ADC - NF3 - Executive Summary |
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Risk Management Plan Executive Summary Anderson Development Company - NF3 Gulf Street Plant 1. Accidental Release Prevention and Emergency Response Policies Anderson Development Company is strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program that includes design, installation, operating procedures, maintenance, and employee training in the processes at our facilities. It is our policy to implement appropriate controls to prevent releases of hazardous substances. If such a release does occur, our highly trained personnel will respond to control and mitigate the effects of the release. We also coordinate our training and response efforts with the Adrian Fire Department which provides additional emergency response administrative capabilities. 2. The Stationary Source and the Regulated Substances Handled ADC manufactures high purity nitrogen trifluoride gas at our NF3 plant. The nitrogen trifluoride plant on Gulf Street has two RMP regulated materials onsite. Anhydrous ammonia and anhydrous hydrogen fluoride are the two basic raw materials for nitrogen trifluoride production. Maximum inventories of these RMP chemicals at the Gulf Street plant exceed the RMP threshold quantities. 3. The Worst Case Release Scenario and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario. Required offsite consequence analysis for both plants have been performed using the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The anhydrous hydrogen fluoride storage tank is filled via tank truck carrying a maximum 35,000 pounds of anhydrous hydrogen fluoride. If the entire contents of the tank truck were to be released in a 10 minutes under the most unfavorab le atmospheric conditions, the plume could reach many miles when calculated to the EPA's toxic endpoint of 0.016 ppm. Such a major raw material tank truck failure constitutes the worst case release scenario for the nitrogen trifluoride process. The anhydrous ammonia storage tank at our Gulf Street plant has a maximum content which could extend a few miles under the most unfavorable atmospheric conditions (or half a mile under typical atmospheric conditions) of a complete release lasting 10 minutes when using the EPA's 0.14 ppm toxic endpoint. A major storage tank failure such as this constitutes the most serious alternative release scenario involving anhydrous ammonia. The anhydrous hydrogen fluoride storage tank uses another empty storage tank below it to provide sealed secondary containment, and is located inside a fully enclosed cement storage building for tertiary containment. Because of these passive mitigation measures, only 10% of the maximum storage tank inventory could poss ibly be involved in a 10 minute release under the most unfavorable atmospheric conditions would reach a few miles (or just over a mile under typical atmospheric conditions) when calculated to the EPA's toxic endpoint of 0.016 ppm. Such a major storage tank failure constitutes the most most serious alternative release scenario involving hydrogen fluoride. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps ADC has taken all necessary steps to comply with the accidental release prevention requirements. Both of our Adrian facilities meet all requirements of State Building Codes and MIOSHA' s Process Safety Management standard for chemical processes, as well as the Community Right To Know notification requirements of EPCRA and TRI. The following sections briefly describe the elements of the accidental release prevention program in place at ADC's NF3 Gulf Street facility. Process Safety Information - Detailed records of process sa fety information describing chemical hazards, operating parameters and equipment designs are maintained for all processes. Process Hazard Analysis - Comprehensive HAZOP studies are conducted for our chemical processes to ensure that all potential hazards are identified and controlled efficiently. The methodology for these logic analyses is generally a software package of "what if" checklists. The studies are performed by teams of qualified personnel from engineering, safety, management, and operators who are familiar with the operational details of each particular process. The studies are revalidated at intervals of three years or whenever major process changes occur. Any findings related to the hazard analysis are addressed. Operating Procedures - Written operating procedures are maintained for all processes. These procedures cover initial startup, normal operations, temporary conditions, normal shutdown and emergency shutdown. The information is regularly reviewed and routinely fo llowed by process operators. Training - Our comprehensive training program is the basis for certification of the process specific competency of each operator. Refresher training is provided every three years at the time of PHA reviews. Mechanical Integrity - ADC performs documented maintenance checks on process equipment to ensure reliable operations. Process equipment inspected includes: reactors, storage tanks, piping systems, relief and vent systems, emergency generators and shutdown systems, pumps, and control systems. Maintenance operations are performed by qualified personnel trained and certified in maintenance practices. All identified deficiencies are corrected in a safe and timely manner. Management of Change - Necessary process changes to chemicals, technology, equipment and procedures are made in accordance with methodical written management procedures. Process operators and maintenance personnel are informed of and provided training to safely and reliably deal with nec essary process modifications. PreStartup Safety Reviews - Whenever startups of new processes or modified processes occurs, a hands on review is conducted to confirm that construction, equipment, operating and maintenance procedures are suitable before equipment is placed into operation. Compliance Audits - Extensive reviews of all compliance aspects of accident prevention programs are performed every three years. Prompt corrective actions are performed upon audit completion. Incident Investigation - Any incident that has resulted in, or could reasonably result in the release of a hazardous substance is promptly investigated. These investigations are undertaken to identify the root cause of each incident as well as to identify any corrective actions to prevent releases from occurring. Employee Participation - Process safety and accident prevention are a team effort. All process employees are included in discussions concerning accident prevention issues and to recommend improvemen ts. All process employees have access to all information in the accident prevention program, especially information from process hazard analyses. Contractors - ADC hires numerous area contractors to perform specialized maintenance and construction activities. The safety programs and performance of all contractors are evaluated and continually monitored. All individuals working for contractor firms hired by ADC receive annual safety training from ADC's Safety Department. ADC informs all contractor workers of known potential hazards related to each project's plan of action. All contractors are also informed of emergency response procedures and required to cease working should an accidental release occur. 5. Five Year Accident History There have been no accidental releases of RMP regulated chemicals in quantities greater than one pound from ADC's NF3 facility. 6. Emergency Response Plan ADC has developed a written comprehensive emergency response plan to deal with all emer gencies, including the accidental release of hazardous substances. The plan covers all aspects of emergency response including first aid and medical treatment, evacuations, shelter in place, notification of local emergency response agencies and the public, as well as post incident decontamination of affected areas. All emergency response equipment is regularly inspected and serviced. The emergency plan is promptly updated to incude response to any process changes. 7. Planned Changes to Improve Safety ADC strives to continuously improve and update operating procedures, replace or maintain equipment to meet or exceed original specifications or design codes and to develop and implement safety improvement capital projects. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Randy Gibbs Title: Environmental Manager Da te: 28 June 1999 |