Monochem, Incorporated - Executive Summary |
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RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1093 LDEQ Facility ID Number Monochem, Inc. owns and operates a steam generating and electrical and water distribution system to support Borden Chemicals and Plastics (BCP) and Uniroyal facilities located in Geismar, Louisiana. As required by 40 CFR 68.155, BCP is including with the Risk Management Plan Submission the following Executive Summary. Monochem is operated by BCP, and as such the accidental release prevention and emergency response programs implemented at either facility is identical in scope and approach. Accidental Release Prevention and Emergency Response Policies Monochem, in conjunction with the operator BCP, has a long-standing commitment to protection of the health and safety of its employees and the general public. It is Monochem policy to provide the safest workplace possible for our employees while also minimizing to the fullest extent practical any impact on the neighboring community, which includes striving to elimin ate accidental releases. This commitment is demonstrated by the resources invested in accident prevention, such as emphasizing safety in the design, installation, operation, and maintenance of our processes; providing proper training to personnel; having up-to-date operating procedures; and implementing an effective maintenance and mechanical integrity program. Our policy is to implement appropriate controls to minimize the potential for releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release in order to minimize to the fullest extent any possible impact on the neighboring community. Stationary Source and Regulated Substances The Monochem/BCP facility is located in Sections 3, 49, and 50 of Township 9 South, Range 2 East and Section 11 of Township 10 South, Range 2 East in Ascension Parish. The site is approximately 22 miles southeast of Baton Rouge, Louisiana at the intersection of Louisiana Highway s 73 and 30 near the rural town of Geismar, LA. Monochem has been in operation since 1961. Monochem produces steam, industrial waters, and electricity for use by BCP and Uniroyal. The plant uses or produces the following RMP regulated substances in quantities above the threshold quantities listed in 40 CFR 68.130: Toxics: Chlorine Worst-case and Alternative Release Scenarios NOTE: Monochem has numerous controls to minimize the potential for releases and to manage their consequences, however, as required by rule, no credit for administrative controls or passive mitigation measures was taken into account in evaluating worst-case scenarios for toxic substances. Toxic Worst Case Scenario The worst case scenario (WCS) associated with toxic substances at the plant is a catastrophic failure of a one-ton chlorine cylinder, resulting in a release of the entire contents over a ten-minute period. The maximum distance to the toxic endpoint of 0.0087 milligram per liter of chlorine for this WCS is 1.3 miles as determined by using EPA's RMPComp modeling program. The potential population impact by such a release was determined to be 204 based on an enumeration of houses and dwellings within the 1.3-mile area of concern. In addition to residences, a major commercial and industrial area is also potentially impacted. Note that there are no schools, hospitals, prisons/correction facilities, or recreation areas within this area of concern. Toxic Alternative Case Scenarios The alternative release scenario (ARS) for chlorine is a 5-minute release resulting from a piping leak. The quantity released is assumed to be 500 pounds (or 100 pounds per minute release rate). The maximum distance to the toxic endpoint of 0.0087 milligram per liter of chlorine for this ARS is 0.2 miles as determined by RMPComp. While this scenario reaches off-site, there are no public receptors located within the modeled area of concern. Accidental Release Prevention Program and Chemical Specific Prevention Steps The following is a summary of the general accident prevention programs in place at Monochem's Geismar facility. Because the processes at the plant regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation Monochem, through its operator BCP, has its employees participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees are involved in the writing of procedures and development of the training materials that accompany them. Employees have access to all information created as part of the plant accident prevention program. Specific ways that employees are involv ed in the process safety management program are documented in an employee participation plan that is maintained at the plant and addresses each process safety program element. In addition, the plant has a number of initiatives under way that addresses process safety and employee safety issues. Teams made up of employees and contractors meet on a regular basis to review and develop safety procedures, training programs, emergency response procedures, investigate process safety related incidents and report to the plant management safety team. Process Safety Information Monochem has a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information. Employees have been advised of the location of the process safety information and trained in how to use the information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known hazards such as those associated with the inadvertent mixing of chemicals. 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 process are not compromised. Process Hazard Analysis (PHA) Monochem has a comprehensive program to ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify potential process safety hazards and ensure that adequate controls are in place to manage these hazards. The facility primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted by a team comprised of individuals who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures. Suggestions for additional prevention and/or mitigation measures are made when the team finds such measures are necessary. To ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, Monochem, through its operator BCP, updates and revalidates the hazard analysis results at least once every five years for the life of the process. The results and findings from these updates are documented and forwarded to manag ement for consideration, and the final resolution is documented and retained. Operating Procedures Monochem maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) shutdown, and (4) initial startup of a new process. Temporary and emergency operating procedures are developed for each case prior to commencement of the operation. