Zeneca Ag Products - Cold Creek Plant - Executive Summary |
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Zeneca Cold Creek RMP Executive Summary Accidental Release Prevention Overall Approach to Safety Zeneca Cold Creek helps people around the world. Our facility makes products which help produce better and healthier foods. We also make products to eliminate pests indoors and outdoors. At Zeneca, Safety, Health, and the Environment are always our top priorities. They are top priorities from product development right on through its final use. This benefits our community, our customers, and our employees. It is the responsibility of Zeneca Cold Creek management to identify and control risks to an acceptable level. We are an accepted part of our community because we strive to meet all relevant laws and regulations so that we can protect the health of all employees and our neighbors, and reduce environmental impact to a practical minimum. We participate in our Lemoyne Industrial Park Community Advisory Panel which is an active and worthwhile panel. We are also active members of the Chemical Manufacturers Association (CMA) Phosgene Panel. We have adopted a "Zero Tolerance" philosophy defined as the level of acceptance the organization has for leaks, spills, and incidents. Zero Tolerance means that we don't accept incidents and injuries as a given. We recognize they are preventable and we are accountable to establish their cause and elimination. Zero Tolerance is a part of our culture. It is accepted proactively, pursued during work activities by every member of the Cold Creek Site. We have worked almost 6 years and close to3.5 million manhours without a Lost Time Injury. Our Toxic Release Inventory (TRI) has been reduced more than 99% since 1992. Corporate Guidelines Zeneca Cold Creek also follows 19 SHE ( Safety, Health, & Environmental) Standards as defined by the Zeneca board in consultation with the Chief Executive Officers of the Business. The 19 Standards are: 1) Safety, Health, and Environment (SHE) commitment 2) Management and Resources 3) Communication and consultation 4) Training 5) Material Hazards 6) Acquisitions and divestments 7) New plant, equipment and process design 8) Modifications and changes 9) SHE assurance 10) Systems of work 11) Emergency plans 12) Contractors and suppliers 13) Environmental impact assessment 14) Resource conservation 15) Waste management 16) Soil and groundwater protection 17) Product Stewardship 18) SHE performance and reporting 19) Auditing Cold Creek Managers have applied these Standards to our daily activities. We are audited by Corporate every 3 years on these Standards. In addition, we evaluate ourselves on these Standards on a yearly basis by providing the Zeneca Board with an annual 'Letter of SHE assurance' which outlines a) Strategic SHE issues on business b) Compliance with legislation & the Zeneca SHE Standards c) SHE performance evaluation over the past year SHE Improvement Plan for the next year SHE Management Structure Process Safety Team 1) Process Safety & RMP Manager 2) Safety and Training Supervisor 3) Industrial Hygienist 4) Fire and Emergency Supervisor 5) Process Safety Training Clerk Environmental Team 1) Environmental Manager 2) Environmental Engineer 3) Environmental Specialist Mechanical Integrity Team 1) Mechanical Integrity Manager 2) Equipment Failure Analyst 3) Critical Piping/Equipment Engineer 4) Critical Piping/Equipment Technician 5) Mechanical Integrity Specialist - 2 6) Mechanical Integrity Engineer 7) Mechanical Integrity Clerk General Accident Release Prevention Rule/Regulations We employ an OSHA Process Safety Management Prevention Plan that : Identifies Hazards by 1) Conducting Process Hazard Analysis of all our processes. 2) Reviewing all Modifications to identify potential hazards 3) Conducting Pre Startup Safety Reviews Controls Hazards by 1) Providing detailed Operating Procedures 2) Training each employee in process overviews and cert ifying that they can carry out the procedures 3) Identifying, inspecting, and testing equipment for proper Mechanical Integrity 4) Maintaining accurate Process Safety Information on chemical hazards, the technology of the process, and equipment design data. 5) Screening and using only Contractors with safe work histories and the informing them of hazards and emergency plans. 6) Maintaining Safe Work Practices by utilizing Hot Work Permits to insure safe work. Emergency Response by 1) Maintaining an Emergency Action Plan that involves the LEPC and the Community in case a release does occur. Auditing by 1) Conduct Incident Investigations on all incidents and accidents to prevent them from recurring. 