Hexcel Corporation - Executive Summary |
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Executive Summary Facility Overview Hexcel's Decatur facility manufactures polyacrylonitrile (PAN) fiber that is converted into carbon fiber at a Hexcel facility in Salt Lake City, Utah. Carbon fiber is utilized in many important applications such as commercial and military aircraft structural components, satellites, recreation products (golf shafts, fishing rods and tennis rackets), and infrastructure applications (bridges) and industrial products (air tanks, computer housings, etc.). Accidental Release Prevention and Emergency Response Policies Hexcel Decatur is strongly committed to employee, public and environmental safety. This commitment is the foundation of our comprehensive accidental release prevention program. Hexcel's program covers areas such as design, installation, operation procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated sub stances. For example, our critical control valves are design to "fail" close, meaning in a loss of power or other incident they would close preventing a release. In the unlikely event of a release, we are tied directly to the Emergency Management Association (EMA) who would coordinate an orderly response to minimize the impact. Through the EMA, the Decatur Fire Department would provide emergency response to our site, if necessary. Stationary Source and the Regulated Substances Handled The Hexcel Decatur facility is regulated under RMP due to onsite propane storage being in excess of the 10,000-lb. flammability RMP applicability threshold and onsite acrylonitrile storage being in excess of the 20,000-lb. toxicity RMP applicability threshold. The propane storage system provides fuel for onsite equipment and consists of one storage tank with a maximum capacity of 30,000 gallons (127,200-lb). The acrylonitrile storage system provides raw materials to the process and consists of a s eries of tanks for storage, feed, and recovery. The single largest vessel stores a maximum of 100,000 gallons (684,000-lb). The Worst Case Release Scenario(s) and the Alternative Release Scenario(s) Worst-case and alternative release scenario assessments were conducted for the facility's single largest vessels based on US EPA's Offsite Consequences Analysis guidance. For propane, a vapor cloud explosion scenario was considered for both releases and public receptors were determined to be located within the impact zone of both the worst-case and alternative releases. The resulting worst-case and alternative release impact zones were (0.41) miles and (0.25) miles, respectively. NFPA 58 guidance on restricting the maximum propane inventory stored within a vessel to 88% (at 60F) of the vessels rated capacity is followed at the facility to minimize the potential quantity released in an accident scenario. For acrylonitrile, both release scenarios were considered. Public recepto rs were determined to be located within the impact zone of both the worst-case and alternative releases. The resulting worst-case and alternative release scenarios included passive mitigation (cement dike around the tank), which limited the exposed surface area of the pool and thus reduced the release rate. The impact zones were determined to be (1.70) miles and (0.40) miles, respectively. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps The facility's overall approach and commitment to chemical safety is demonstrated by 1) the existing procedural, training, management and maintenance systems already in place at the facility, and 2) the hazard assessment, prevention program and emergency response provisions implemented specifically for propane and acrylonitrile in response to the RMP requirements. The management structure ensures safety is documented in the facility's RMP and includes compliance with applicable regulations, codes and sta ndards (US EPA 40 CFR 68 and NFPA 58 guidance for propane). The following outline the elements of the release prevention program that are in place at Hexcel Decatur. Hexcel Decatur complies with OSHA standard 29CFR1910.119 (PSM). Process Safety Information Hexcel Decatur maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodologies used to carry out these analyses include Hazop. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of no more than three (3) years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures Hexcel Decatur maintains written operati ng procedures for the purposes of safely conducting activities within our processes. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a shutdown. The information is reviewed at least annually and revised as necessary, and is readily accessible to operators involved in the processes. Training Hexcel Decatur has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is also provided. Mechanical Integrity Hexcel Decatur carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Only q ualified personnel with appropriate training carry out maintenance operations. These personnel receive specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Hexcel Decatur to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Hexcel Decatur. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Audits Hexcel Decatur conducts complia nce audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three (3) years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. We also conduct other safety, environmental, and health audits at least annually. Incident Investigation Hexcel Decatur promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. Employee Participation Hexcel Decatur truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. Hexcel has an active employee sug gestion program were employee ideas are thoroughly reviewed and implemented as appropriate. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, in particular information resulting from process hazard analyses. Contractors Hexcel utilizes trained contractors to conduct select maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Hexcel Decatur has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. Five-year Accident History The Decatur facility has had no RMP reportable accidents/releases of acrylonitrile and propane within the five years preceding RMP submittal. The facility, in fact, has had no releases i n its 10-year history. Emergency Response Plan Hexcel Decatur carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Hexcel Decatur is constantly striving for continuous improvement of all safety programs and processes and will continue to do so in the future. Summary In summary, Hexcel Decatur is dedicated to safe and responsible operation in our community. We have demonstrated this commitment through our excellent record to-date. We strive to prevent releases through proper design, procedures, training, audits, and mai ntenance. In the unlikely event of a release, we are prepared to respond in a safe and orderly manner including notification to the Emergency Management Association to minimize any impact to our plant and the community. |