Titanium Metals Corporation - Executive Summary |
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Titanium Metals Corporation (TIMET) RMP Executive Summary & Prevention Program Summary EPA Identifier #: 1000 0007 2404 BAR CODE #: MRM-1999-2-006853-7 Table of Contents 1.0 TIMET Henderson Facility RMP: Executive Summary 1.1 EPA RMP and the Nevada CAPP program 1.2 Facility Description and Covered Processes 1.3 TIMET's Approach to Safety 2.0 TIMET Hazard Assessment Results 2.1 Offsite Consequence Analysis (OCA) Summary 2.1.1 Worst Case Scenario 2.1.2 Alternative Release Scenario 2.2 Five Year Accident History 3.0 TIMET Henderson Facility Prevention Program 3.1 Safety Information 3.2 Process Hazard Analysis 3.3 Operating Procedures and Safe Work Practices 3.4 Training 3.5 Maintenance 3.5.1 Mechanical Integrity Training 3.6 Incident Investigation 3.7 Compliance Audits 3.8 Chemical Specific Prevention Steps 3.9 Additional Prevention Programs 3.9.1 Employee Participation 3.9.2 Contractor Safety 3.9.3 Management of Change 3.9.4 Pre-Startup Safety Reviews (PSSRs) 4.0 Emergency Response Program Summary 5.0 Management Systems ************************************************************************************** 1.0 TIMET Henderson Facility RMP: Executive Summary The federal Risk Management Program (40 CFR Part 68) requires Titanium Metals Corporation (TIMET) to submit a Risk Management Plan (RMP) for any processes containing regulated substances above threshold quantity (TQ) at the Henderson Facility. The TIMET Henderson, Nevada, Facility (the Facility) handles hazardous materials onsite, and recognizes a responsibility to safely operate the Facility in order to protect the surrounding community, employees, contractors, and the environment. TIMET has taken a proactive stance to promote the overall safe operation of the processes, with programs to prevent accidents fr om occurring, planning for emergencies, and maintaining the equipment needed if an emergency does occur. The RMP is a document that formalizes existing programs and procedures so that these programs may be reviewed more efficiently. The RMP consists of two parts required for submittal: - RMP Executive Summary, Prevention Program Summary, and Management System - RMP Data Elements The RMP effort at the Facility was divided into three steps. First, the Facility determined which processes were covered by the RMP Regulation. The results of this study are published in the report titled "Maximum Inventory Determination." Located at the facility. The inventory determination measured the quantities of regulated substances to determine which processes are subject to RMP. Next, the Facility conducted the required Hazard Assessment as defined by 40 CFR Part 68. The Hazard Assessment modeled accidental release scenarios that provided TIMET and the local emergency responders insight about the potential for onsite processes to affect the surrounding community and the environment. A summary of the Hazard Assessment is provided in Section 2. Finally, a summary of the RMP effort is provided in this document. It contains the Executive Summary, a synopsis of the Prevention Program, and an organizational chart of the Management Systems in place to implement and maintain the Facility's risk management measures. The Executive Summary and Data Elements are submitted to Local Emergency Planning Committee (LEPC) and the Federal EPA as part of the Risk Management Plan requirements. 1.1 EPA RMP and the Nevada CAPP program The Federal RMP regulation specifies three program levels based on the hazards of the processes and the degree of compliance program required. Under the Federal EPA RMP regulation, the TIMET titanium production process is subject to Program Level 2 for titanium tetrachloride. Under the separate, but similar, Nevada CAPP program, the TIMET titani um production process is subject to Tier A Program Level 3 for titanium tetrachloride and chlorine. As such, TIMET has complied with most stringent requirements of both programs, which meets with the RMP Program Level 3. Therefore, for the purposes of streamlining the required submission documents for both agencies, TIMET is submitting as Program Level 3 for the Federal RMP Submission, for titanium tetrachloride. A separate submission document will also be supplied to the Nevada Department of Environmental Protection for the Tier A Program Level 3 processes for titanium tetrachloride and chlorine. 1.2 Facility Description and Covered Processes The TIMET Henderson plant produces titanium metal sponge and ingots. The Facility is divided into five main process areas: Titanium Tetrachloride Production; Titanium Tetrachloride Storage; Titanium Sponge Production; Titanium Ingot Production; and Magnesium Recovery. The principal materials produced at the TIMET facility include t itanium tetrachloride (TiCl4), titanium sponge, titanium fines, titanium ingots, and neutralized leach liquor (magnesium chloride concentrate). Principal raw materials used at the facility include chlorine, petroleum coke, magnesium and rutile. TIMET operates 24 hours per day, seven days per week. The facility produces titanium sponge and ingots from rutile (primarily titanium dioxide) by a series of chemical processes, which include chlorination, purification, reduction with magnesium metal, and vacuum distillation. The titanium sponge (so named because of its appearance) is crushed, pressed into compacts and then melted into ingots in vacuum arc remelt furnaces. In the Titanium Tetrachloride Production Unit, titanium tetrachloride (TiCl4) is produced by reacting rutile ore with chlorine. Chlorine and titanium tetrachloride are the two listed substances which are required to be reported in the RMP. The resulting TiCl4 is purified and is either stored in the Titanium Tetrachl oride Storage Unit or sold and shipped offsite in railcars and tank trucks. To make titanium, the TiCl4 is reduced in the Vacuum Distillation Process Unit using magnesium to yield a raw titanium sponge and magnesium chloride. The solid titanium sponge is further processed into titanium ingots. The magnesium chloride is processed to recover the chlorine and magnesium for reuse in the process in the Magnesium Recovery Unit. TIMET also operates an ingot plant, which consists of blending, welding and ingot melting operations. There are also areas for storing raw materials and products, scrap reclamation, transportation and maintenance operations that support the manufacturing process, a quality assurance laboratory and administrative offices. The Henderson Technical Laboratory (HTL) is also located within the main plant area, south of the manufacturing facilities. HTL conducts various testing and developmental work associated with titanium production. Titanium tetrachloride a nd chlorine are regulated substances, each with RMP threshold quantities of 2500 pounds. The maximum inventory calculation determined that only titanium tetrachloride is handled in amounts greater than the threshold quantity. The process units within the titanium tetrachloride process, which is subject to RMP Program Level 2, are the Chlorination Unit, Titanium Tetrachloride Purification Unit, Titanium Tetrachloride Storage Unit, and the Vacuum Distillation Unit. TIMET recognizes its duty to also ensure the safe handling of chlorine and titanium tetrachloride, and therefore the Prevention Program is generally applied to all areas of the facility handling chlorine, including titanium tetrachloride production and storage. 