2) Conducting Compliance Audits of the PSM Program every three years. All this is accomplished using as much Employee Participation in each of the above as possible. We completed all initial process hazard analysis of our processes in 1996 using the Hazop Method which is the most thorough, systematic approach for identifying, evaluating, and controlling the hazards of our processes. Presently, we are in our third year of revalidating the initial Hazard Studies by reviewing and evaluating the initial process hazard analysis, reviewing all modifications to the process, and reviewing all incidents that have occurred since the initial analysis. Teams are used to conduct the studies and findings or recommendations for improvement are monitored. Cold Creek operates an extensive Mechanical Integrity Program. We conduct periodic inspections and tests on piping, vessels, relief devices, rotating equipment, and instrument and electrical equipment. Piping is checked by visually inspecting every flange for corrosion of the flange and the bolts. Alignment and torquing is also checked. Non-destructive testing is performed on the pipe and re-inspection is based on the remaining life of the piping system. Vessels are inspected in a similar manner with the results evaluated against the code requirements and pressure rating of the vessel. Relief devices are inspected, tested based on codes and operational history. Rotating equipment is tested using vibration analysis. Practices important to our Prevention Program Behavior Based Safety Process This Safety Management process involves all employees and focuses on behaviors needed to work and operate safely. It ensures that each employee understands the required behaviors, and then, measures whether the required behaviors are actually used. Required behaviors are re-enforced and at-risk behaviors are discussed on a daily basis. This all occurs before an incident occurs. Central Safety and Health Organization Structure We have 10 Task Groups each with a Leader who reports to the Plant Manager, and members that are both wage roll and salaried employees. Each Task Group has specific Safety and Health responsibilities and meet monthly with the Plant Mana ger to report on their activities. The Groups consist of the following: 1) DELTA - the Behavior Based Safety Group 2) Safety Activities 3) Rules & Procedures 4) Inspections & Audits 5) Safety & Health 6) Fire & Emergency 7) Education & Training 8) Accident / Incident Investigation 9) Housekeeping 10) Process Hazards Plant Safety Committee This Group is composed of 3 Union and 3 Management members who meet monthly and discuss Safety and Health issues. They develop action plans to get issues resolved in a timely manner. Operational Audits We have our Safety and Health Committee Task Groups audit our policies and procedures to determine if we are " doing what our procedures say we should be doing". Cold Creek Facility and Processes Zeneca Cold Creek produces agricultural products designed to help farmers produce more food to meet the world's ever growing demand. Our products are technical, active ingredient pesticides that are sh ipped to other Zeneca sites that put it in a form that the farmer's can use. We have ten separate processes with each producing one or more unique product Three processes use Chlorine directly from 90 ton DOT approved railcars. Phosgene is produced in two processes, and then utilized in six other processes without maintaining any appreciable inventory. Phosphorus Trichloride is another toxic on site that is produced in one process, stored, and then shipped off site. Ethyl Mercaptan, a flammable, is purchased, stored, and used in one process unit. Worst Case Scenarios Chlorine Scenario: 90 ton (180,000 lbs.) liquid Chlorine tank car under pressure catastrophically ruptures, and the entire contents are released to the atmosphere in a 10 minute time period. Model: EPA's offsite Consequence Analysis(OCA) Mitigation Controls Used: None Endpoint: >25 miles Administrative Controls: Railcars are regulated by Department of Transportation (DOT) for tes ting and inspection of the shell and relief devices, Railcars are located in a remote section of the facility. Key Points: It is important to remember that the EPA defined conditions for a WCS are unrealistic because they combine the sudden, complete failure of a railcar with weather conditions that would carry the material as far as possible, assuming all preventive safety systems failed simultaneously. Railcars are designed, constructed, inspected, tested, & marked in accordance with the ASME Boiler & Pressure Vessel Code. They contain 4 inches of insulation and an outer steel jacket. DOT sets the regulations for the shipment, and specifications for the construction of the cars. They are equipped with 375 psig safety valves. The cars are inspected every two years. The cars are located on a dead-end siding, the brakes are set and the wheels blocked. Warning signs are posted that a car is connected. OSHA regulations also require that the rail siding be protected by a derail. Alternative Release Scenarios Chlorine Scenario: 1/4" hole develops in 90 ton liquid Chlorine tank car unloading