Marsulex, Inc. Oregon Refinery Services - Executive Summary
Risk Management Plan Executive Summary |
Marsulex, Inc. Oregon Refinery Services
Accidental Release Prevention and Response Policies
Marsulex, Inc. Oregon Refinery Services is strongly committed to safety. We are deeply committed to the safety of our employees, to the public and to the environment. As a result, we are a member of the Lucas County Local Emergency Planning Committee and actively participate in events sponsored by the Lucas County LEPC. This participation includes attendance at meetings held by the Lucas County LEPC. This participation also includes attendance at special events. During the month of May 1999, Marsulex, Inc. was a proud participant in the community safety awareness events held at the Franklin Park Mall and at the Oregon Fest.
Consistent with Marsulex's commitment to safety and the protection of the environment, Marsulex is also an active member of Responsible Care. This commitment ensures that process operations do not present an unacceptable level of ri
sk to employees, customers, the public or the environment. It ensures that information regarding the hazards of our products is provided to our customers, emergency response personnel and the public. It also ensures an understanding of product hazards, compliance with all legal requirements, sensitivity to community concerns and active assistance with governments and selected organizations to foster and encourage equitable and attainable standards.
Unforeseeably, if an accidental release occurs, despite the rigorous controls maintained by Marsulex, Inc. Oregon Refinery Services, our emergency action plan is fully integrated with that of the Oregon Fire Department. This means that highly trained personnel are continuously ready to control and mitigate all effects of an accidental release.
Marsulex, Inc. Oregon Refinery Services also maintain numerous accident prevention controls that are fully described below.
Description of the Stationary Source and the Regulated Substance
x, Inc. Oregon Refinery Services provides sulfuric acid recycling services. We process used or "spent" sulfuric acid into fresh acid that can then be reused. Oleum, also known as fuming sulfuric acid, is the regulated substance that is present in the oleum process at our facility. Oleum is a mixture of sulfuric acid and sulfur trioxide. The maximum expected inventory of oleum based upon our operational requirements is 1,144,227 pounds. It is used to create products used by most Americans on a regular basis. Oleum is a constituent of laundry detergent and is also used to produce "white oil" and computer chips.
Hazard Assessment Results
To perform the required offsite consequence analysis for our facility, we have used look up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details regarding the scenarios chosen.
The Worst Case Scenario associated with the toxic substance oleum involves a catastrophic release
of 20% oleum due to a storage tank failure. In this scenario, 1,144,227 pounds of oleum are immediately released into the atmosphere. It then forms a pool 1cm high and begins to evaporate. EPA lookup tables predict that the fumes will travel 3.6 miles before the fume concentration in the air will reach a safe level at 0.01 mg/l.
The Alternative Release Scenario associated with the toxic substance oleum involves a release of 3180 pounds of oleum from a loading hose over a ten (10) minute period. EPA Lookup tables predict that the fumes will travel .2 miles before the fume concentration in the air will reach a safe level at 0.01 mg/l. This release is controlled by both active and passive mitigation measures, including neutralization.
General Accident Prevention Program Steps
Marsulex, Inc. is committed to reducing the risk of accidental release of hazardous substances at our Oregon facility. Because the oleum process is subject to the EPA's Risk Management Plan, we take all steps nec
essary to comply with the accidental release prevention requirements for Program 3 processes that are set forth in 40 CFR Part 68 of the EPA. The following sections briefly describe the accident prevention programs in place at the oleum process at our facility.
Process Safety Information
Marsulex, Inc. Oregon Refinery Services maintains detailed records of process safety information to ensure the safe operation of its facility. In general, Process Safety Information pertains to process chemicals, technology and equipment. Process Safety Information describes the chemical hazards, operating parameters, and equipment designs associated with the oleum process. These records ensure that all personnel understand the hazards related to the oleum process. These are accessible to all employees in Process Safety Information binders located in the control rooms and in the lunchroom.
Process Hazards Analysis
Marsulex, Inc. Oregon Refinery Services conducts comprehensive studies to ensure that
all hazards associated with oleum process equipment are identified and controlled. Our qualified team uses the Hazard and Operability Study methodology, also known as the Hazop, to perform its Process Hazards Analysis. This team thoroughly uses its expertise in engineering and process operations to identify process hazards. It makes all recommendations necessary to control the identified hazards. Management is responsible for addressing these recommendations in a timely manner. The Process Hazards Analyses are also made available to all affected employees in the Process Safety Information binders. To ensure that all changes to a process are accounted for, the Process Hazard Analysis is revalidated every five (5) years.
To ensure the safe conduct of activities within the oleum process, Marsulex, Inc. Oregon Refinery Services maintains written operating procedures. These procedures address all stages of operation, from initial startup through emergency shutdown.
Operating procedures are readily accessible to all operators involved in the processes within the Process Safety Information binders located in the control rooms and in the lunchroom. They are also used as a reference tool to train new employees.