1.3 TIMET's Approach to Safety TIMET places a priority on the safety of its employees and contractors, and the wellbeing of the surrounding community and the environment. TIMET is compliant with the State of Nevada's Chemical Accident Prevention Program (CAPP) requirements, NRS 459.380 through 459.3874 of the Nevada Revised Statutes (NRS). This program is similar in structure to the OSHA Process Safety Management regulation (29 CFR 1910.119), and the Prevention Program portion of the RMP. Compliance with the Nevada CAPP program is directed by the Plant Manager, and is upheld by the individual engineering, operations, safety and environmental department managers. The person responsible for the implementation of the CAPP program, the Manager of Environmental Affairs, is also responsible for the compliance to the RMP regulation. This organizational structure ensures complete and efficient compliance with both regulations. The Manager of Safety is responsible for implementation of Safe Work Practices and the Emergency Planning and Response Program. Both of these programs are part of the Nevada CAPP and RMP programs. A Safety Committee comprised of operations, maintenance, engineering and safety department personnel ensure that the Safe Work Practices and Emergency Response procedures are uniformly followed plant wide. This ensures that operations staff with the opportunity to work in multiple process units follow the same set of safe practices standards. TIMET is also certified to comply with the ISO 9002 standard to ensure quality products. The same management systems that apply to processes that affect product quality are also generally applied to all processes and operations. This broad-based application of a single management system ensures that all operations are continually evaluated and improved. ************************************************************************************** 2.0 TIMET Hazard Assessment Results 2.1 Offsite Consequence Analysis (OCA) Summary The objectives of this hazard assessment are twofold: (1) satisfy the requirements of the RMP Regulation and Nevada CAPP and (2) provide OCA information that will help local emergency planning officials improve community emer gency response in the event of an accidental release at the facility. The Facility is providing one alternative release scenario and one worst case scenario for the regulated toxic substance (titanium tetrachloride) held in the covered processes. RMP has provided the levels of concern (LOC) for certain regulated substances that have the potential to be carried offsite during a release. For regulated substances where Emergency Response Planning Guidelines (ERPG) values have been established, RMP requires that the ERPG-2 value be used as the level of concern. Since ERPG-2 values are available for titanium tetrachloride, it was selected as the LOC to be applied in this study. 2.1.1 Worst Case Scenario For the toxic WCS, the hazard assessment determined the potential downwind impact zone to a LOC of 0.02 mg/L (ERPG-2) for titanium tetrachloride using the most pessimistic weather conditions and the EPA- mandated release rates. EPA requires facilities to present Worst Case Scenario s regardless of site conditions, administrative and actual mitigation measures in place at the facility. The worst case scenario was the rupture of the largest vessel, a TiCl4 storage tank, containing the maximum amount of titanium tetrachloride. The storage tanks are contained in a diked area, which minimize the pool area of any release. This reduces the evaporation rate of the material, and therefore minimizes the release rate. The worst case scenario release does not go beyond the TIMET plant boundary, and does not have the potential to reach any offsite receptors. The distance to the LOC was calculated using a commercially available software program, BlazeTech - ADORA. This model was communicated to the Clark County LEPC as an alternative to using the RMP- supplied lookup tables. Even though the worst case scenario does not impact any offsite receptor, the worst case scenario is still very unlikely to occur. TIMET restricts access to the facility, and all visitors to the facility must receive the appropriate contractor safety training before access is permitted. TIMET also limits the vehicle traffic on site, and posts safe driving limits to reduce the likelihood of a vehicular impact with process equipment. TIMET operates the process equipment to the codes and standards to which the equipment was built, and routinely inspects and tests all process equipment per the appropriate codes, standards, and best engineering practices. 2.1.2 Alternative Release Scenario TIMET has modeled Alternative Release Scenarios (ARSs), to identify release scenarios that may have a higher likelihood of occurrence. The Alternative Release Scenarios allow the facility to present scenarios that assume the use of administrative and actual controls in place at the facility. The results of the hazard assessment show that for the toxic ARS, the downwind impact zone to a LOC of 0.02 mg/L (ERPG-2) for titanium tetrachloride does not have the potential to reach an y offsite receptors. The BlazeTech - ADORA model was also chosen to calculate the ARS scenarios. Several scenarios were chosen from each unit for further investigation. The scenarios included actual incidents and near misses from the facility, as well as scenarios identified in the Process Hazard Analysis studies as possible to reach an offsite receptor. The Alternate Release Scenario chosen for submission for the RMP program is considered to be possible, but mitigation such as process instrumentation and alarms, operator training, equipment and piping inspection, maintenance programs, and standard operating procedures greatly reduce the likelihood of this scenario occurring. Additionally, building enclosures and emergency response procedures at TIMET prevent this scenario from resulting in an offsite impact. 2.2 Five Year Accident History The RMP rule requires facilities to compile a 5-Year Accident History for all RMP regulated substances in covered processes at the Facility. As part of the ongoing Nevada CAPP Program, the Facility documents and tracks all incidents and near misses that occur within the Facility. RMP requires facilities to report any incident from a covered process involving a regulated substance and resulting in any of the following: - Onsite deaths, injuries, or significant property damage - Offsite deaths, injuries, property damage, evacuations, sheltering-in-place, or environmental damage To date, there are no accidents relating to titanium tetrachloride at the Facility in the past 5 years that fall within the criteria. ************************************************************************************** 3.0 TIMET Henderson Facility Prevention Program The following is a summary of the general accident prevention program in place at the TIMET Henderson Facility. The Prevention Programs required for Program Level 2 facilities are as follows: - Safety Information - Process Hazard Analysis - Operating Procedures - Maintenance - Incident Investigation - Compliance Audits Because processes at the Facility that are regulated by the EPA RMP regulation are also subject to the Nevada CAPP standard, these prevention programs were already implemented at TIMET to comply with the CAPP standard. The CAPP standard for the TIMET facility requires the development of Prevention Programs similar to that of the RMP Program Level 3. Therefore, although not required by RMP, TIMET has also implemented the following programs: - Management of Change - Pre-Startup Safety Review - Employee Participation - Hot Work Permit - Contractor Safety This summary addresses each of the RMP Program elements and describes the management system in place to implement the accident prevention program. Each section below contains a brief summary of the prevention program elements. 