hose, and 3,160 lbs. are released to the atmosphere in 20 minutes. Model: EPA's offsite Consequence Analysis (OCA) Mitigation Used: Gas Detectors sense leak, Video Monitoring observe leaks. Tank car isolation valves are closed, Securing procedure Automatic isolation valves are closed from remote location, Emergency pipeline evacuation tank is utilized. Endpoint: 0.81 miles Phosgene Scenario: 1/2" hole develops in the vapor tubing connection of the Phosgene process unit, and 284 lbs. are released to the atmosphere in 10 minutes. Model: EPA's offsite Consequence Analysis (OCS) Mitigation Used: Remote flow shutoff to reactor, Phosgene process detectors, securing procedure isolation valves Endpoint: 2.2 miles Key points: Liquid Phosgene equipment is housed inside a sealed building that is vented to a scrubber and then to a thermal oxidizer. Phosphorus Trichloride Scenario: Phosphorus Trichloride loading hose ruptures while filling a tank car, and 6.500 lbs. are released to the atmosphere in 5 minutes. Model: EPA's offsite Consequence Analysis (OCA) Mitigation Used: Remote pump & valve shutoff Endpoint: 0.61 miles Ethyl Mercaptan Scenario: Ethyl Mercaptan feed pipeline develops 1/4" gasket leak on pump discharge for 20 minutes leaking 1400 lbs. into sump. Model: EPA's offsite Consequence Analysis (OCA) Mitigation Used: Remote pump shutoff & valve shutoff Endpoint Burn Potential: 100 ft Key Points: Mechanical Integrity programs require inspections & testing of piping, valves, hoses, and equipment on the Chlorine system on a regular basis. Detailed Procedures to operate the system safely are written and the Operators are trained and certified that they can perform these procedures. All incidents are investigated to prevent recurrence and all changes to the system are reviewed in great detail to identify and contr ol any potential hazards. The process used to determine the Alternative Release Scenarios (ARS) is as follows: 1) Brainstormed potential causes of releases with the workers in each process. 2) Reviewed Accident History of each process 3) Reviewed Hazard Studies for potential release scenario from each process. 4) Condensed the causes into generic categories 5) Performed a Relative Risk Ranking using potential magnitude of release, probability, & mitigation available. 6) Selected most likely scenario 7) Reviewed scenarios with Companies in Mobile County with same chemical to insure consistency. Five Year Accident History Zeneca Cold Creek has had no accidental releases of regulated substances from covered processes that have resulted in deaths, injuries, or property damage on or off site, and none that caused evacuations, shelter in place or environmental damage off site in the last five years. Emergency Response Program Zeneca Cold Creek's Emergency Response Plan is coordinated with the LEPC of Mobile County and with GMIA for Mutual Aid. We have close to 100 Emergency Responders, 30 Medical First Responders, one EMT, and an available nurse on site. Each Emergency Responder receives annual training and is certified at a Certified Fire School. We also have an on site training field. A Mutual Aid drill is conducted yearly with one of the Lemoyne Industrial Park (LIP) sites serving as the host. Table Top and Simulation drills are conducted throughout the year. The Lemoyne Industrial Park sites also have Community Alarms installed throughout the local area to warn the community when to shelter in place or evacuate. Also, we coordinate with a local radio station, WABB, to communicate emergency instructions to the surrounding citizens. Our Emergency Response equipment consists of the following: 1) Fire Truck 2) Hazmat Truck 3) Medical First Responder Truck 4) Foam Eductor Fire Monitor 5) 2 Fire Ponds - 1,200,000 & 400,000 gallons 6) 3 Fire Pumps 7) 75 Self Contained Breathing Apparatus 8) 63 Fire Hydrants 9) 418 Fire Extinguishers Also, detailed Emergency Securing Procedures have been developed for each process detailing the exact procedure to be followed to minimize the amount of a hazardous chemical that could escape to the environment. Drills are conducted throughout the year to assure that operators can perform these procedures on a minimum amount of time. Risk Reduction Activities Leak Prevention 1) Revise piping to reduce number of flanges & other potential leak points 2) Reduced Ethyl Mercaptan fixed storage capacity by 50% 3) Upgraded instrumentation & control valves in Phosgene processes 4) Increased inspection frequency for specific equipment Leak Detection 1) Installed in plant Phosgene monitors 2) Installed perimeter Phosgene monitors 3) Upgraded Chlorine monitors Leak Response 1) Increased Emergency Securing Drills to greater than 80 per yea r These activities are the result of a continuous and on going effort that began many years ago to improve the safety of all of our processes regardless of whether they are covered by OSHA's PSM regulation or EPA's RMP rule. |