QCI, A ChemFirst Company- Tyrone Facility - Executive Summary |
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FACILITY DESCRIPTION QCI is a custom chemical manufacturer whose primary business is in the manufacture of fine chemicals for the agrochemical, bulk pharmaceutical, polymer, and photoactive markets, but we welcome the opportunity to evaluate projects from other markets. QCI was opened for business in 1976 by two entrepreneurs. In 1986, QCI was bought by First Chemical Company of Pascagoula, MS. First Chemical Company is a subsidiary of First Mississippi Corporation, who was restructured under the name of ChemFirst Inc. in late 1996. The facility is designed for maximum flexibility and is continuously upgraded to ensure safe operation, minimal waste, and top efficiency. We have more than 50,000 gallons of reactor capacity and a complete range of solids handling equipment. The plant is especially well-equipped for complex, multi-step synthesis. QCI's production operations consist of the batch production of specific and finite campaigns to produce chemicals for our customers. The facility's Quality and Environmental management systems are ISO 9002 (Quality) and 14001 (Environmental) registered. FACILITY POLICIES FOR ACCIDENTAL RELEASE PREVETION AND EMERGENCY REPSONSE Company environmental and safety/health policy statements stress the importance of protecting the safety and health of our employees as well as that of the community and the public. "The world's natural resources of air, water, and land are finite and must be conserved and protected. Life and health are precious and must be safeguarded. These beliefs compel us to conduct our business in a manner that protects the health and safety of our employees and the public...." "The personal safety and health of each employee of this company and the general public of Tyrone is of primary importance. The prevention of occupationally-induced injuries and illnesses is of such consequence that it will be given precedence whenever necessary. QCI will provide all mechanical and physical facilities required for personal safety and health, in keeping with the highest standards, applicable laws, and guidelines...." QCI is also committed to supporting a continuing effort to improve the chemical industry's responsible management of chemicals through the Chemical Manufacturers Association's Responsible Care. program. Using Responsible Care. as an umbrella, QCI manages its business in a manner which will: - recognize and respond to community concerns about chemicals and our operations. - develop and produce chemicals that can be manufactured, transported, used, and disposed of safely. - make health, safety, and environmental considerations a priority in our planning for all existing and new products and processes. - promptly report information on chemical related health or environmental hazards to officials, employees, customers, and the public. - counsel customers on the safe use, disposal, and transportation of our chemical products. - operate our facility in a manner that protects the environment and the health and safety of our employees and the public. - extend knowledge by conducting or supporting research on the health, safety, and environmental aspects of our products, processes, and waste material. - work with others to resolve problems created by past handling and disposal of hazardous substances. participate with governments and others in creating responsible laws, regulations, and standards to safeguard the community, workplace, and environment. - promote the principles and practices of Responsible Care. by sharing experiences and offering assistance to others who produce, handle, use, transport, or dispose of chemicals. - It is the obligation of every employee to adhere to the spirit as well as the letter of these policies. REGULATED SUBSTANCES HANDLED We handle three regulated substances that may be on-site in excess of their threshold quantity. These chemicals and their maximum intended inventory levels are: chlorine, 28000 pounds; anhydrous h ydrochloric acid, 8000 pounds; and hydrochloric acid (37% solution), 23000 pounds. Chlorine and anhydrous hydrochloric acid are gasses that are delivered and maintained in cylinders, while hydrochloric acid solution is a liquid that is stored in an 8000 gallon tank. Only one cylinder of chlorine and/or anhydrous hydrochloric acid is used at a time to feed the raw material to a batch. In addition to minimizing the inventory of these and other chemicals that are needed for our production operations, we also try to remove the chemicals from our site when they are no longer needed for a production campaign. WORST-CASE RELEASE SCENARIO A worst-case release scenario has been modeled for chlorine. An alternative release scenario has also been modeled for chlorine, and the worst-case release scenario is being presented as the alternative release scenario for the other regulated substances; all of the releases have off-site impact. For the worst-case scenario, a cylinder leaks and relea ses 2000 pounds of chlorine gas (the entire contents of the pressurized cylinder) in 10 minutes. The impact distance hypothetically could be up to 1.3 miles