ICI EXPLOSIVES USA INC - Executive Summary |
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ICI EXPLOSIVES USA INC. JOPLIN, MISSOURI RISK MANAGEMENT PLAN Executive Summary THE FACILITY AND THE REGULATED SUBSTANCES HANDLED ICI Explosives USA Inc. (ICI) has owned and operated the Joplin Site since 1991. The original facility was constructed by DuPont in 1905. Presently, ICI manufactures ammonium nitrate, weak nitric acid and explosives at the Joplin Site. The substances that are regulated under EPA's Risk Management Plan regulations (40 CFR Part 68) are anhydrous ammonia and ammonia solutions. ICI's Joplin Site is subject to both OSHA's Process Safety Management (PSM) and EPA's Risk Management Plan (RMP) requirements. The Joplin Site is a Program 3 facility. RISK REDUCTION POLICIES THE OSHA PSM standard (29 CFR 1910.119), the EPA RMP regulations and ICI's corporate Safety, Health and Environment (SHE) standards, serve to minimize the risks involved in handling, use and storage of anhydrous ammonia, ammonia solutions and other potentially hazardous chemicals. ICI's c orporate SHE policies and requirements promote overall facility, employee, and public safety. These programs enable ICI to minimize the risk and consequences of significant releases of anhydrous ammonia or ammonia solutions. It is ICI's primary policy to operate its business in accordance with all applicable safety, health and environmental requirements and to promote a safe, environmentally conscious workplace. (See www.ici.com). Each employee is obligated to comply with this policy. ICI strives through individual and collective efforts to achieve outstanding safety, health and environmental performance. ICI encourages sharing of ideas between its employees, customers and the public about safety and environmental issues. Specifically, ICI has established a community advisory panel to promote communication and understanding. ICI maintains dialogue with local authorities and communities about safety and environmental incident prevention and preparedness. ICI actively participa tes on the Jasper and Newton county local emergency planning committees (LEPCs) and in a group comprised of various area industries to promote community awareness and to facilitate safety, health and environmental compliance. AMMONIA AND AMMONIA SOLUTIONS Ammonia is used in the manufacture of nitric acid, ammonium nitrate and ammonia solutions (ammonium hydroxide). Ammonia and ammonia solutions are used in explosives manufacturing and in fertilizers. Due to the hazards associated with ammonia, ICI implements certain safety procedures and precautions in order to prevent unnecessary human and environmental exposure, both on the site and in the surrounding community. ACCIDENTAL RELEASE PREVENTION PROGRAM ICI has developed a comprehensive accident prevention program. This program addresses all aspects of plant operation in order to provide controls that prevent errors, failures and inadvertent process changes that could result in an accident. The accident prevention program include s the following elements: * Employee Participation - Employees are involved in establishment of the Process Safety Management/Risk Management program and process hazard analysis. * Process Safety Information - All process safety information is developed, consolidated and maintained. * Process Hazard Analysis (PHA) - PHA studies are performed with a stated scope, purpose and objectives to identify and correct perceived hazards. Issues identified during a PHA study are resolved in a timely manner. * Operating Procedures - Written operating procedures for all aspects of plant operation are developed and employees are trained in their use. Procedures are maintained in an accurate and up-to-date manner. * Training - Personnel who operate, maintain, and supervise the covered processes and chemicals are trained and qualified in their respective areas of responsibility. * Contractors - ICI has developed and maintains an approved bid list of contractors. Only contractors on the Site Approved List perform work on the Site. Periodic audits of contractor performance are conducted. * Pre-Startup Safety Review - Modifications are installed in accordance with approved design standards New procedures are developed prior to startup of a modified facility or equipment. All personnel are trained on the procedures pertaining to their work. * Mechanical Integrity - Critical equipment is identified. Inspection, testing, maintenance and repair schedules are followed. * Hot Work Permit - A permitting system is known, understood, and used by all Site personnel for Hot Work activities. * Management of Change (MOC) - Changes to the system are reviewed and approved to ensure the safety of any change and prevent any unintended consequences as a result of a change. * Incident Investigation - A formal incident investigation system is established and implemented. * Emergency Planning and Response - Emergency planning and response procedures have been developed and all personnel have been trained in their use (including regular practice drills). * Compliance Audits - Compliance with program procedures are verified by audit at least once every three years. All recommendations produced during an audit must be resolved in a timely manner. EMERGENCY RESPONSE PROGRAM ICI's emergency response program is based on OSHA's requirements for emergency action plans (29 CFR 1910.38) and HAZWOPER (29 CFR 1910.120). Employees have been trained for emergency response and an emergency response plan is maintained. The emergency response plan has been supplied to, and discussed with, Duenweg Fire Department, Jasper County LEPC, Jasper County Sheriff's Department, St. John's Hospital, Freeman Hospital, Joplin Fire Department, Carthage Fire Department and Jasper County Emergency Services Board. ICI conducts regular drills for implementation of the emergency plan at the Joplin Site. ACCIDENTAL RELEASE SCENARIO ANALYSES Ammonia in both anhydrous and in certai n solution forms is regulated under both the