3.1 Safety Information The Facility provides complete and accurate information concerning all covered processes. This information i s essential for having an effective process safety management program and for conducting thorough process hazards analysis. This includes information regarding process chemicals, process technology and process equipment. General guidelines are as follows: - Key process safety information is kept in a central location within the facility, however clear ownership exists for making sure the information is current, accurate and kept up to date through the management of change process. This includes a system for document management and controls. - Process unit process safety information is typically contained in the both the unit operations files and the central engineering files. - The process safety information is available to all employees either electronically or in hard copy form upon request. - Written process safety information is required for each of the three process safety categories. At this facility, these include process chemicals, process techno logy and process equipment. - Process chemical information: Process chemical information includes: toxicity, permissible exposure limits (PELs), physical data, reactivity data, corrosivity data, thermal and chemical stability and the potential effects of accidental mixing of different chemicals. This information is nominally contained in MSDS records. - Process Technology Information: Process technology includes block flow or simplified process flow diagrams, process chemistry, maximum intended inventories and safe upper and lower limits for key process variables. Also, an evaluation is required for the consequence of deviations. This information is nominally contained in the Unit Process Flow Diagrams. Consequences from deviating from the operating limits were discussed in the unit PHAs, and are clearly documented in the Standard Operating Procedures for each unit. - Process Equipment Information: Process equipment includes pressure vessels and storage tanks, piping systems including valves, relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices, sensors, alarms, and interlocks) and pumps. This information is nominally kept in the process and project engineering files, and the maintenance and inspection files. As reference, the information required for process equipment includes: materials of construction, piping and instrumentation diagrams, electrical classifications, relief system design and design basis, ventilation systems, design codes and standards used, and safety systems (interlocks, detection or suppression systems). This facility assures that existing equipment still utilized that was originally designed to previous codes, standards and practices no longer in use, is considered safe to operate based on either (1) successful prior operation, (2) documentation that the equipment meets current codes and standards or by (3) performing an engineering analysis. To verify this fact, a strenuous inspection/testing program is being performed in accordance with the applicable codes and standards. Key Process Technology definitions are: - Process chemistry - This information describes the intended chemical reactions needed to generate the products. It will typically include a description of the feedstocks, chemical equations, process conditions affecting chemical reactions and whether the reactions are endothermic or exothermic. This information is included in Process Engineering Files and the Project Engineering Files. - Maximum intended inventories - This is the total volume of the vessels and piping in the affected process system. The working inventory of the large vessels is calculated rigorously; however, the volume of the piping, pumps, etc. is assumed to be 20% of the vessel volume. This information is kept with the RMP Coordinator. - Safe upper and lower limits - The PSI limits are the maximum equipment limits that cannot be exceeded or violated without consequence. Operating beyond the safe operating limits requires a Management of Change request (MOC). This ensures that appropriate engineering reviews are performed to determine if it is safe to operate at the new limits. The Safe upper and lower limits is documented on the Piping and Instrument Diagrams, the Standard Operating Procedures, and in the Nevada CAPP Assessment of Risk through the Analysis of Hazards reports for each unit. - Consequences of deviation - This effort clearly identifies the consequence of deviating outside the PSI limits. These actions are normally identified during the development of the process hazard analyses, and are documented in the Standard Operating Procedures. Key process equipment definitions are: - Materials of construction - This is typically information that shows which materials were used . - Relief system design and design basis - This is information that provi des the rationale for providing safety relief valves (PSVs) at certain locations, the selection of the size of the relief valve, the establishment of PSV setpoints and criteria used in designing the inlet and outlet piping of the PSV. - Ventilation system design - This is information such as airflow calculations and equipment sizing calculations. - Design codes - This is information that references the codes and standards used to form the design basis of the process. This is a combination of industry standards and facility specific standards. Some of the more common codes used are ANSI, ASTM, NFPA, and ASME. - Safety systems - This is information that fully describes all of the safety systems at the facility. This includes control interlocks, relieving control valves, hazardous disposal systems such as flares, deluge and spray systems and ambient detectors. The process safety information is already in place for existing processes or is developed a ccording to the CAPP/RMP guidelines for new processes. The preparation of materials for the process hazards analyses by the PHA team leader will identify any shortcomings in information. The PHA team will then initiate a request for generating the deficient information to assure that the PHAs are completed properly. Updating of documents is completed through the established management of change request process. This assures that the process safety information is always current. Each area manager is responsible for their area Process Safety Information. 