Wabash Alloys, L.L.C - Executive Summary |
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Prevention of a release is a core component of the Wabash, LLC Risk Management Program. This program is designed to insure proper work practices and an on-going mechanical integrity program. The primary methods used by this facility are a part of the Process Safety Management Program as follows: A. Written Plan of Action - Process Safety Information. This part of the program is one of the most involved and included the development of a written plan of action regarding the implementation of employee participation in the program. In accordance with a specific schedule outlined by the standard, as per 29 CFR 1910.119, Wabash Alloys has completed a compilation of written process safety information concerning the process and operations involved with Chlorine of these standards of operating procedures. For purposes of defining a process covered under this program, the use of Chlorine in the demagging system has been considered "a process," whereas a production or usage system/functio n is considered an "operation." By identifying each functional operation, a team was able to ascertain the potential and develop preparation plans in the case of a release. This compilation of information is to enable Wabash Alloys and the employees involved in the operations related to Chlorine to identify and understand the hazards posed by these processes. This process safety information includes information pertaining to the toxicological and physical hazards of the chemical listed. B. Hazard Analyses/Abatement Schedule. This analysis is the heart of Wabash Alloys ' process safety management or Risk Management release prevention program. The safety and health staff, engineering and maintenance personnel, and certain operational personnel performed an initial process hazard analysis (hazard evaluation) on each operation within the chlorine process. The analysis was completed by a team with expertise in the operations. The team included employees who have experience and kno wledge specific to the operations of handling and using the chemicals at each of the process operations. A system was developed and is maintained to promptly address the team's findings and recommendations by the formation of a PSM/RMP committee. Also, a written schedule of when these actions were to be completed has been developed, indicating by whom and when. The hazard analyses will be updated as needed and at least every five (5) years. This analyses involved a review of each operation of the process to address steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions. The assessment also included information concerning the emergency action plans related to the process; development and implementation of safe work practices in the format of Job Safety Analysis also in regards to the control of entrance and exit of personnel in the process areas; pre-startup safety; mechanical integrity of equipment; inspection and testing, correction of deficiencies in equipment, planned or unexpected changes to the process, equipment, and procedures to the processes. C. Written Operating Procedure. Wabash Alloys has developed and implemented written operating procedures to provide clear instructions for safely conducting activities involved in the processes at each operation by our employees, consistent with the process safety information and to address steps for each handling phase, limitations, safety and health considerations, and safety systems and their functions. Other written documentation of standard operating procedures as a part of this program is included in the following documents: Mechanical Integrity Study of Process Equipment Preventive Maintenance Program Written Emergency Response Plan Employee Emergency Action and Evacuation Plan D. Training. Process Safety Management Each employee involved in operations within the process where Chlorine is received, processed, or used at the facility has been trained in an overview of the process and in the operating procedures as outlined by 29 CFR 1910.119. Refresher training is provided no less than every three years and more often if necessary. Training includes: a. Emphasis on the specific safety and health hazards; b. Emergency operations in the case of a release including shutdown; and c. Safe work practices applicable to the employee's job tasks. Mechanical Integrity Also, each maintenance person who has responsibilities to perform maintenance on the process components receives training on an as needed basis, but no less than every three years. Emergency Response A team of individuals has been trained and is equipped as a HAZMAT team. The team is equipped with Self-Contained Breathing Apparatuses, Level A suits and monitoring equipment to respond in an offensive manner. A record of the training, which contains the identity of the employee, the date of training, and the means, used to verify that the employee unders tood the training is completed and maintained. E. Contractors. Designated personnel have specific responsibilities related to the use of contractors who perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to areas where the Chlorine is received, stored, or processed in the facility. These responsibilities include specific requirements in selection of contractors regarding the contractor's safety performance and programs; the provision of information concerning the emergency action plans related to the process; development and implementation of safe work practices regarding the control of entrance and exit of contract employers and contract employees in the process areas, periodic evaluation of the contractor related to safety management at the process; maintenance of certain records related to contractor employee injury and illness; development of written procedures for any new processes, and provision of training to employees. Contractor s performing work on or adjacent to equipment or processes in which Chlorine is present must have clearance from the Maintenance Supervisor prior to beginning operations. Each contractor must also complete the Wabash Alloys Visitor and Contractor Safety Rules form prior to entry into the