during the worse possible weather conditions. This scenario DOES NOT take into account the plant's safety and prevention systems, and assumes nothing is done to minimize the release. ALTERNATIVE RELEASE SCENARIOS The production area and operating personnel are equipped with gas monitors to detect process leaks. A chlorine transfer pipe fails during the transfer of chlorine. QCI personnel respond and manually stop the chlorine release within 15 minutes. Approximately 150 pounds of chlorine gas escapes as a vapor cloud. The gas hypothetically migrates 0.1 miles before dissipating below the calculated endpoint concentration. For anhydrous hydrochloric acid, a cylinder leaks and releases 600 pounds of hydrochloric acid gas (the entire contents of the pressurized cylinder) in 10 minutes. The impact distance hypothetically co uld be up to 1.1 miles during the worse possible weather conditions. This scenario DOES NOT take into account the plant's safety and prevention systems, and assumes nothing is done to minimize the release. For hydrochloric acid solution, a tank rupture causes the release of 23000 pounds. (The amount of material in the 8000 gallon tank is limited to 7200 gallons by written operating procedures and high-level alarms.) The liquid spills into a dike around the tank and evaporates over 10 minutes. The concrete dike around the tank limits the exposed surface area of a pool. The impact distance hypothetically could be up to 1.1 miles during the worse possible weather conditions. This scenario DOES NOT take into account the plant's safety and prevention systems, and assumes nothing is done to minimize the release. FIVE YEAR RELEASE HSITORY The facility did not have any reportable accidents in the last five years. The scenarios described above are hypothetical and have never occurred at this location. There has never been an off-site injury or environmental impact resulting from an accidental release of these regulated substances. GENERAL ACCIDENTAL RELEASE AND PREVETNION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS QCI prevents accidents at the plant by designing equipment for safe operation, installing and maintaining equipment in safe working order, training personnel to operate equipment safely, auditing to check and improve equipment and procedures, and maintaining a plant wide emergency response plan and in-plant emergency response personnel. In addition, QCI complies with OSHA's Process Safety Management standard, as required, and complies with the intent of the standard for all production projects. The following outlines QCI's general prevention and safety measures and specific measures relating to hydrochloric acid and chlorine. DESIGNING FOR SAFE OPERATIONS Rigorous safe operating limits are established for all projects. Industry and manufactur ing engineering standards and recommendations are followed. Protective bridges are used for pipe support/distribution system. Design safety reviews are conducted. Mechanical Integrity program is followed by maintenance and contractor personnel. Instrumentation and interlock system is incorporated in all processes. Valves and equipment are tagged and numbered for field identification. Process vents are connected to scrubbers and/or flares. MAINTAINING PLANT EQUIPMENT Preventive Maintenance program is established and conducted. Maintenance personnel and staff are qualified and highly skilled. Equipment is tested and rechecked by operators upon completion of system changes and repairs. Technology and equipment process changes are documented. Critical equipment including tanks, reactors, relief devices, piping, instrumentation and shutdown systems are tested and inspected to ensure proper operation. Design safety reviews are conducted for all system changes (Management of Change). Intern al vessel inspections are conducted before and after each project involving chlorine; other reactors and pressure relief devices are tested/inspected during the annual shutdown. OPERATING SAFELY Processes are computerized and continuously monitored by operators. Detailed operating instructions (Batch Records) are written for each project. Qualified and highly skilled operators run the plant safely; project-specific and general training is conducted. Entry into production areas is controlled, and work permit systems control work activities to ensure operational safety. Chlorine and Hydrogen chloride gas detectors are provided with alarms to signal for rapid response. Dedicated technical staff are available. All employees are trained in hazard and safety procedures. AUDITING OPERATIONS Independent audits and reviews are conducted by the Pennsylvania Department of Environmental Protection, United States Environmental Protection Agency, Occupational Safety and Health Administration, C ity of Tyrone, Registrars, and customers. Corporate audits are performed using Process Safety Management and other OSHA and environmental standards. Facility audits and reviews are performed with employee participation. Investigations are performed and documented with corrective actions taken for all incidents, accidents, and near misses. Pre-startup reviews are conducted prior to startup of new or modified equipment, or