Keil Chemical Division - Executive Summary
Keil Chemical Risk Management Plan: Executive Summary |
1.1 Accidental Release Prevention and Response Policies
The Ferro Corporation, Keil Chemical Division (Ferro-Hammond) is committed to worker and public safety. The resources invested in accident prevention such as the training of personnel and consideration of safety and prevention in the design, installation, operation, and maintenance of our processes demonstrate this commitment. Our policy is to prevent releases of substances. If a release does occur, Ferro-Hammond's trained personnel, supplemented by the Hammond Fire Department, Hammond Emergency Management Agency, and Lake County Emergency Planning Commission will respond, if needed, to control and contain the release.
1.2 Description of the Stationary Source and Regulated Substances
Ferro-Hammond manufactures and processes specialty chemicals in Hammond, Indiana. Raw material, intermediate and process storage tanks, and chemical manufacturing processes are in use at th
e site. These are evaluated to determine the regulated flammable or toxic substances which exceed the threshold quantity as set forth in regulations issued pursuant to the Clean Air Act, Section 112(r).
The site uses two regulated toxic substances in two different processes. The regulated substances, process unit, largest quantity in a single process, and their threshold quantities are shown below in Table 1.
Summary of Regulated Substances
Regulated Substances Process Largest Quantity In a Single Process Threshold Quantity
Chlorine Chlorination 180,000 10,000
Ethylenediamine Fuel Additives 90,000 20,000
The two Ferro-Hammond chemicals are classif
ied as Program 3 under the Accidental Release Prevention (ARP) Program. Using the EPA risk analysis format, the distances to endpoints [i.e., Emergency Response Planning Guideline level 2 (ERPG-2)] for chlorine and ethylenediamine exceed the distance to the nearest public receptors (i.e., off-site residences, institutions, industrial and commercial office buildings, parks, or recreational areas inhabited or occupied by the public). Ferro-Hammond is regulated by to Occupational Safety & Health Administration (OSHA) Process Safety Management (PSM) rule and operates within a listed Standard Industrial Code (2899).
1.3 Off-Site Consequence Analysis Results
1.3.1 Worst-Case Releases (EPA Required Format)
Regulated Toxic Substances
Endpoint distances for regulated toxic substances can be determined by the ERPG method. Toxic endpoints are listed in Appendix A, 40 CFR Part 68 (Table of Toxic Endpoints). The two regulated substances at Ferro-Hammond were reviewed using the EPA look-up
tables to determine which had the greatest distance to an endpoint. Chlorine indicated the greatest distance, therefore this is the scenario being reported as the worst-case.
A worst-case release, as defined by the U.S. Environmental Protection Agency (EPA), involves the complete release, over a 10-minute period, of the largest amount of a regulated toxic substance from a process at the facility during weather conditions that would allow the release to have the greatest distance of impact. Additionally, the EPA requires that these distances be calculated assuming that none of the active safety systems that could minimize the effects of the release would be used and that no emergency actions to stop or minimize the release would be taken.
Under these stringent and extremely unlikely conditions, the accident that would have an impact the farthest away from the Keil facility would result from the failure of a full railroad car of chlorine. In this scenario, a total of 180,000 pounds
of chlorine would be released and - based on the very conservative EPA model that assumes no response by our workforce and that all controls and protective systems fail - spread as far as 14 miles.
1.3.2 Alternative Releases (EPA Required Format)
Alternative release scenarios are those that are more likely to occur. EPA requires that the selected alternative release scenarios for toxic substances be limited to those that lead to concentrations above the endpoint beyond the facility=s fence line. The following conditions are considered for alternative release scenarios:
Release rate is dependent upon scenario;
Use of typical meteorological conditions ;
Actual release height;
Consideration of active mitigation systems; and
Passive mitigation systems.
An alternative release scenario was developed for each regulated toxic substance.
For chlorine, the alternative-case scenario was caused by improper valve operation. As a result of improperly aligning the valve, chlorine was sen
t to a caustic scrubber. The large volume of chlorine caused a rapid depletion of the caustic scrubbing solution and therefore eliminated the mitigation capabilities causing 4,524 pounds of chlorine to be vented, unabated through the scrubber stack. The release was discovered and stopped within 10 minutes due to emergency shutdown and back-up systems. This type of release resulted in a 0.21-mile distance to the toxic endpoint.
