Nepera, Inc. - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies The Nepera facility maintains accidental release prevention and emergency response programs to assist in providing a work place safe for employees and the community. Specific programs in place include this Risk Management Program which was developed in accordance with Section 112(r) of the Clean Air Act (CAA): the Spill Prevention Report (SPR) in accordance with New York State's Chemical Bulk Storage (CBS) regulations (5 NYCRR Parts 595-599): an Integrated Contingency Plan: Guidelines and Procedures for Hazardous Materials Emergencies: and Occupational Safety & Health Administration (OSHA) Process Safety Management Program. All of these plans and programs have been developed to prevent or minimize the occurrence of spills or releases of hazardous substances, as well as to ensure the appropriate response measures that will be implemented by Nepera in the event of a spill or release of a hazardous substance. Nepera has implemented a Community Alert Network enabling the facility to activate recorded telephone messages providing critical safety information to key community agencies, officials and local residents in the event of a release or emergency at the facility. Nepera has installed a state of the art Perimeter Monitoring System, which detects and identifies hazardous substance emissions that might reach beyond our fenceline and cause discomfort to those who detect the odors. This system has been programmed to provide warning levels and alarm levels of hazardous substances stored and processed at Nepera. Should warning or alarm levels be reached, our staff has been trained to activate the Community Alert Network and the Early Warning System at the local public park. Each of these systems will provide information as to what actions the community should take as a result of an emergency. Nepera maintains an internal Emergency Response Organization including Fire Brigade, Emergency Response Team and First Aid Teams. Nepera has an on-site fire truck, emergency response truck and spill response lockers located throughout the site for ready access in the event of an emergency. These teams are comprised of employees from all shifts providing response capabilities 24 hours a day, 7 days a week and have been fully trained to mitigate fires and/or spills that might be associated with incidents involving any substances handled at the facility. Nepera Facility and Regulated Substances Nepera stores the regulated substances anhydrous ammonia, acetaldehyde and formaldehyde in storage tanks at various locations within the facility at quantities above the Risk Management Plan (RMP) thresholds. The substances are delivered to Nepera via rail car or tank truck and transferred to storage tanks. These substances are then pumped via pipelines from the storage tanks to the process reactors on site. All rail cars, tank trucks, storage tanks and associated equipment is inspected before eac h use ensuring its safe operation and is monitored continuously by on-site personnel. In addition, the rail car area has continuous video monitoring between the rail car siding and the operator control room. Worst Case Release Scenarios and Alternate Release Scenarios The RMP requires facilities to review various release scenarios of regulated chemicals, including a worst case release, no matter how unlikely such a release may be and identify and implement measures to minimize impacts under such scenarios. The worst case release scenario modeled by the Process Hazard Analysis Software Tool (PHAST) air dispersion model, that resulted in the greatest endpoint distance, consists of the instantaneous release of a rail car load of 178,000 lbs. of anhydrous ammonia. In determining this worst case scenario, the rate of release was set at 17,800 lbs./min with duration of 10 minutes. An alternate toxic release scenario for anhydrous ammonia was also conducted. The alternate scenario con sidered was a transfer hose failure releasing 5,300 lbs over a 20-minute duration. The alternate toxic release scenario modeled by PHAST that resulted in the greatest toxic endpoint distance was for formaldehyde. The scenario entails the failure of a pump seal and the release of 52,812 lbs. of formaldehyde solution (60 weight percent) in 30 minutes at a rate of 1,750 lbs./min. The passive mitigation considered in determining the rate of release was a dike acting as a barrier to prevent the spill from spreading. Nepera personnel can respond immediately by turning off pump system via emergency stop button since both a Nepera operator and the truck driver are manning this operation. On-site response personnel can typically begin cleaning spilled material within 10 minutes. The worst case flammable scenario modeled by PHAST that resulted in the greatest overpressure endpoint was for acetaldehyde. The modeled quantity of acetaldehyde released was 196,000 lbs. The alternative flammab le scenario for acetaldehyde was also modeled using PHAST, assuming a hose failure of acetaldehyde. The PHAST model generates results for both an overpressure endpoint and a toxic endpoint. Results generated for the acetaldehyde indicates that the toxic endpoint for the alternative release scenario evaluated were greater than the overpressure endpoint. The Nepera facility stores the following additional four (4) compounds that were considered general duty clause of section 112(r): acetone, benzene, pyridine, and methyl pyridines. These compounds are not regulated substances as listed under 40 CFR Part 58.130 Table 1: List of Regulated Toxic Substances and Threshold Quantities for Accidental Release Prevention. Worst case scenarios using PHAST were performed for all four general duty clause compounds. All of the release scenarios discussed above have the potential for off-site impact to the local population, local recreation areas and environmental receptors including the Ramapo River. General Accidental Release Prevention Program The Nepera facility, as a Program 3 Facility, is required to develop a Prevention Program under Section 112(r) of the CAA. The Prevention Program at the Nepera facility is written in accordance with 40 CFR 68 Subpart D. The Prevention Program implemented at Nepera consists of the following areas; process safety information, process hazard analysis (PHA), operating procedures, training, mechanical integrity, management of change, pre-startup review, compliance audits, incident investigation, employee participation, hot work permit and contractor safety. Nepera did conduct a detailed compliance audit in accordance with OSHA's Process Safety Management Program (29 CFR 1910.119) in May of 1998 and will have completed all identified deficiencies by June 1999. This audit was comprehensive and included all twelve elements of the Process Safety Management program. This audit information is reflected in the RMP Submission, Prevention P rogram Level 3, items 7.10(a) and (b) for each of the three identified programs. Five Year Accident History The Nepera facility has experienced two reportable incidents in the past five years (1994-1999) of 112(r) regulated substances. The first incident occurred in November 1994 as a result of a power failure. The power failure resulted in the shutdown of a control device as designed and released small amounts of ammonia vapors. Two contractors working on the railroad siding adjacent to Nepera claimed they were impacted by the ammonia vapors. The second incident occurred in September 1998 during the cleaning of a formalin storage tank. A transfer of a hot wash solution from the formalin tank to our wastewater collection tank caused an over-pressurization resulting in a lifting of the relief vent. Officials from the local school reported the need to have an elementary school shelter in place as the odors were causing discomfort to students and staff. To minimize the chance o f a recurrence of these situations, certain actions were implemented as a result of incident investigations. Such actions include the installation of additional emission controls, which will capture releases in the event of a release due to a shutdown of primary controls. Additionally, Nepera reviewed and revised its cleaning procedures and installed temperature and pressure gauges which trigger alarms when such parameters begin to rise allowing operators to respond to such alarms and cease cleaning, if necessary, to prevent possible releases. Emergency Response Program The Nepera facility maintains an Integrated Contingency Plan, which has been coordinated with the local emergency response agencies and includes provisions for public notification in the event of a release. Nepera conducts regular emergency drills in cooperation with the local Fire Department and the Orange County LEPC. The facility maintains Guidelines and Procedures for Hazardous Materials Emergencies to be foll owed by on-site Emergency Response Team members as well as by external response agencies. Planned Changes to Safety Nepera, being aware of the effects of an accidental release of the regulated substances at the facility, maintains an Emergency Response Program and Integrated Contingency Plan. These plans are routinely reviewed and updated to ensure the safety of Nepera's employees, the general public and the environment. Additionally, Nepera has installed redundant control systems in many of our process operations including high-level cut-off controls, temperature and pressure level alarms. |