To ensure that all employees involved in the operation of the oleum process are competent to operate and maintain that process, Marsulex, Inc. Oregon Refinery Services maintains a comprehensive training program. All employees operating the oleum process prior to June 21, 1999 have been certified as having the requisite knowledge, skill and ability to safely carry out all required duties and responsibilities. Initial training is additionally provided to all new Marsulex employees. To ensure a continued safe operation of the oleum process, Marsulex documents all training provided and also provides refresher training every three (3) years, and more frequently, as required.
To ensure that all oleum process equip
ment functions as designed, Marsulex, Inc. Oregon Refinery Services maintains a comprehensive Mechanical Integrity program. This means that maintenance inspections are regularly performed on the oleum process. These inspections are performed and documented on a variety of process equipment including the Oleum Tower pumps, Oleum Tower coolers and control room alarms. Deficiencies are identified and resolved in a timely manner.
Management of Change
Marsulex, Inc. Oregon Refinery Services has a Management of Change procedure in place to ensure that all changes to the oleum process chemicals, technology, equipment, and procedures are safely managed. Once a change (other than replacement in kind) is identified, that change is documented, reviewed, authorized, tracked and communicated to all affected personnel. All required modifications are made to existing operating procedures and personnel are trained in the revised operating procedures.
Pre-Startup Safety Reviews
As new processes are
commissioned or substantial modifications are made to the existing oleum process, we at Marsulex, Inc. Oregon Refinery Services conduct a Pre-startup Safety Review. The Pre-startup Safety Review is used as a means to ensure that all construction has been completed according to design specifications, that operating procedures have been developed, that training is complete, and that Process Hazards Analysis and/or Management of Change procedures have been followed. Identified deficiencies result in recommendations that are addressed in a timely manner.
Compliance Audits are performed to ensure compliance with the requirements of the RMP Rule. This audit also evaluates whether practices and procedures developed under the rule are adequate and that the practices and procedures developed under the rule are being followed. They are performed every three (3) years by an audit team that is knowledgeable in process operations and engineering. This team is responsible for re
viewing all elements of the Accident Prevention Program. Deficiencies are identified, prioritized, documented, tracked and addressed in a timely manner.
Marsulex, Inc. Oregon Refinery Services maintains a written Incident Investigation program. This program ensures the timely investigation of all incidents that resulted in or could have resulted in a catastrophic release of a regulated substance. Incident Investigations are conducted to identify factors leading to the incident, and all necessary corrective actions are identified, documented, tracked and addressed in a timely manner to ensure that similar incidents do not occur in the future. These reports are made available to all affected employees in the Process Safety Information binders located in the control rooms and in the lunchroom.
In an effort to promote safety awareness, Marsulex, Inc. Oregon Refinery Services has implemented an Employee Participation Plan. As a result, empl
oyees are granted access to all elements of Marsulex's Accident Prevention Program in the Process Safety Information binders located in the control rooms and in the lunchroom. Marsulex employees have been consulted in the development of procedures that ensure compliance with the EPA's Risk Management Plan requirements. Marsulex employees are additionally consulted in the conduct of Marsulex's Process Hazards Analyses, and in all Incident Investigations.
Marsulex, Inc. Oregon Refinery Services maintains controls over contractor employment. These controls include thorough contractor safety performance assessments that are conducted prior to the hiring of contract employees. These safety assessments are also performed on a quarterly and an annual basis thereafter. Marsulex additionally notifies all contract employers of the known potential fire, explosion, and toxic release hazards related to employment, as well as its emergency action plan. Marsulex also electronically mai
ntains a contract employee illness and injury log.
Marsulex, Inc. Oregon Refinery Services maintains strict controls over welding, torch cutting, grinding and all other heat/spark producing activities in oleum process areas. An attending supervisor specifies whether a hot work permit is required on all Work Orders. When required, the attending supervisor specifies the work parameters and precautions that must be taken prior to the commencement of hot work. Hot Work Permits are maintained on file throughout the duration of the hot work performed.
5 Year Accident History
Due to the stringent release prevention controls in place at Marsulex, Inc. Oregon Refinery Services, Marsulex, Inc. has only had one accidental release over the past five years. This accidental release occurred on 10/20/94 and involved a release of 57,799 pounds of oleum due to an equipment failure. Mitigation efforts were taken and the spill was neutralized. Off site responders were immediately notified,
and several evacuations and shelterings in place were issued as a precautionary measure. As a result, there were no known impacts, either on site or off site.
Emergency Action Plan
Marsulex, Inc. Oregon Refinery Services maintains a written Emergency Action Plan to deal with the threat of accidental releases of hazardous materials. Because we actively participate in Lucas County's Local Emergency Planning Committee's Community Emergency Response Plan, Marsulex employees will not respond to releases of regulated substances. However, Marsulex maintains appropriate mechanisms to notify emergency responders when there is a need for an emergency response. Reportable releases will be reported within 30 minutes of discovery of the release. Those releases that pose a threat to the community will immediately be reported to the Oregon Fire Department and to 911.
Planned Changes to Improve Safety
Safety is of primary importance to us at Marsulex, Inc. Oregon Refinery Services and we are de
dicated to continuous improvement within our safety programs. We meet this goal by responding to all developments and findings that result from the implementation and maintenance of these controls.