startup of new or modified projects. Process Hazard Analysis is conducted on all equipment and processes. Design changes are reviewed for proper design and completed documentation. PROCESS SAFETY MANAGEMENT PROGRAM DESCRIPTION Employee Participation Plan: QCI has an established and implemented a written plan that describes employee participation for each of the PSM program elements. Employee input during all stages and phases is critical. Process Safety Information: MSDSs are usually furnished by our customers, and they usually contain toxicity, PEL, physical, re activity, and corrosivity data. The R&D Department reviews this and other (i.e., thermal and chemical stability) information obtained from customers, and if the information is inadequate, testing of the reaction mixtures or compounds is performed. The Engineering Department generates a P&ID for each project so that the R&M Department can install the equipment as designed. The Engineering Department has determined the electrical classification for the various buildings and purchases equipment which meets these requirements. The Engineering Department designs the general ventilation systems for the production buildings and designs the local ventilation systems throughout the plant. Design Codes and standards that are used are a combination of QCI requirements, ChemFirst requirements, ASME Boiler Codes, NFPA Codes, and other applicable codes and standards. The Engineering Department reviews the process and generates a short process description and block flow diagram. It also review s proposed chemical usage and determines the maximum inventory levels. The Engineering Department reviews process chemistry and determines the corrosivity of raw materials and reaction mixtures. They then select the proper equipment which will withstand the corrosive effect of the various chemicals or mixtures. The Engineering Department develops relief system design using a computer program and often customer recommendations. The R&D Department develops material balances for the reactions. The Engineering Department generates a list of safety systems and engineering controls (i.e., interlocks, pressure relief devices, computer alarms and controls) which are used during a project. Process Hazard Analysis: The Production Project Coordinator, Safety Department, Production, and Customer representatives conduct a HAZOP for each project. Administrative control of the projects is maintained by the use of a Production Batch Record for each batch that is produced, Production Shift Supe rvisor Checklists for each shift, and Production Coordinator weekly production reports. Facility siting concerns are reviewed using a checklist developed by the Engineering Department. Human factors are covered during the HAZOP. The Quality Department has established Standard Operating Procedures for corrective action systems for both ISO 9002 and 14001. Operating Procedures: Production Coordinators write Batch Records for each project. The batch records are used as operating instructions for the production operators. The R&D Department develops procedures for emergency shutdown, emergency operations, and startup after an emergency; these are included in the batch records. The R&D Department also generates limits for temperature and pressure that are incorporated into the batch records. The Safety Department reviews the MSDS for each raw material and product, and the information is put into a batch record safety sheet which uses a standard format to make it easier for operator s to locate needed information. Raw material and product specifications are developed to maintain materials quality control. Training: The Production Project Coordinator conducts initial training for Production and R&M employees before each project starts. Refresher training is conducted prior to successive production campaigns. Contractors: Contractors use QCI Emergency evacuation procedures and safety permits, and QCI informs contractors of work and unique process hazards. Contractors attend QCI safety training programs and also have their own job training programs. The Safety Department maintains OSHA 200 logs for each contractor company. The Engineering and Safety Departments conduct periodic evaluations of the safety programs and performance for each contractor company. PreStartup Safety Review: A series of checklists are developed and implemented to ensure that all appropriate items are reviewed before projects are started. The Production Project Coordinator develops a list of recommendations from the HAZOP, and the recommendations are resolved before the project is started. Mechanical Integrity: The R&M Department has developed Standard Operating Procedures for Preventive Maintenance, and personnel are assigned to conduct the various PM items. The PM system is also a part of the ISO 9002 and 14001 systems, and these systems are each audited two times a year by third party auditors. The R&M Department conducts an annual shutdown each year in which additional equipment is inspected and/or tested. Certain equipment may also be inspected and/or tested by contractors. The R&M Department has developed and implemented a quality assurance program for