls for the atmospheric stability class to be used as type F, which is the worst atmospheric situation. For all the scenarios, the type F atmospheric stability class was used. Flammable Substance The worst-case scenario (WCS) associated with a release of flammable substances in the covered proc esses at the facility is a vapor cloud explosion (VCE) involving the largest (only) storage tank containing propane. This scenario would release 171,628 pounds of propane, assumed to release instantaneously, completely vaporize, and ignite, resulting in a VCE. This event would have off-site consequences from the 1psi overpressure wave. The distance to endpoint would be .40 miles, which is just past the facility gate. The estimated population within the distance to the endpoint is 153. The public receptors within the distance of the endpoint include residences and recreational facilities only. There are no environmental receptors within the distance to the endpoint Although we have controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this worst case scenario. There is one alternate release scenario (ACS) considered more credible for the flammable release. This scenario is at a single locati on in our facility and based upon propane unloading line failure. This failure would release 1870 pounds of propane. The 1psi endpoint would be .06 miles which is within the boundaries of the facility and will not reach public or environmental receptors. Toxic Substance The worst case scenario associated with the release of a toxic substance is a storage tank containing nitric acid. This scenario would release 713,775 pounds of nitric acid over a 10-minute period. The release would involve a liquid spill and vaporization of nitric acid. The release rate would be 71,377.5 pounds per minute. The wind speed would be 1.5 m/sec. The topography used in the model is urban. The distance to the endpoint is 25 miles and would effect a residential population of 1,032,120. The public receptors, within the distance to endpoint would include; schools, residences, hospitals, prisons/correctional facilities, recreational areas, and other major commercial, office or industrial areas. The environmental receptors, within the distance to endpoint would include officially designated wildlife sanctuaries, preserves, or refuges and federal wilderness areas. The release would reach a public receptor at the ERPG 2 concentration. There are three alternate release scenarios for toxic chemicals that would have off-site consequences. The chemicals involved are anhydrous ammonia, nitric acid and oleum. These events are selected as being practical scenarios for use in emergency planning and response. Although we have controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this worst case scenario. Scenario-Anhydrous Ammonia The ACS for anhydrous ammonia involves a pipe leak of liquid ammonia in the amount of 1860 pounds. The release rate would be 372.0 pounds per minute for a 5-minute period. The wind speed would be 1.5 m/sec. The topography used in the model is urban. The distance to endpoint would be .20 miles and would effect a residential population of 45. The public receptors, within the distance to endpoint would include only residences. There are no environmental receptors within the distance to endpoint. Scenario-Nitric Acid (conc.80% or greater) The ACS for nitric acid involves a pipe leak of liquid nitric acid in the amount of 379 pounds. The release rate would be 75.9 pounds per minute for a 5-minute period. The wind speed would be 1.5 m/sec. The topography used in the model is urban. The distance to endpoint would be .30 miles and would effect a residential population of 36. The public receptors, within the distance to endpoint would only include residences. There are no environmental receptors within the distance to endpoint. Scenario-Oleum (fuming sulfuric acid) The ACS for oleum involves a pipe leak of liquid oleum in the amount of 6,800 pounds. The release rate would be 1,360 pounds per minute for a 5-minute period. The wind speed would be 1.5 m/sec. The topograp hy used in the model is urban. The distance to endpoint would be 1.20 miles and would effect a residential population of 1,299. The public receptors, within the distance to endpoint would include; schools, residences, and recreational areas. There are no environmental receptors within the distance to endpoint. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Welland Chemical facility. Because the process at the facility falls under the EPA RMP regulation, it is also subject to the OSHA PSM standard. This summary addresses each of the OSHA PSM elements and describes the management systems in place to implement the accident prevention program. Employee Participation The Welland Chemical facility encourages employees to participate in all elements of process safety management and accident prevention. Examples of employee participation include employees serving as members on process hazard analy sis teams as well as incident investigation teams. Employees also serve as trainers and procedure writers. Employees also form the emergency response team and haz mat teams for the facility and receive training to maintain qualifications; participate in safety and environmental meetings. Our process unit operators monitor their areas of responsibility and provide monthly reports on the status of various safety and emergency response equipment. Process Safety Information The Welland Chemical facility maintains a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific persons within the facility are assigned responsibility for maintaining up-to-date Process Safety Information (PSI). Each process unit has its specific PSI training material for the operating personnel to refer to when questions arise. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, are provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with inadvertent mixing of chemicals. Each process area also has available all the equipment listed including what, if any, chemicals or hydrocarbons are present and a hazard rating based on the National Fire Protection Association system. For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g. temperature, level, and pressure) and has studied hazard scenarios through the Process Hazards Analysis process. The facility ensures that the processes are maintained within these limits using process controls and monitoring instruments, trained personnel, and protective instrument s ystems (e.g. automated shutdown systems) The facility also maintains technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the processes are not compromised. Process Hazards Analysis (PHA) The Welland Chemical facility has a program in place to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards, and to ensure that adequate controls are in place to manage these hazards. The facility uses primarily the Hazard and Operability (HAZOP) analy sis and What-If/Checklist technique to perform these evaluations. HAZOP and What-If/Checklist analysis are recognized as the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a multi-disciplined team with various experience backgrounds. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are documented for local management. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. Resolution of items can be categorized as procedures, repairs of existing equipment, engineering studies and installing new equipment. The final resolution of each finding is documented and retained in a facility item tracking process. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Welland Chemical facility periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures The facility maintains written procedures that address various modes of process operations, such as unit startup, normal operations, temporary operations, emergency shutdown, normal sh utdown, and initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified, by operators and management, as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the Management of Change (MOC) process, described below. These written operating procedures are readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks. Training To complement the operating and maintenance procedures, the facility has a comprehensive training program for all employees. New employees are required to complete the facility-training program. This program includes formal operations training, classroom training, on the job training, self-study training, and testing. The program design calls for completion, depending on the experience level of hired employees, within the following time frames; Operator (Lead and Break-shift) 60 work days Operator II 45 work days Loader/Mixed Acid Operator 30 work days Utility Operator 2 work days During a three year apprenticeship, each apprentice must successfully complete all facets of the program which include; basic facility training, job specific training, testing (written & skill demonstration), and qualifying on a jobs at the assigned area. In addition, all operators are re-certified every three years. This re-certification process includes any necessary refresher training, written testing, and skill demonstrations. All training and testing is documented for each individual employee. Contractors Welland Chemical uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process e quipment, the facility has procedures in place to ensure that contractors have the appropriate knowledge and skills, are aware of the hazards in their workplace, understand what they should do in the event of an emergency, understand and follow site safety rules, perform their work in a safe manner, and inform facility personnel of any hazards that they find during their work. Our contractor safety program is accomplished by providing contractors with an initial orientation meeting, prior to their beginning work, which provides site specific hazards by using safety information cards (SIC) Cards, information about general safety and health hazards, emergency response plan requirements, and safe work practices. In addition, the facility evaluates contractor safety programs and performance during the selection of a contractor. Welland Chemical personnel periodically monitor contractor performance and perform various audits to ensure that contractors are fulfilling their safety obligat ions. A weekly Contractor Safety meeting is held with representatives of our contractors. Contractors participate by presenting topics and the minutes are distributed to all attendees. Pre-Startup Safety Review (PSSR) Facility personnel conduct a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. A PSSR involves field verification of the construction, and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The Welland Chemical facility has practices and procedures to mainta in pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include; conducting training, developing written procedures, performing inspections and tests, correcting identified deficiencies, and applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on safety and health hazards, applicable maintenance procedures, emergency response plans, and applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and equipment tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g. adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or key personnel will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is Positive Material Identification (PMI) for equipment containing alloy materials. The Welland Chemical facility incorporates PMI measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper material and spare parts are used when repairs are made. Safe Work Practices The Welland Chemical facility has long-standing safe work practices in place to help ensure worker and process safety. Examples include; control of entry/presence/exit of support personnel, a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintena nce, a procedure for safe removal of hazardous materials before process piping or equipment is opened, a permit and procedure to control spark-producing activities (i.e., hot work), and a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change (MOC) The Welland Chemical facility has a MOC system to manage changes to the process. This system requires that changes to items such as process equipment, chemical technology (including process operating conditions), procedures and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards, and to verify that existing controls have not been compromised by the change. Affected chemical ha zard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. Any changes which has a potential impact on quantities of new or existing toxic or flammable hydrocarbons must be review by the person assigned to coordinate the RMP. Documentation of employee training on the change is covered