3.2 Process Hazard Analysis TIMET has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each covered process unit is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The PHA team identifies and evaluates hazards of the process as well as accident prevention and mitig ation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. TIMET 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 and is accepted by EPA, OSHA, and Nevada Dept of the Environment.. Other techniques utilized less frequently are What-If or Checklist Analysis. All areas of the Facility covered by the regulation are subjected to a hazard evaluation. The evaluation identified and evaluated the hazards involved in the process. The hazards will be controlled based on the extent of the hazards, the number of potentially affected employees, the age of the process, and the operating history of the process. Hazard evaluation methods are selected based on the complexity of the process to be analyzed and the purpose of the analysis. The methodology for new facilities will be selected based on the nature of the hazards involved, and the complexity of the process. All hazard evaluations include: - Identification of process hazards - Review of previous incidents that had a potential for catastrophic consequences in the workplace. - Review of procedures, process monitoring and control instrumentation including alarms and detection hardware. - Determine the consequences of the failure of equipment and control instrumentation. - Evaluate the level of safeguards present to prevent, detect, or mitigate the identified hazards - Review facility siting. - Review the consequences of human error - Review of global occurrences or events, such as power failure, earthquake, or vehicle impact. The process hazard analysis are be performed by teams of individuals with knowledge and experience in process operations, safety and design. The team leader will be knowledgeable in the specific methodology being used. The team's findings a nd recommendations will be assigned a level of potential risk, given a prompt management review, assigned a priority, given an expected completion date, assigned to a person responsible for completing the necessary action and then entered into the facility tracking system. At five-year intervals, each hazard review will be updated and revalidated by a team. All Incident Reports, Management of Change requests, and Capital Projects since the last evaluation will be reviewed as part of the revalidation process. The Environmental Manager is responsible for process hazard analysis, and the timely completion of study recommendations. 3.3 Operating Procedures and Safe Work Practices The Operating Procedures Element develops and implements written operating procedures that provide clear instructions for safely conducting activities in each covered process. The tasks and procedures must be appropriate, clear, consistent and communicated with the employees. This program is designe d to satisfy the Nevada CAPP regulation, RMP Requirements, and meet all parts of the Compliance Guidelines CPL 2-2.45A. Operating procedures are the responsibility of the Departmental Managers. General guidelines are as follows: - The operating procedures address steps for each operating phase, operating limits, safety and health considerations and safety systems and their functions. - The operating procedures are consistent with the process safety information regarding the process equipment. - Employees are involved in developing and reviewing the procedures. - All procedure modifications require a Management of Change request - All new procedures require a Pre-Startup Safety Review - The procedures are easily accessible for all affected personnel. Document management practices are used to control all paper copies to ensure each distributed document is the most recent version. The procedures developed include the following brief summaries to define what the se terms mean at this facility. The following are typical applications but do not limit the application of the rule to these examples and definitions: - Initial startup - Include commissioning of a new facility or system or for a facility that has undergone major changes. - Normal operations - Includes procedures for a facility or system that is operating within the safe operating envelope for temperature, pressure, etc. per engineering criterion. - Temporary operations - Includes a controlled change to normal procedures that can be used to satisfy a maintenance or operational requirement. - Emergency operations - Includes procedures that are required to avoid, prevent, minimize control or contain a condition that would otherwise become critical or threaten safe operations. This will include, but not limited to troubleshooting procedures for loss of air, electrical power, cooling water and steam, uncontrolled reaction, etc. - Normal shutdown - Includ es, but is not limited to, shutdowns for a turnaround, to repair a specific problem, to put a unit into a safe holding point or standby mode until feed can be reestablished, etc. - Startup - Includes procedures to start up after a turnaround, take the unit from a standby to operating mode or to start up after an emergency shutdown. The procedures follow a specific format to assure that the intent of the regulation is clearly met in the areas of operating limits, safety and health considerations and safety systems and their functions. Specific features contained in the procedures are: - A specific purpose and numbering system to uniquely identify each procedure. - Clear health and safety considerations and required references to MSDS information. - Cautions, notes, and warnings to clearly identify deviations or hazards that could cause personnel injury or equipment damage. Recommended steps to take to avoid or react to these deviations. - Inclusion of safety syst ems and instrumentation. The procedures are developed and reviewed by individuals experienced in the process involved. Specifically the review sequence is as follows: - An experienced individual, such as a Foreman or Process Engineer, writes the draft procedure. The procedure follows standard TIMET format. - The procedure is submitted to an Operator, Foreman, Safety Manager, Environmental Manager, or other affected persons for review - Final comments are included, as appropriate, and the procedure is issued as revision 0. Any changes to the procedure fall under the authority of appropriate Area Supervisor or Department Manager. - The managers who are responsible for authorizing procedures are: Safety Manager, Environmental Manager, Process Engineering Manager, Quality Manager, and the appropriate Department Manager. - Training on the new or revised procedures follows facility training guidelines. Continual feedback is supplied from the operators to the Foremen, Area Supervisors, or Department Managers as procedures are used and deficiencies or ambiguities are found. This action takes place through verbal and/or written means. Periodic auditing of procedures is conducted by the Department Manager or a delegate and documented to verify the procedure accuracy. This effort also identifies any additional training needs. Typically, this auditing is performed during the normal course of daily activities and does not require any additional or practice procedures. However, annual reviews are performed on operational departmental SOPs to ensure accuracy and compliance to the Nevada CAPP and RMP regulations. TIMET provides a safe and healthful work place for the workers at the Facility, contractors, visitors, and the community surrounding the Facility. Safe work practices are in place to ensure that common hazardous activities are conducted safely and routinely. These procedures (and others), along with training of affected person nel and contractors, form a system to help ensure that operations and maintenance activities are performed safely. Examples of standard safe work practices at TIMET include: Forklift Operation Worksaver Operation Confined Space Entry Lock, Tag & Try Employee Orientation Visitor Policy Respiratory Program Personal Protective Equipment Fall Protection Hazard Identification Management of Change Incident Investigation Line Opening/Breaking Pre-Startup Safety Review Hot Work Permit Contractor Safety Program Bloodborne Pathogen Hazard Communication Program Work Permit Policies & Procedures In addition to the Safe Work Practices listed above, TIMET conducts regular inspections to ensure compliance with Federal, State, and local regulations, and Company loss control requirements. 