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. Procedures are reviewed annually. Training Monochem, through its operator BCP, has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in both safety issues and plant operations. After successfully completing this training, a new o perator is paired with a senior operator to learn process-specific duties and tasks. After an operator demonstrates (e.g., through tests, skills demonstration) adequate knowledge to perform the duties and tasks in a safe manner, the operator can work independently. In addition, all operators receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least once every three years. All training is documented for each operator, including, the means used to verify that the operator comprehended the training. Contractors Monochem, through its operator BCP, routinely employs contractors to work on or near process equipment. Additional contractor work force is present during periods of increased maintenance or construction activities. Contractors are provided both plant-wide and unit-specific training using computer based training programs. The program includes a written test that requires an 80% passing score. In addition, craftsmen must complete the eight-hour safety-training program for industrial workers provided by industry through the local safety council. The training is maintained through annual refresher training. The long-term contractors participate as members of the safety teams tasked with the development of procedures, audits, accident investigation and training. Additionally, Monochem, through its operator BCP, also provides monthly safety training for the contractor supervision. In addition to the safety training, procedures are in place to ensure that contractors perform their work in a safe manner; 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; and inform plant personnel of any hazards that they find. Each contractor employee is provided with a process overview and information about saf ety and health hazards, emergency response plan requirements, and safe work practices prior to beginning work. Plant personnel monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSR's) Monochem conducts a Pre-Startup Safety Review (PSSR) for any new facility or major facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that necessary training, safety features, procedures, and 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. The PSSR review team uses checklists to verify all aspects of readiness. 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 Monochem, through its operator BCP, has well-established practices and procedures to maintain 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: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) 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 (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is perfor med in a consistent manner and provide a basis for training. Inspections and 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, as appropriate, or Management will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment until the actions are completed. Another integral part of the mechanical integrity program is quality assurance. Monochem, through its operator BCP, incorporates quality assurance measures (e.g., purchasing specifications and inspection procedures) into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices Monochem has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (2) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (3) a permit and procedure to control spark-producing activities (i.e., hot work), and (4) 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 Monochem has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure t hat adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, and equipment information, as well as procedures and drawings are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. The management of change program is designed to allow anyone in the system, operations or maintenance, the ability to initiate a MOC. Employees have been trained concerning the various elements that would constitute a change such as parts, procedures, operating conditions, etc. The change form provides an abbreviated version of the pre-startup review. Management of the documents and approval to proceed are controlled at the department level. Incident Investigation Monochem promptly investigates all process safety related incidents. The goal of each investigation is to determine the facts and develop c orrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. When necessary, short-term interim measures are taken until the permanent fix is implemented. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained on file for at least five years to supplement the hazard analysis records for the affected areas, and are reviewed during PHA's and PHA revalidations. A team of employees are permanently tasked with identifying opportunities to improve the investigation system for the over all benefit of Mon ochem and associated industries. Compliance Audits To help ensure that the process safety program is functioning properly, Monochem, through its operator BCP, periodically undergoes an audit to determine whether the procedures and practices required are being implemented. Compliance audits are conducted at least every three years. Both hourly and management personnel participate in the audits. The audit team develops findings that are forwarded to the plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained on file. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at Monochem have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the facility. Collectively, these prevention program a ctivities help prevent potential accident scenarios that could be caused by equipment failures and/or human errors Five-year Accident History There have been no RMP related accidents at Monochem during the past five years. Monochem investigates every incident that meets RMP criteria very carefully to determine ways to minimize the potential for similar incidents from occurring in the future. While our goal is to eliminate the occurrence of such events, Monochem recognizes that they may occur and therefore we also work to ensure proper response to minimize and mitigate any potential impact on our employees and the neighboring community. Emergency Response Program Monochem, through its operator BCP, maintains a written emergency response program to protect workers 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 accid entally 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, and post-incident cleanup and decontamination requirements. In addition, the plant 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 receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is reviewed annually and updated when necessary based on modifications made to plant processes or other plant facilities. Emergency response program changes are administered such that informing and/or training affected personnel is accomplished prior to implementation of the change. The overall eme rgency response program for the Geismar facility is coordinated with the Geismar Area Mutual Aid (GAMA) network which is comprised of local industries and the Ascension Parish Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Geismar facility has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response. In addition to periodic GAMA meetings, the Geismar facility conducts periodic emergency drills. Planned Changes to Improve Safety The Geismar facility addresses each recommendation resulting from process hazard analyses. Some recommendations result in modifications to the process. At present there are no changes envisio ned, however, Monochem will continue to evaluate our systems to identify any improvements in our safety systems. |