Reynolds Metals Company - Troutdale - Executive Summary |
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Reynolds Metals Company Risk Management Plan Executive Summary 1. Accidental release prevention and emergency response policies Reynolds Metals Companys (RMC) Troutdale reduction facility is committed to responsible stewardship of the environment, protection of the community, protection of employee health. Management systems and controls have been implemented which comply with various applicable regulations to prevent the release of regulated substances especially in locations, which may cause detrimental effects to employees, the community, or the environment. This is accomplished through a systematic and periodic evaluation of process design, process technology, operational procedures, maintenance activities, non-routine procedures, emergency preparedness and training. Although the EPAs RMP was recently promulgated RMCs commitment to safety is reflected in the operating history of the plant. The Propane and Chlorine systems in place at RMC, covered by the RMP rul e, have been in operation for at least 20 years. During that time there have been no releases to the environment that have resulted in injuries to workers or the public. To continue to assure Chlorine or Propane releases are prevented or will not result in adverse impacts programs have been developed and implemented. The Chlorine and Propane system programs comply with OSHA's 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals for Chlorine and Propane, and EPA's 40 CFR part 68 subpart D, Accidental Release Prevention Provisions in the Risk Management Program. The Emergency Response and Construction Contractor programs were also reviewed and revised to assist in prevention and mitigating actions. In addition, both systems are being upgraded to meet the current NFPA and Chlorine Institute recommendations. It is important to note that the EPA Consequence Analysis shows that no one in the surrounding residential community would suffer significant injury or health effects if the largest container of chlorine or propane stored on the RMC Plant site failed completely. The adjacent industrial area would also only suffer limited damage with no fatalities expected. 2. The stationary source and the regulated substances handled RMCs Troutdale facility is a primary aluminum reduction smelter and a casting operation. Substances that are stored at facility that are covered by the RMP rule are chlorine and propane. Chlorine is used to remove impurities from the aluminum in the casting operation. Propane is stored as a backup system to the natural gas line for the furnaces, in the event of a natural gas curtailment. The maximum amount of chlorine that is stored at this facility in the system is 6 tons. The maximum amount of propane that is stored at this facility in the system is 40,000 gallons. 3. The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation mea sures to limit the distances for each reported scenario. Each of the regulated substances at the RMC is in a separate process system, which feeds the cast house furnace. As required, RMC has developed worst case and alternative case release scenarios for each substance. EPA has defined the method to estimate the worst case release scenario as estimated to create the greatest distance in any direction to an endpoint In the worst case release scenario, the quantity of a substance released is equal to the greatest amount held in a single vessel or pipe line. RMC does not expect a worst-case release scenario to ever occur. In fact, the worst case releases required by EPA to be evaluated in this RMP have never occurred in the past. The alternative case release scenarios developed by RMC are considered more likely to occur than the worst case release scenarios. However, the alternative case release scenarios are still considered unlikely and have never occurred in the hi story of the facility. As part of its prevention program, RMC has automatic release mitigation systems in place to reduce the likelihood of an accidental release. RMC performed an offsite consequence analysis to estimate the potential for an accidental release to affect the public or the environment. The offsite consequence analysis consists of evaluating both worst-case release scenarios and alternative release scenarios. For all worst case and alternative case release scenarios for chlorine, the EPA approved Degadis model was used to calculate the distance to the toxic endpoint defined in Appendix A of the RMP rule. For propane, EPAs RMPComp computer modeling program was used to calculate the distance to 1 psi overpressure, the offsite consequence analysis parameter defined in the RMP rule. These models are considered conservative and would generally give longer distances, that is cover a larger area, than computer models developed specifically for the RMC. The follo wing information summarizes the offsite consequence analysis for the Chlorine and Propane systems performed by RMC Chlorine Alternative Case Scenario The alternative release scenario for chlorine, considered by RMC to be more likely to occur than the worst case, is a leaky valve or gasket which results in the release of 100 pounds of chlorine in an hour. This scenario could occur only if there were a failure of the detection systems at the facility and occurred during hours with less staff on site and when the guard was on rounds. The distance to the toxic endpoint for this scenario was calculated at 0.13 miles. The U.S. Census Bureau indicates that as many as 5 people may live within the distance to this toxic endpoint but a more accurate estimate of residential population is zero persons. No public or environmental receptors are located within this area. Note that the toxic endpoint is defined as 3-ppm chlorine in air. This is described by the American Industrial Hygi ene Association as The maximum concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individuals ability to take protective action. Chlorine Worst Case Scenario The worst case release scenario for chlorine is a rupture of the 2,000 pound storage tank in the chlorine storage area. The worst case release scenario for chlorine as defined by EPA is a release of the entire contents of the tank over 10 minutes. The maximum distance to the toxic endpoint for this release is 1.62 miles. The U.S. Census Bureau indicates that as many as 3,797 people live within this endpoint distance of this hypothetical release, using methods that are not truly representative of the area around the RMC Troutdale plant. A more accurate estimate of residential population living within this endpoint concentration is 1,500 people. With in this endpoint distance are located residential areas, commercial