3.4 Training The intent of this element is to ensure that the materials processed in this facility are handled in a consistent and safe manner. This is accomplished by having well trained operators. An effective training program will help operators understand the nature and causes of problems arising from the process operations and will increase the employee's awareness with respect to the hazards of a particular process thereby preventing unplanned catastrophic incidents. The TIMET Training Department has developed and maintained a comprehensive training program that provides operators with the materials and instruction necessary to ensure that the process units are operated in a safe, efficient and environmentally sound manner. The Training Coordinator has overall responsibility for the training program. TIMET conducts training to ensure that employees have the knowledge, skills, and ability to perform their tasks safely and effectively. The Training Program outlines the requirements and responsibilities for establishing training needs, developing training plans, conducting training, and keeping training records. In general, the training program covers: - Employee Orientation - Process Overview - Indoctrination - Safety & Health - Area Specific - Job Specific - Emergency Response - Plant Fundamentals - Certification - Management of Change - Refresher Training - Annual Training Plan - Trainer Qualifications/Responsibilities - Plant Training Annual Review. All training utilize positive feedback to assure the employee has a good understanding and has comprehended the training provided. This shall be achieved through both objective and subjective assessment. TIMET maintains records of training, as well as the means used to verify that the employee understood the training. The following is a summary of the operator training program. The following approach is used to meet the PSM and RMP standards and to adhere to industry and facility polices: - Fundamentals Training: This training program is completed for all new operators. Included in the curricula is instruction on (1) the facility organization, (2) general safety, health and environmental standards, (3) general facility rules, (4) process fundamentals, (5) facility process equipment and, (6) overall facility operation. - Process Specific Training: This training is to provide new or experienced operators with the knowledge necessary to master the job duties specific to the operator's job assignment. This training is accomplished through the use of an operator training guide which includes modules on (1) Introduction and daily rounds, (2) Unit Safety, (3) Unit process overview, (4) Specific unit equipment, and (5) Emergency Procedures. - Job Specific Training: This training is to provide new or experienced operators with the skill to master the job duties specific to the operator's classification. This includes training on all relevant operating procedures necessary for them to safely and effectively perform the duties associated with their specific job assignment. - Refresher/Requalification Training: This training is designed to maintain the qualified operator's knowledge at a level that assures the operator's duties are performed in a safe and effective manner. This is accomplished through review of procedures, equipment, MOCs and training on new or modified unit equipment or systems. - Compliance Training: This training is to provide the employees with necessary safety, health and environmental knowledge to meet the intent mandated by law. Format: Various techniques will be used for the training sessions. They will be presented in following manner: - Classroom sessions utilizing visual aids, videos, charts, drawings, and guest instructors, as applicable. - Field training to provide "hands on" familiarity with new and modified equipment and systems as they are introduced to operating units. - Control room procedural and systems reviews on an ongoing basis, to provide operator refresher and systems review training. - Training packages and discussion review sessions during monthly safety meetings. A compliance training matrix is developed annually to assure that each employee receives the necessary training Refresher training is an ongoing process, which will be summarized at least every three years. All employees are encouraged to provide input through their the Training Steering Committee regarding the frequency of refresher training. 3.5 Maintenance The objective of the Maintenance Program is to assure the mechanical integrity, safe, reliable operation and repairs to equipment; to document the condition of pressure vessels, heat exchangers, boilers, pipes, and other process equipment; and to comply with applicable State and Federal regulations. The Maintenance progr am includes a Preventive Maintenance program, and Inspection program, and a Testing program. The Manager of the Engineering and Maintenance Department is responsible for the Mechanical Integrity Program. The Maintenance Program ensures that the Facility uses appropriate inspection and testing methods to determine the condition of pressure vessels, heat exchangers, boilers, pipes and other process equipment; recommend necessary repairs; perform proper preventive maintenance; assure quality of new fabrication / construction; and assure fitness for service of maintenance materials and spare parts. Equipment covered by this Program is listed in a computer database maintained by the Maintenance Department. Inspection and testing shall be conducted per the codes and standards to which the equipment was design, and good engineering practices. Inspection and testing (NDE / NDT) methods used may include (but are not limited to) any of the following: - ultrasonic - radiography - ha rdness - visual - metallagraphy Determinations made from inspections may include any of the following: - suitability for continued service - nature of corrosion and corrosion rates - replacement date - vessel reinspection date (based on calculated remaining life) - condition of internal / external insulation and / or coatings - condition of foundation and anchor bolts - condition of fireproofing The information regarding the Maintenance program for all areas is contained within the Computerized Maintenance Management System (CMMS) maintained by the Engineering and Maintenance Department. A team of engineers and maintenance personnel ensure that the information contained within this databases, such as testing methods and frequency, comply with good engineering practices. 