various types of equipment to ensure that replacement parts meet initial design requirements (replacement in kind). Hot Work Permit: The Safety Department has developed and implemented a Hot Work Permit which is used by all QCI and contractor employees. Other permits (i.e., Line Breaking, Confined Sp ace, Lockout/Tagout, Safe Work, Elevated Work) are also implemented. Management of Change Procedure: Standard Operating Procedures are developed and implemented to describe when this procedure applies. If a change is needed for a project, the Project Coordinator initiates an MOC Procedure, and the MOC is reviewed by the appropriate personnel. The hard copy of the MOC is maintained in Production, and the MOC is also tracked in our computer network. Incident Investigation Procedure: The Production Shift Supervisor generates the initial incident report following any accident, incident, or close call. An investigation is held to identify root causes and to propose corrective actions. These suggestions are added to a computer tracking system where the are monitored until they are resolved. Information is shared with appropriate employees at the plant and at other company locations. Emergency Planning and Response: The Safety and Environmental Departments have developed several em ergency response plans for the site. Training and drills are conducted to ensure the plans are understood and followed. Audits: Process Hazard Analyses are conducted prior to each new campaign, and at least every five years for repetitive projects which last more than five years. Batch records are continuously reviewed and updated to ensure they are accurate and the production employees are following them. The Corporate Safety Department conducts a compliance audit at least every three years to certify compliance with the PSM standard. Trade Secrets: QCI does not claim any trade secrets. Emergency response program Several plans and procedures address emergency planning and response for the entire plant as well as procedures for handling localized releases. The Emergency Response Plan is updated to reflect any facility changes, and is coordinated with the Blair County Local Emergency Planning Commission (LEPC). Annually, all employees receive training in their duties unde r the plan, and the evacuation plan is practiced at least once each year. Each shift has a trained Emergency Response Team, that is equipped to respond to fires, spills and releases, and medical emergencies. Each Team is comprised of employees and is led by its shift supervisor, who assumes the role of Incident Commander during any on-site emergency. QCI emergency response personnel receive appropriate training (i.e., confined space rescue, SCBA, fire fighting, spill response); some members are also certified in CPR and first aid response. Drills are conducted at least twice/year for each crew's response personnel. The safety department determines the scenario for each drill. After the drill is completed, it is critiqued; the findings and recommendations are used to help design future drills and training exercises. Using this approach, each Team addresses specific response areas that need improvement. All production and maintenance employees are also trained to respond to spill s and releases, and all employees receive training in the use of hand held fire extinguishers to extinguish incipient stage fires. In addition, the facility is protected with a foam sprinkler system, and is also equipped with several outdoor fire monitors and wheeled fire extinguishers that may be used in the event of a larger fire. In addition to this emergency response training, all employees are instructed to activate the fire alarm and to evacuate the facility in the event of an emergency. We also utilize the emergency fire and medical response services provided by the City of Tyrone emergency response personnel; response time to our facility is about five (5) minutes. We provide periodic orientation and informational tours for off-site response personnel. These training sessions are often conducted in conjunction with the addition of new equipment and/or a new chemistry to the facility. QCI Emergency Response Teams also conduct training and emergency response drills in c onjunction with the City of Tyrone and Blair County response organizations. The 1993 Blair County mock drill was conducted at QCI; it involved a spill from a bulk tank and a fire. In 1996, QCI participated in a chlorine release drill with Tyrone fire companies; this scenario is similar to the chlorine worst-case release scenario identified in this plan. Planned changes to improve safety. Several changes are being planned to help improve safety. Additional members of response teams will be trained at the Delaware State Fire School; we attempt to send several employees each year. First Responder (medical) training is planned for this fall; employee volunteers will be sought. A "Corrective Action Team" is being organized to investigate and address potential point source ventilation issues. In addition, on a routine basis, we assess the effectiveness of many of our plans, programs, and activities; and develop and implement action plans to address any deficiencies. |