facility. In those cases where contractors will perform work directly to or on the process equipment in which the Chlorine is present, the Safety Coordinator and Maintenance Supervisor provide an orientation section to them prior to beginning operations. This orientation includes an introduction to the Wabash Alloys Process Safety Management Program, information concerning the toxicological and physical hazards of Chlorine, and the emergency response plan in the case of an incident involving a release. Upon completion, the contractor is issued a permit by the Maintenance Supervisor to begin work. F Inspection and Testing. A program has been developed for inspection and testing, correction of def iciencies in equipment, quality assurance, management of changes in the handling of the Chlorine, and procedures to the process, and compliance audits. (1) Mechanical Integrity Program and Assessment - To insure the integrity of the mechanical components of the chlorine process, a professional engineer, in collaboration with Wabash, LLC personnel has developed an On-going Written Mechanical Integrity Program. This development included a thorough assessment of the process in an attempt to assess the age and present integrity of the component parts. This assessment included the identification of the component parts for comparison with the manufacturer's specification for maintenance and replacement with "like in-kind components" on a scheduled basis. In addition, updated Piping and Instrument Diagrams were completed. (2) Equipment Preventive Maintenance and Quality Assurance Program - In an effort to maintain the mechanical integrity and to complete repairs of the equipment in the pr ocess, the Maintenance Supervisor oversees a Preventive Maintenance Program. (3) Management of Change - To insure that proper safety precautions are initiated when change in the operations of the process occurs, the PSM/RMP committee will meet to discuss the planned changes before authorization is given. The committee will address the following issues prior to approval of a change in the process: 7 The technical basis for the proposed change 7 Impact of the change on employee safety and health, 7 Modifications to operating procedures 7 Necessary time period for the change If changes are decided upon, training for personnel in the operation is provided. Also, any changes to be made are evaluated by performing a Hazard Operability Study to identify any hazards and/or actions that must be taken. Additionally, if a change covered by these procedures results in a change in the process safety information, such information will be updated accordingly. (4) Pre-startup safety review - To insure that proper safety precautions are initiated when shut-down and startup of the systems occurs after such things as renovations or major repairs, the PSM/RMP committee will meet to discuss the changes. The committee will decide if the changes are significant enough to require a change in the process safety information. If the modification is significant enough to require such a change the committee will confirm the following: 7 Construction and equipment are in accordance with design specifications; 7 Safety, operating, maintenance, and emergency procedures are in place and are adequate 7 A process hazard analysis has been performed for new facilities and recommendations have been resolved or implemented before startup, and modified facilities meet the management of change requirements, and 7 Training of each employee involved in operating the process has been completed. (5) Compliance Audits - Compliance audits will be conducted with these operating procedures at least every three years to verify that the procedures and practices developed are adequate and are being followed. The PSM/RMP Committee will certify that they have evaluated compliance with the provisions of the program. The compliance audit must be conducted by at least one person knowledgeable in the process and a report of the findings will be developed and documented noting any deficiencies that have been corrected. The written report of the two (2) most recent audit reports will be retained. G. Incident investigation A crucial part of the Wabash process safety management and release prevention program is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented. An investigation will be conducted on each incident, which resulted in, or could reasonably have resulted in a catastrophic release of the Chlorine in the workplace. Accident Investigations will be conducted by: Plant Manager Safety Co ordinator Maintenance Supervisor H. Emergency planning and response The facility Emergency Response Plan will be maintained according to the provisions of 29 CFR 1910.38 and 29 CFR 1910.120 and EPA guidelines. A team of individuals has been trained and is equipped as a HAZMAT team. The team is equipped with Self-Contained Breathing Apparatuses, Level A suits and monitoring equipment to respond in an offensive manner. Meetings with the Local Emergency Planning Committee Chair and local fire-fighting personnel have taken place to insure proper implementation of emergency response operations should a release occur. I. Hot Work Permits In accordance with 29 CFR 1910.252, authorization is required from a designated person before cutting or welding is permitted in areas not specifically designed for such purposes. Based on fire potentials of the plant facility, areas are established for cutting and welding and procedures for a permit for other areas. Prior to welding or cutting in other than established areas, any Wabash Alloys employee or contract employee must acquire a written permit. J. Monitoring Devices Air monitoring devices to measure the concentration of Chlorine are located at the storage vehicle, in the vaporizer room, and at the furnaces. If for some reason the concentration of chlorine equals or exceeds 5ppm an audible and visual alarm in the production area engages. Also, an alarm in the production supervisor's office alerts personnel of the concentration. Actions to be taken should the alarm engage are a part of the facility's written Emergency Response Plan and subjects covered during initial and refresher HAZMAT training. |