3.5.1 Mechanical Integrity Training In addition to the general training provided for all facility employees, the Mechanical Integrity training program is specifically designed to train Maintenance pe rsonnel on issues specifically relating to the inspection, testing, and maintenance of process equipment. The Mechanical Integrity Training program is the responsibility of the Training Manager. The intent of the Mechanical Integrity training program is to ensure that all equipment that is integral to processing or storing hazardous materials is maintained in a consistent, reliable manner. This is accomplished by having maintenance personnel who are educated in the requirements for mechanical integrity of the facility equipment. The TIMET Training Department along with the Maintenance and Engineering Department has developed a comprehensive training program to accompany the testing and inspection program as described above. TIMET provides the training to ensure that all maintenance employees have the knowledge, skills, and ability to fully implement the mechanical integrity program. The Mechanical Integrity Training Program outlines the objectives of the maintenance pers onnel regarding their core competencies. The Mechanical Integrity Training Program includes: - Regulatory requirements for Mechanical Integrity - Categorizing process equipment types - Application and format of maintenance procedures - Requirements for inspection, testing and documentation of process maintenance activities - Requirements for correcting equipment deficiencies - Quality assurance requirements for new plants and equipment The topics for the inspection and testing program include the following: Routine Job Duties: This covers subjects such as communication between shifts, how to handle work orders; ordering parts and materials and how to perform routine scheduled testing and inspection requirements such as crane repairs, installing conduit, etc. Non-Routine Job Duties: This covers testing and inspection of critical equipment as scheduled, including the specific steps required to complete the mechanical integrity requirements for all covered equipment. Saf ety, Health, and Environmental Duties: Although the maintenance personnel are not operating the process units, their job duties require that they be knowledgeable on the nature of the process chemicals, and how to respond to abnormal situations involving hazardous chemicals. This includes responding to leaks and spills, wearing and maintaining personnel protective equipment, and housekeeping responsibilities. Administrative Duties: Maintenance personnel are trained to develop and revise maintenance procedures, document testing and inspection performed; document changes requires as a result of testing and inspection. Issues such as submitting new procedures for approval are also covered. The format for the training modules are presented as follows: - Classroom sessions utilizing visual aids, videos, charts, drawings, and guest instructors, as applicable. - Field demonstration training to provide "hands on" familiarity with Mechanical Integrity procedures, inspection, a nd testing. - Practical training to provide knowledge in how to develop and complete Mechanical Integrity testing forms and documentation, Preventive Maintenance forms and documentation. During the training sessions, the maintenance personnel will receive reference material corresponding to the training provided, and Mechanical Integrity policies and procedures. The same policies as applied to Operator Training for determining the nature of the training, the personnel to be trained, and training documentation, and competency testing is also applied to the Mechanical Integrity training. 3.6 Incident Investigation The purpose of the incident investigation program is to learn the basic causes of incidents. The Incident Investigation Program covers all incidents and near miss incidents that occur at the facility. Examples of incidents or near misses covered by this policy but not limited to are: occupational injuries and illness, property damage or loss, and environme ntal incidents such as spills and releases. The purpose of this guideline is to ensure that effective incident reporting and investigation procedures are carried out efficiently. To be effective, all investigations are conducted in a timely, organized and objective manner. The purpose of an investigation is not to fix blame, but rather to determine the facts surrounding the incident, present the findings and conclusions, and make recommendations for corrective actions that will prevent a similar occurrence in the future. All serious incidents will be investigated by an incident investigation team. The Incident Investigation is initiated by the departmental Foreman or Departmental Supervisor. The Departmental Manager is responsible for ensuring corrective actions are taken, and the TIMET Safety Manager has the overall responsibility for ensuring the investigation is performed to CAPP and RMP standards, and that all recommendations are addressed in a timely manner. An Inci dent Investigation team is convened for each incident, and will include personnel applicable to the particular incident. At a minimum, the team consists of at least the Foreman responsible for the area under investigation, employees involved in the incident, and witnesses to the incident. Other team members may include the Manager or Area Supervisor, Union Representative, Safety Manager, and Plant Resources, depending on the level of severity of the incident. . If the incident involves a contractor, a contractor representative may also be part of the team. Other team members may be appointed as needed to conduct a thorough and effective investigation. Compliance with PSM requires the investigation to be started within 48 hours of the incident. The Foreman on duty completes an Incident Investigation Report for all incidents occurring in his or her department within this timeframe. The report must contain at least the following: - Name of equipment involved - Name of person nel involved - Date and time of incident / date and time incident reported - Location of the incident - Description of the incident - Immediate and basic cause(s) - Recommendations for controlling or correcting the immediate and basic causes. - Any photographs, drawings and sketches, as necessary, to help explain the incident. - Other details required by RMP The report is reviewed by the Plant Manager, Department Manager, and Safety Manager, and distributed to the appropriate departments, including Medical, Operations, and Safety. The Safety Department is responsible for ensuring that the applicable Department Manager receives a copy of the report. The Department Managers discuss the report as appropriate with their departments. RMP requires that all affected personnel and contractors are made aware of incident investigation report findings. 3.7 Compliance Audits To help ensure that the accident prevention program is functioning properly, TIMET periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Per Nevada CAPP, this facility verifies CAPP and RMP compliance every three years with an audit. The facility will retain the two most recent compliance audits. The Environmental Manager is responsible for implementing the Compliance Audit portion of the Prevention Program. 