areas, industrial areas, and environmental receptors. Propane Alternative Case Scenario The alternative release scenario for propane, considered to be more likely to occur than the worst case release, is a leak from a 2-inch pipe. A release rate of 100 pounds of propane was assumed. With this alternative release scenario, a distance to the 1 psi overpressure endpoint was calculated at 0.03 miles. At this distance, there is no impact to any offsite receptors. Propane Worst Case Scenario EPA defines the propane worst case release scenario as a vapor cloud explosion involving one of two 20,000-gallon propane storage tanks at the facility. If the entire contents of this tank were involved in an explosion, the distance to a 1 psi overpressure would be 0.3 miles. The U.S. Census Bureau indicates that as many as 27 people may be living within the area defined by the 1 psi overpressure endpoint. Other methods for estimating population show zero population within those areas. There are business and commercial receptors located within this area but no environmental receptors. 4. The general accidental release prevention program and chemical- specific prevention steps. This facility complies with EPAs Accidental Release Prevention Rule and with OSHAs Process Safety Standard as well as all applicable state codes and regulations. The Prevention Program consists of 12 elements, which assist in prevention and minimization of regulated substance releases. A description of each of the elements is given below: Employee Participation RMC has involved employees in the development and implementation of the elements of Process Safety Management and the Prevention Program. RMC encourages employees to participate with the understanding that their participation is a key factor to the success of any program. RMC is committed to maintaining a safe workplace, and as a result all employees are re sponsible for adhering to the PSM/RMP regulations. RMC has committed to the following: 7 Including employees in Process Hazard Analyses 7 Consulting employees on the development of PSM/RMP regulation elements Providing employees with access to the information developed through the PSM and RMP rules.. Process Safety Information RMC provides appropriate protective equipment and controls and trains personnel about the process equipment and hazards so that they can conduct their jobs in a safe manner. A complete compilation of Process Safety Information (PSI) is made available to those involved in operating and maintaining the PSM/RMP regulated processes. The PSI includes the following: 7 Hazards from chemicals used or produced by the process 7 Information pertaining to the technology and safety controls of the process Process Hazard Analysis RMC provides appropriate resources to make the working environment around regulated substances safe. To assist in assuring safety, hazards are identified through the Process Hazard Analyses performed on each of the areas regulated by PSM/RMP. RMC has performed Process Hazard Analyses (PHA) on each of the regulated processes. The Hazard Analysis for both propane and chlorine were reviewed and updated in March and April 1999. RMC will update the hazard analysis at least every five years to assure that the PHA remains applicable to any process improvements and changes. The level of detail in the PHA is intended to be appropriate to the complexity of the process. The findings, which require changes, will be submitted in the RMP. Records maintained by RMC on an ongoing basis include: 7 Documentation showing those PHA recommendations are resolved in a timely manner. 7 Documentation of what actions were taken as a result of the PHA 7 Documentation that all PHAs are updated at least every five years. 7 Employee Training Records Standard Operating Procedures RMC provides appropriate resources to insure personnel have the knowledge necessary to make the working environment at the facility safe. To assist in assuring the safety of employees, the surrounding community, and the environment, operating procedures have been completed for each regulated process. In conjunction with operating personnel, RMC has developed and implemented written operating procedures, available in the operating manuals, which provide clear instructions for safely conducting activities involved in each of the PSM/RMP regulated processes. Employees who work in or maintain the process utilize the procedures. The procedures address all operational phases, and are reviewed at least annually to ensure they remain up to date. Copies of the Standard Operating Procedures are available in the corresponding control rooms. The PSM Coordinator is responsible for notifying the supervisor of the process area the date by which the SOP needs to be re-certified. The supervisor of the process is respo nsible for ensuring the manual is reviewed and certified annually. The ongoing recordkeeping requirements for the standard operating procedures are: 7 Proof of certification annually that the standard operating procedures are current and accurate. Training RMC provides the appropriate resources to ensure adequate training of personnel involved in operating the regulated processes and to ensure that the jobs can be performed safely. The training program includes initial training, refresher training, and training documentation. Employees currently involved in operating a regulated process and employees being transferred into a regulated process will be trained in an overview of the process and in the standard operating procedures. This initial training will also include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. Refresher training will be provided at least eve ry three years to employees involved in operating a regulated process to assure that the employee understands and adheres to the current standard operating procedures of the process. RMC will verify that each employee involved in operating a regulated process has received and understood the required training. A record will be prepared that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. The training programs and documentation are available in the PSM Central files. The area supervisors are responsible for ensuring employees in their area are appropriately trained. The ongoing recordkeeping requirements for training are: 7 A written record that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. Contractors RMC periodically uses contractors to perform work in and around processes that involve regulated subst ances. To ensure safety, RMC has developed a Contractor Program to inform and manage contract employees working in the PSM/RMP regulated systems. The Contractor Program has been developed to establish a screening process so that RMC hires and uses contractors who have a