under PSSR. Incident Investigation The Welland Chemical Facility promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and to develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team is led by an experienced supervisor or technical representative, and includes other required technical support and those employees responsible for the work in the area of the incident. The incident inv estigation personnel document their findings, develop recommendations to prevent a recurrence, and review the results for resolution. Corrective action taken in response to the investigation findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that reports can be reviewed during future PHA revalidations. Five Year Accident History In accordance with the RMP rule, an accidental release is defined as one associated with an EPA listed chemical that resulted in death, injuries, significant property damage, evacuations, shelter in place, or environmental damage. The Welland Chemical facility has had three reportable accidents in the last five years. These incidents all were of a minor medical nature that required medical treatment. No offsite consequences occurred nor notifications necessary. Emergency Response Program Information The Welland Chemical facility maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, post-incident cleanup and decontamination requirements. In addition, the facility has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees rece ive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to plant processes or other plant facilities. Affected personnel are trained on the changes to the emergency response program. The overall emergency response program for the facility is coordinated with the Local Emergency Planning Committees (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency officials, local government officials, and industry representatives. The facility has around the clock communications capability with appropriate LEPC officials and emergency response organizations (e.g. fire departments). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, facility personnel conduct periodic emergency drills that involve the L EPC and emergency response organizations, and the facility provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. The facility maintains an in-house trained group for initial response for fires or emergencies. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Welland Chemical facility periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three years. The audit personnel develop findings that are reviewed for resolution. Corrective actions taken in response to the audit findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. Trade Secrets None associated with the process. Specific Prevention Steps The processes at the Welland Ch emical facility contain hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to each of the various areas of the facility. 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, the facility has numerous safety features which help contain/control a release, quickly detect a release, and reduce the consequences of (mitigate) a release. The following risk reduction and safety measures are used at the plant: General: * Engineering and construction in accordance with recognized industry standards. * Substance abuse program/Employee Assistance Plan (EAP) * All process modifications reviewed for safety & health impacts. * Regular safety meetings/training (weekly) * Contractor Safety Program (covered previously). * Joint Employee/Management Health & Safety Committee/ plant walk-through inspections. * Material compatibility for plant applications (metallurgy, corrosion) * Handling and disposal of Hazardous and Non-hazardous wastes * A comprehensive Environmental, Health, and Safety Policy Manual Material Release Prevention: * Equipment construction resistant to degradation from chemicals & process conditions. * Equipment properly designed with protection from overpressure * Shutdown devices for critical systems. * Operating systems monitored & controlled 24 hrs by dedicated operator. * Piping systems inspected & tested as part of Mechanical Integrity program. * Frequent unit surveillance by operators. * Routine inspection & testing of instruments, analyzers, & safety interlocks. * Hydrotesting & dye testing of vessels & equipment on a periodic basis. * Testing & inspection of all boilers by state inspectors on a regulated basis. * Vehicular traffic controlled by speed limit and prohibited from entering critical areas. * Limited facilit y access * Anhydrous ammonia unloading hose tested every annually * Preventative Maintenance program. * Piping & Instrumentation diagrams updated for accuracy. * Process Flow Diagrams (PFD) for each process. * Maintain and test storage tanks in compliance with PA Department of Environmental Protection standards. * Daily tank inventory. Release Mitigation: * Dikes and curbing to minimize spreading of released material. * Remotely operated shutoffs to limit release quantity. * Manually operated valves to isolate leaks. * Communication system for daily and emergency operations * Emergency Response Personnel 1. Fire Control and Extinguishment 2. Hazardous Materials Control 3. Emergency Medical Service * Fire Protection Systems * Emergency drills with plant personnel, regulatory agencies, and community emergency responders to enhance response skills and coordination among agencies. * Communication procedure with local emergency responders and regulatory agencies. * Emergency Manageme nt System to manage and coordinate emergencies. * Onsite first aid facility and equipment * Annual emergency training for employees. Planned Changes to Improve Safety The facility personnel resolve all significant findings from PHAs, some of which result in modifications to the process. The following types of changes are planned in future risk reduction projects: * Installation of additional process flow metering and instrumentation equipment. * Improvements in safety systems and safety policies. * Improvement and enhancement of the fire protection system, training and response drills. * Improvement in facility labeling * Improvements in motor vehicle operation, training, and inspections * Improvements to physical plant property * Improvements in personnel protective equipment * Improved action item tracking program * Continue and expand annual Industrial Hygiene monitoring program |