3.8 Chemical Specific Prevention Steps The accident prevention program summarized previously is applied to the Program 2 process at the Facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Some of the administrative programs to prevent, detect or mitigate an incident at the Facility are presented below. Specific safety equipment and procedures, known as safeguards, are in place at the Facility. These safeguards are listed as part of the Process Hazard Analyses, process s afety information, and in the operating procedures. Some examples of safeguards are: Release Prevention - Preventative Maintenance - Inventory control - Safety Interlocks and fail safe control devices Release Detection - Hydrogen Chloride & Chlorine perimeter detectors - Process area chlorine monitors - Process area carbon monoxide monitors - Facility alarm system to notify personnel in case of emergency Release Containment/Control - Overpressure protection for all pressure vessels - Manual and automatic valves to permit isolation of the process - Automated shutdown systems for specific process parameters - Containment around storage tanks to contain liquid materials - Fume elimination preventing carryover of TiCl4 to atmospheric combustion stack. - Chlorine scrubbing towers are used to remove any unreacted Cl2 gas. - Tank vapor recovery system to contain hazardous tank vapors - Operating procedures and list of safe operating limits - Flow limitation devices Relea se Mitigation - Trained emergency response personnel - Safety Showers / Eyewashes - Personal protective equipment (e.g., respiratory protection, eye protection) 3.9 Additional Prevention Programs In addition to the prevention programs listed in Sections 3.1 to 3.7, TIMET also complies with the Nevada CAPP program to implement additional Prevention Program 3 elements. A brief summary of these programs is provided here. 3.9.1 Employee Participation The intent of this element is to involve employees in the development and implementation of the various RMP/CAPP element compliance activities. This involvement is intended to be a cooperative, interactive effort that will bring together the best resources at the facility to achieve a sound loss prevention program. Employee Participation is the responsibility of the Training Coordinator. The facility Safety Committee and Emergency Response Steering Committees are the primary forum for discussing and assuring employee partici pation with the individual elements of the RMP/CAPP standard. As necessary, an update on the conduct of elements pertaining to RMP/CAPP will be provided to the committees. Employee involvement in aspects of RMP/CAPP activities will be a specific item to be reviewed. Practices that have been successful at TIMET will continue (e.g., employee participation). These are formalized as required by RMP/CAPP in the following: - Process Safety Information: This is information deemed essential for Process Hazard Analyses studies, training purposes, operating procedures, etc. As the information is developed or updated, an employee knowledgeable in the specific process is be asked to assist the review to ensure the information is accurate and precise. - Process Hazard Analysis: All process hazard analysis studies require that an employee knowledgeable in the specific process be a member of the study team. In addition, TIMET requires that an employee representative be included in the PHA. If a study must be completed by other than facility personnel, then a review team including an employee knowledgeable in the specific process will be formed to review the study findings. - Operating Procedures: Employees knowledgeable in specific processes will participate in initial and periodic reviewed of the operating procedures. Knowledgeable employees will also participate in subsequent periodic reviews of operating procedures. - Training: The Plant Training Steering Team consists of representatives from all levels of the TIMET organization. The team is responsible for developing the training programs, and recommending specific types and forms of training, as well as the frequency of refresher training. Modifications to existing training programs will be reviewed with this team, and the composition of the team requires employee representation from various appropriate groups within TIMET. - Pre-Startup Safety Review s: Employees knowledgeable in the process will participate in all applicable stages of the PSSR process. Documentation for the remaining stages will be available for review. - Mechanical Integrity: A team that includes individuals with appropriate expertise will address aspects off the mechanical integrity provisions of the PSM standard. Maintenance and Inspection personnel with requisite knowledge and expertise are members of this team. - Incident Investigation: TIMET's practice to include employee representatives in the conduct of any formal incident investigation. This practice continues and is adequate to meet all requirements of the RMP/CAPP standard. TIMET also communicates the finding of the incident investigation to any affected employees. All employees will have access to process hazard analyses and other information developed under the requirements of RMP/CAPP rules. Employees or representatives that require access to information not readily a vailable at their work site may make arrangements through their supervisor and the proprietor of the information for an opportunity to review this information. 3.9.2 Contractor Safety It is the TIMET philosophy that all injuries are preventable. This applies to all personnel on the Henderson site whether they are TIMET employees or Contractor employees. This policy is intended to evaluate, monitor, and control contractor safety performance within the plant facility. The system includes pre- award safety evaluation of contractors, contractor safety orientation, required contractor activities to promote safety, periodic contractor safety audits, monitoring of contractor injury/illnesses, and on-the-job and post-job evaluations. Contractors are trained by onsite personnel about the hazards of the process, safety procedures and equipment requirements, and the emergency response procedure onsite prior to commencement of work. All contractors scheduled to work at TIMET will rec eive General Safety Orientation to the plant, and Process Overview training specific to the area in which the work will be performed. The Safety Orientation includes Rules of Conduct, Emergency Procedures, HazCom, Nevada CAPP Program, Respiratory Protection, and Personal Protective Equipment. A Visitor/Contractor Safety Orientation Card is issued to each contract employee, and documents that he/she has received and understood the information provided by TIMET. Prior to starting work, all contractors performing operations at the Facility must complete the Pre-Work Safety Review Checklist. Contractors must also provide basic safety training to their own employees as required by State and Federal Regulations. Contractors are advised of TIMET's communication program. The Contractor safety and health program requirements are commensurate with the type of work, associated risk, potential exposure of employees, and cost benefit analysis. Contractors that are at a greater risk of exposure to hazards, such as maintenance Contractors in process areas, will require a program and plan that is different from those in lower risk activities such as janitorial, delivery materials, or engineering. Contractor Safety and contractor evaluation is the responsibility of the Safety Manager. 