Reilly Industries - Executive Summary |
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Reilly Industries, Inc., (Reilly) located in Indianapolis, Indiana, is a specialty chemical manufacturing company. Reilly is committed to the protection of the environment and to the safety and health of its employees and communities. This commitment incorporates the safe and environmentally sound development, manufacture, distribution, use and disposal of its products. In addition, as a member of the Chemical Manufacturers Association, Reilly has pledged commitment to the Responsible Care Program. The Guiding Principles of Responsible Care, require Reilly to make continuous progress towards the vision of no accidents, injuries or harm to the environment. Responsible Care has six codes of Management Practice, two of which are particularly relevant to RMP. The Community Awareness and Emergency Response (CAER) Code addresses community outreach and emergency response. The goal of the CAER Code is to assure emergency preparedness and to foster community right-to-know. As a result o f the CAER Code, Reilly meets bimonthly with the surrounding neighborhood to keep the neighbors informed on Reilly activities and to discuss any concerns the community may have. Reilly held one of these meetings in April and shared the worse case and alternative case scenario results. The Process Safety Code addresses process safety and, at a minimum, incorporates OSHAs process safety management system regulation. Reilly has been in full practice with all codes of Responsible Care since the end of 1997. The RMP chemicals handled at this plant include anhydrous ammonia, formaldehyde in solution (generally 50%), piperidine, acetaldehyde and hydrogen. This Executive Summary includes a brief description of the overall Accident Prevention Program, the Offsite Consequence Analysis, a Five Year Accident History, and the Emergency Response Program. Finally, the summary includes a brief overview of safety improvement projects. ACCIDENT PREVENTION PROGRAM Reillys accident prevention p rogram is based on both OSHAs Process Safety Management regulation and the Responsible CareR Process Safety Code. Reilly has developed a process safety system for all processes at the plant, including non-RMP and non-OSHA processes. OFFSITE CONSEQUENCE ANALYSIS This Risk Management Plan submittal includes two worse case scenarios and four alternative case scenarios. The worst case scenarios are ammonia, representing the toxics, and acetaldehyde, representing the flammables. The worst case scenarios were evaluated using the EPA Offsite Consequence Analysis guidance and RMPComp. The decision to use EPA documents for the worst case analysis was based on an agreement among industry in our county to keep the analyses consistent. As stated in the regulation, emergency planning should be based off of the alternative case scenarios. Therefore, for the alternative case scenarios, Reilly used the Complex Hazardous Air Release Model (CHARM), created by Radian International in Austin, Te xas. For the chemicals and processes used at the plant, Reilly felt that CHARM would more accurately model the alternative case scenarios. This submittal includes alternative case scenarios for acetaldehyde, ammonia, formaldehyde and piperidine. The alternative case scenario for flammables involved a release of acetaldehyde from a pressure relief device. The amount of material released was based on the amount of time it would take for the device to close. CHARM predicted the valve would close in less than ten minutes. This would result in approximately 14,000 pounds of material released. If the vapor exploded, 1 psi of pressure would be felt a maximum of 350 feet away from the tank, which extends just beyond the fenceline. The storage tanks have manually operated sprinkler systems and remote operated fire monitors. If the pressure became too great in the tanks, these safety devices would be used to increase the rate of pressure reduction. The alternative case scenario for amm onia involves the rail car unloading process. Rail cars of ammonia are unloaded by pumping the ammonia through a flex hose to the unloading station which distributes the material to the tanks. In the alternative case scenario, it is assumed that the flex hose uncouples resulting in a release of ammonia. The unloading of ammonia is constantly monitored by the operators, which ensures a quick response in the event of an incident. The process has a variety of safeguards that help mitigate a potential release. The rail car has an automatic shutoff valve that closes when too much flow is detected. Also, the operators can shut off the pump from an emergency switch in the control room. Finally, there is a check valve in the piping from the unloading station to the tank that prevents the ammonia already in this line from escaping. It was assumed that the release was stopped within ten minutes. Based on the pumping rate, it was estimated that 320 gallons of ammonia would be released. The CHARM model calculated a toxic endpoint distance of 0.65 miles. The formaldehyde alternative case scenario is based off of a real incident that occurred in 1992. Formaldehyde was released when the line from the circulating pump failed. The pump was shutoff from a remote switch in the gear room. Approximately 1800 gallons of material was released from a failed 1 inch stainless steel pipe nipple. After the incident, an investigation team was formed to determine the cause of the release and recommend corrective actions. Evidence and data from the investigation indicated the failure was caused by vibration in the line from the pump. Development of an engineering standard for piping design around pumps, compressors, and any lines where vibration could occur was implemented as part of the corrective action. Operations, maintenance and engineering personnel were trained on the new standard. In addition, all lines in the plant where vibrations were expected to occur were inspect ed, giving priority to those lines close to the plant boundaries. Given the 1800 gallons of material released, CHARM calculated a toxic endpoint distance of 0.21 miles. In the alternative case for piperidine, the process of loading piperidine from the storage tank to a tank truck was evaluated. Specifically, the release involved the uncoupling of the flex hose to the truck. The flex hose employs a quick coupling locking mechanism that is engaged before the pump is started. This minimizes the likelihood of occurrence of this event. However, if this scenario did occur, the loading process is constantly monitored, ensuring a quick response. Based on the pumping rate and the time to stop the release, it was estimated that 375 gallons of material would be released. The toxic endpoint distance calculated by CHARM is 0.21 miles. FIVE YEAR ACCIDENT HISTORY The five year accident history of Reilly includes one incident involving the release of ammonia. This incident occurred in 1996 w hen two maintenance employees were exposed to ammonia while attempting to remove an ammonia pump. Ammonia was not properly purged and was released when the pump was opened. Both employees were sent to the hospital with injuries and ultimately returned to work. Equipment modifications have been made, improved procedures have been written, and increased training has been adopted to prevent this incident from reoccurring. Reilly has had no neighbor injuries or evacuations in the past five years involving any chemical. EMERGENCY RESPONSE PROGRAM Reillys emergency response program includes an emergency response plan that was prepared in accordance with OSHA and RCRA. The plan is coordinated with the Local Emergency Planning Committee. The program includes bringing the Hazardous Materials Response Team of the Indianapolis Fire Department onsite annually for joint training and inspections. In addition, Reilly has a telephone notification system that, in the event of an emergency, wou ld communicate to the neighbors the appropriate protective actions to take. SAFETY IMPROVEMENT PROJECTS Reilly has a few projects that portray its commitment to overall safety. Currently, Reilly is implementing a highly involved workforce (HIW) at the Indianapolis plant. This initiative will help improve safety due to its focus on integrating safety at the operations level. In addition, this past April, Reilly installed an improved emergency notification system called the Community Alert Network. This is the telephone notification system mentioned above. In the past, Reilly relied on the Fire Department to make emergency notifications to the community. Several options were considered, but the telephone notification system seemed the fastest and most efficient mechanism to notify the neighbors in the event of an emergency. Finally, the check valve that was mentioned in the ammonia alternative case scenario was installed as a result of the alternative case analysis itself. Thi s analysis revealed that ammonia already in the pipeline to the tank could be released. A team met to discuss the results and decided that the installation of a check valve would prevent the release of ammonia in this line. In the future, Reilly intends to continue to review all offsite consequence analyses and, where appropriate, initiate changes to mitigate any uncovered impacts. |