commitment to safe work practices. The contractor program includes all activities that have the potential for affecting process safety, including the performance of maintenance or repair, turnaround, equipment installation, renovation, demolition, or specialty work on or adjacent to the PSM/RMP regulated processes. A facility wide Contractor Program is available in the PSM Central files or through Purchasing. Pre-Startup Safety Review RMC will ensure a new, or significantly modified, facility in a regulated process is as safe as possible before starting the system. To assist in assuring safety, a Pre-Startup Safety Review (PSSR) is performed before regulated substances are introduced to the system. The PSS R verifies the following information: 7 Training is complete 7 SOPs are complete 7 Construction/equipment is in accordance with the design specifications 7 A PHA has been complete, if it is a new facility Records of the PSSRs and procedures are available in the PSM Central Files. The supervisor of the area/ construction project leader is responsible for ensuring a PSSR is performed. Mechanical Integrity RMC will provide appropriate resources to ensure that the equipment used to process, store, or handle highly regulated substances is designed, constructed, installed, and maintained to minimize the risk of releases of the regulated substances into the workplace or community. To accomplish this goal, a Mechanical Integrity Program has been implemented to ensure the continued integrity of the processes. The Mechanical Integrity Program has been implemented for the systems that could potentially result in the release of a hazardous chemical. The program utilizes increased ma intenance training, and preventive maintenance in conjunction with regular inspections and tests, to ensure equipment is in satisfactory condition. A summary of the Mechanical Integrity Program is found in the PSM Central Files with more details located in the maintenance shop. The ongoing recordkeeping requirements for the mechanical integrity testing program are: 7 Documentation showing each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. Hot Work/ Safe Work The objective of the RMC Hot Work Permit is to consistently control non-routine work conducted in the process areas. The Hot Work Permit System is specifically concerned with the permitting of hot work operations associated with welding and cutting on or near PSM/RMP regulated process areas. The permits will document compliance with the fire prevention and protection requirements. Additional safe work practices such as lockout/tagout, confined space entry, and control over entrance have also been implemented to increase facility safety. The ongoing recordkeeping requirements for the hot work/safe work programs are: 7 Copies of the hot work permit showing: that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations; the date(s) authorized for hot work; and the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations. Management of Change RMC manages all changes to processes regulated by PSM or RMP to ensure the processes are operated and maintained as safely as possible. To assist in accomplishing t his goal, a Management of Change Program has been implemented. Management of Change examines any type of change that is planned for the process, and the basis of the change. The Management of Change Program is designed to evaluate, approve and administer changes to PSM/RMP regulated processes to assure any changes implemented enhance the operation and safety of the system. A description and procedures for the Management of Change Program can be found in the PSM Central Files. The PSM Coordinator is responsible for ensuring all MOC forms are complete. The ongoing recordkeeping requirements for management of change are: 7 Copy of the written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process. Incident Investigation It is the policy of RMC to investigate any incident that occurs in a process regulated by PSM or RMP, which could have or did result in a catastrophic release of a hazardous chemical in the workplace. The Incident Investigation policy, procedures, and records of the Incident Investigations are available in the PSM Central Files. Compliance Audits Compliance audits are utilized to evaluate the effectiveness of the PSM/RMP programs that have been implemented at RMC. The compliance audit is intended to identify any deficiencies or weaknesses in RMC's policies, programs, or procedures, and take action to correct the deficiencies. A compliance audit is performed at least every three years to verify that the systems required by the PSM and RMP Regulations are in place and have been implemented. The regulations require that the previous two compliance audits be kept on file. This documentation and the Compliance Audit procedures are available in the PSM Central Files. The ongoing recordkeeping requirements for compliance audits are: 7 Proof of certification that compliance with the provisions of the prevention program has been evaluated at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. 5. The five-year accident history During the past five years, the RMC facility has had no reportable accidents. RMC has used the compounds covered under the RMP program for over 20 years and has not had any reportable accidents in that time. 6. The emergency response program RMC has developed and implemented an emergency response program for the purpose of protecting employees, as well as the public and the environment. 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. RMC utilizes an instrument command system to respond to potential accidents at the facility. In addition, RMC is part of the local CAER group working with surrounding business and the fire department. RMC works cooperatively with the fire department on training activities including fire training and emergency response. 7. Planned changes to improve safety Several developments are already in the development stages as part of ongoing efforts to improve safety at the facility and responsiveness of emergency staff. Upcoming training events are scheduled as well as new mitigation facilities. RMC plans to benchmark our emergency response program with other aluminum companies that have chlorine and propane systems to gather fresh ideas and approaches to be evaluated for inclusion to the operations at the Troutdale facility. RMC plans several programs as part of an ongoing effort to increase communications with the community. There will be a neighborhood community program and increased communications with the public on a routine basis. June 21, 1999 June 21, 1999 June 21, 1999 June 21, 1999 June 21, 1999 June 21, 1999 June 21, 1999 June 21, 1999 June 21, 1999 June 21, 1999 June 21, 1999 June 21, 1999 |