OSHA Process Safety Management standards and EPA's Risk Management Program. Under EPA's Risk Management Program regulations, facilities using regulated chemicals in sufficient quantities are required to perform analysis of hypothetical "worst-case" and "alternative" accidental release scenarios for regulated substances. Although the likelihood of occurrence of such accidental releases is extremely low, given the stringent internal and industry-wide prevention measures, the conservative modeling results representing such scenarios provides a mechanism for ICI and local emergency planning committees to plan and prepare emergency response and abatement procedures. These emergency procedures are designed to protect the health and safety of plant employees, the surrounding community, and the environment. Planning Scenario #1 EPA's defined worst-case release assumes an unspecified catastrophic failure of the largest vessel resulting in the lo ss of the entire contents during a ten-minute period. This represents an extreme and highly unlikely hypothetical release event, and when considered with other abnormal conditions must be presented as the "worst-case" release scenario. Some of the improbable assumptions, all of which must occur simultaneously to result in the defined worst-case, include: complete failure of all equipment, including safety mechanisms, resulting in the loss of the contents; very stagnant atmospheric and wind conditions resulting in minimal cloud dispersion; high ambient temperature to promote complete volatilization of the chemical; and the complete failure of all emergency systems eliminating the possibility of any mitigation efforts. Three ammonia storage spheres exist at ICI. Each has a holding capacity of one million gallons. One sphere is permanently out of use. Ammonia storage is limited to only one sphere at a time, based on inspection schedules. Administrative controls, including detail ed written operating procedures, trained operators, and daily inventory requirements, insure that the maximum inventory in the sphere does not exceed one thousand tons (or two million pounds). Facility maintenance and inspection programs address the integrity of process and storage vessels, including the ammonia spheres, and largely prevent releases such as these improbable, massive failures. This highly unlikely worst-case event was modeled through SLAB, a publicly available model known to provide reasonable estimates of concentrations and distances associated with atmospheric release events. Utilizing SLAB software, the modeled outcome of such a release would be: Quantity released: 2,000,000 pounds Area potentially affected: A radius of 6.6 miles from the plant Planning Scenario #2 Alternative release scenarios focus on a more feasible, however still unlikely, set of circumstances and events. A hypothetical scenario in which a two-inch railcar transfer hose used to offload ammonia from railcars to on-site storage vessels is accidentally disconnected or severed, represents an alternative release scenario. Although the transfer hose is equipped with an excess flow shutoff valve, this valve is assumed to fail and allowed to release ammonia uncontrolled for a period of one-half hour. Utilizing SLAB software, the modeled outcome of such a release would be: Quantity released: 96,500 pounds Area potentially affected: A radius of 1.14 miles from the plant A system of safeguards that prevent and limit a release of anhydrous ammonia has been developed. This system includes: inspection schedules for transfer hoses, various shutdown mechanisms present throughout the plant and operator intervention. Operators responding to these types of releases have had HAZWOPER training. Appropriate personnel protective clothing, including self-contained breathing apparatus, is readily available. Planning Scenario #3 For ammonia solutions, an alt ernative release scenario could be the hypothetical uncoupling of a two-inch transfer hose that contains 30% ammonia solution which is released uncontrolled for a period of one-half hour. Utilizing SLAB software, the modeled outcome of such a release would be: Quantity released: 55,140 pounds of solution Area potentially affected: A radius of 0.66 miles from the plant The system of safeguards that prevent and limit a release of ammonia solutions includes: inspection schedules for transfer hoses, various shutdown mechanisms present throughout the plant and operator intervention. Operators responding to these types of releases have had HAZWOPER training. Appropriate personnel protective clothing, including self-contained breathing apparatus, is readily available. FIVE YEAR ACCIDENT HISTORY ICI Explosives USA Inc's Joplin Site has had no releases that caused injuries, deaths or significant property damage on-site; or any known injuries, deaths, evacuations, sheltering in place or property damage off-site. On July 26, 1995, an incident occurred involving an accidental release of weak ammonia solution. This release resulted in a fish kill in nearby Grove Creek. The quantity of ammonia released was not a reportable quantity per EPA guidelines. A task force was formed to investigate this incident and make recommendations to prevent similar incidents in the future. PLANNED CHANGES TO IMPROVE SAFETY At ICI, safety improvements are continual and ongoing. Formal process hazard analysis is conducted at least every five years. That, along with the other elements of the prevention program, including management of change, operator training, mechanical integrity and incident investigation, facilitate and highlight opportunities for safety improvements. In addition, employee teams and committees meet regularly and provide a forum to address safety, environmental, training and other important issues. As a result, changes relevant to safety are continuall y being implemented as needs are identified. A project scheduled for completion by the third quarter of 1999 will provide emergency holding capacity for spills in the ammonia receiving and blending area. |