3.9.3 Management of Change The intent of this procedure is to assume that all modifications to equipment, procedures, raw materials and processing condition other than "replacement in kind" are safe. This policy applies when one of the following changes are made: - Process chemical or feed stock change. An MOC is needed when making a change in process chemicals or process unit feed stocks that falls outside a defined range of properties. - Process technology. An MOC is required when changes to the method of processing the chemicals are proposed. - Equipment change. An MOC is needed when making changes to process facilities and other than replacement in kind. - Process Sys tems and Controls. An MOC may be needed when changes are made to maintenance, operating or emergency procedures. - Operating Procedures. An MOC is required when changing operating conditions outside of the established limits (including test runs). As a minimum, the MOC approval process must consider the following: - Technical basis for the change. - Health and safety considerations. - Impact on procedures (operating, maintenance, and safe practices). - Codes and standards. - Necessary time period for the change. - Justification of the change versus risk. General guidelines for a MOC request are as that all employees and contract employees are trained to understand the concept of MOC. They are expected to use these principles in their daily activities. They are taught to understand what is meant by change, and recognize and identify such changes. MOC principles apply to both permanent and temporary changes. The MOC process is a communications loop to assure that the chang e is approved, all process safety information and procedures have been changed as necessary, and training completed. The MOC process can take the form of one of the following: - Minor Change - Moderate Change - Major Change While an MOC request can be initiated by anyone, overall implementation of MOC is the responsibility of the Safety Manager. Department Managers ensure the department personnel are trained in the use of the MOC process, and that MOCs in their area receive the appropriate review. 3.9.4 Pre-Startup Safety Reviews (PSSRs) The purpose of this program is to systematically ensure the safety of new and significantly modified facilities before placing those facilities into service. PSSR checks that process equipment and plant personnel are ready to safely start and maintain process operations. This is a final check that all important considerations have been taken into account before start-up. This program is designed to satisfy the PSM and RMP requirements regulation and meet all parts of the compliance guidelines. The scope of the review process is as follows for all new facilities or modified facilities where a change in the PSI has occurred: - Construction and equipment in accordance with design standards - Safety, operating, maintenance and emergency procedures are in place and accurate - For new facilities, a PHA was performed and recommendations resolved or implemented before startup. - Modified facilities meet MOC requirements - Training of employees involved in operating the process is complete. - The Area Production Supervisor or delegate is responsible for the PSSR The Department Managers implement and maintain the PSSR program for their specific area. Other plant personnel may assist in PSSRs by performing specific verifications and reviews in their areas of expertise. The Safety Manager coordinates the PSSR activities as required by the Management of Change program, or other regulatory requirements at the facility. * ************************************************************************************* ****************************************** 4.0 Emergency Response Program Summary TIMET's Emergency Planning and Response Program provides resources for planning for and response to emergencies at the facility. TIMET contributes to the community by protecting the plant and neighbors from the potentially damaging effects of emergency situations. The Emergency Response Plan has been coordinated with the Local Emergency Planning Committee (LEPC), and reviewed by members of surrounding industrial community. The facility design, maintenance, operating procedures, and training provide for risk minimization before an accident can occur. In spite of all these things, emergencies can arise, sometimes through forces beyond control. The Emergency Response Plan, along with training and drills, is designed to prepare the facility to recognize emergency situations of various types and react promptly an d correctly to minimize any ill effects. Local, State, and Federal safety rules dictate that the facility study and understand the principles and specifics covered in this preplanning effort and fully understand all roles in the plan. The purpose of this Emergency Plan is to provide a cohesive procedure for coordinating effective response procedures by all plant personnel in order that danger to employees, contractors, the general public and the environment may be lessened in the unlikely event of an emergency. The Emergency Plan is also intended to meet the emergency planning requirements of the following regulations: Nevada's Chemical Accident Prevention Program NRS 459.380 - 459.3874 EPA's Risk Management Program Regulation 40 CFR Part 68 EPA Notification Requirements 40 CFR Part 302.6 EPA Emergency Release Notification 40 CFR Part 355.40 Nevada OSHA NRS 618 OSHA's Emergency Action Plan Regulation 29 CFR 1910.38 (a); OSHA's HAZWOPER Regulation 29 CFR 1910.120; EPA's Resource Conservation and 40 CFR part 264, Subpart D Recovery Act Contingency Planning Requirements 40 CFR Part 265, Subpart D, & 40 CFR 279.52. TIMET also utilizes perimeter monitors and process monitors to aid in expediting a response to a leak. Perimeter monitors are annunciated in the security office, and the security personnel contact the on-shift Incident Commander. The Incident Commander determines the level of response required for the incident: incidents are categorized as follows: Emergency Response Levels Level Severity ---------------------------------------------------- ----------------------------------------------------------------------------- Level 1 * A minor incident that can be handled in the course of normal operations by the local area operators * Does not pose an offsite impact; * Does not exceed Reportable Quantities (RQ) or is not required to be reported by regulations. Level 2 * Any incident requiring an organized TIMET ERT response from outside the local facility or area where the incident occurs * Does not pose an offsite impact; * Exceeds the Reportable Quantity (RQ) limits or is required to be reported by regulations. Level 3 * Any incident requiring an organized TIMET ERT response from outside the local facility or area where the incident occurs * Poses an offsite impact * Large chemical release, which exceeds the Reportable Quantity (RQ) limits or is required to be reported by regulations All employees and contractors are provided with General Awareness training. Additional training is provided to operations staff to enable active response to site emergencies. ************************************************************************************** 5.0 Management Systems The Plant Manager is ultimately responsible for implementation of the risk management measures set forth in this document. The Henderson Environmental Manager is responsible for upkeep of the Risk Management Plan and Hazard Assessment, and all supporting documentation. The individual departments assigned in Section 3.0 above implement each element of the Prevention Program. Contact Name Tony D. Garcia - Manager, Environmental Affairs 702-564-2544 ext. 238 |