For ethylenediamine, the overfilling of a tank caused the alternative-case scenario. The release is discovered and contained using active and passive mitigation systems. Upon discovery, the transfer pumps were immediately shutdown and 2,082 gallons of ethylenediamine were contained within the diked-area. Of the 2,082 gallons of spilled material 1,872 pounds of this was released within 5 minutes. This release scenario resulted in a 0.05-mile distance to the toxic endpoint
1.4 General Accidental Release Prevention Program
The site has an accidental rele
ase prevention program in place. Processes at the plant regulated by the EPA=s risk management program (RMP) are also subject to OSHA=s PSM standard. This summary identifies each of the OSHA PSM and RMP elements and describes the management system in place to ensure accident prevention.
1.4.1 Process Safety Information
Ferro-Hammond maintains a variety of technical documents that are used to assure safe operations. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific assignments are made to ensure there is responsibility for maintaining up-to-date process safety information. Tables are made available to employees summarizing the reference documents and their locations. This helps employees to easily locate and use process safety information.
Chemical-specific information, including exposure hazards and emergency response/ exposure trea
tment considerations, is provided in material safety data sheets (MSDSs) and other documents. For specific process areas, Ferro-Hammond has documented safety-related limits for critical process parameters (e.g., temperature, pressure, composition). The process is maintained within these limits using process controls and monitoring instruments, emergency relief systems, redundant safety systems, trained personnel, continuous oversight, and/or protective instrument systems (e.g., shutdown systems).
1.4.2 Process Hazard Analysis (PHA)
Ferro-Hammond has a comprehensive program to ensure that hazards associated with the various processes are identified and controlled. Each process is systematically examined to identify hazards and evaluate the controls, including the need for redundancy. The goal is to prevent accidents and releases.
Ferro-Hammond primarily relies on the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as
one of the most systematic and thorough hazard evaluation techniques available. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.
The PHA team findings are forwarded to on-site management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking as assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk potential receives immediate attention. The PHA team findings are tracked until they are completed and the final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards do not even
tually deviate from the original design safety features, Ferro-Hammond periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years. The results and findings from these updates are documented and retained.
1.4.3 Operating Procedures
Ferro-Hammond maintains written procedures that address the various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures are used as a reference by experienced operators and provide a basis for the consistent training of new operators. These procedures are periodically reviewed and are kept current and accurate by revising them as necessary to reflect changes made through the management of change process.
In addition to the operating procedures, Ferro-Hammond has an array of work practices in place to safeguard worker and process saf
ety. Examples of these include (1) control of the entry/presence/exit of personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, anb (4) a permit procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of personnel, form a system that ensures operation and maintenance activities can be performed safely.
Ferro-Hammond has a comprehensive training program for all employees. New employees in operations and maintenance receive basic training in plant operations or demonstrate that they already have those skills. After successfully completing training a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) adequate
knowledge to perform the duties and tasks in a safe manner on their own they can work more independently. All operators periodically receive refresher training on the operating procedures to ensure their skill and knowledge is maintained at an acceptable level. This training is documented separately for each operator, including the means used to verify that the operator understood the training.
All site employees attend monthly environmental, health, and safety meetings. Each monthly meeting covers a different environmental, health, or safety topic. Some of the topics covered in 1999 include spill kit hands-on training, personal protective equipment, and spill response drills.
1.4.5 Mechanical Integrity
Ferro-Hammond has practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) training, (2) written
procedures, (3) inspections and tests, (4) correcting identified deficiencies, and (5) quality assurance measures. In combination these activities form a systematic review of the mechanical integrity of each process.
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures provide assurance that work is performed in a consistent manner. Inspections and tests are performed to provide assurance that equipment can and will function as intended and to verify that equipment is maintained within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified it is corrected before placing the equipment back into service or temporary control measures are used to ensure safety is not compromised.
Another integral p
art of the mechanical integrity program is quality assurance. Ferro-Hammond incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper material and spare parts are used when repairs are made.
1.4.6 Management of Change
Ferro-Hammond has a comprehensive system to manage changes made to processes covered by the OSHA Process Safety Management rule. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information as well as procedures are updated to inco
rporate these changes. Operating and maintenance personnel are trained regarding the changes.
1.4.7 Pre-Startup Safety Reviews (PSSRs)
Ferro-Hammond conducts a PSSR for any facility modification that includes a change that might in some way affect process safety. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriate for safe startup and operation prior to placing the equipment into service. This review provides additional checks to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
1.4.8 Compliance Audits
To ensure that the accident prevention program is functioning properly, Ferro-Ham
mond periodically conducts an audit to determine the extent to which the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
1.4.9 Incident Investigation
Ferro-Hammond promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team d
ocuments its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team=s findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years.
1.4.10 Employee Participation
Ferro-Hammond encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from analyzing, updating, and compiling process related technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have 24-hour access to information used in Ferro-Hammond=s accident prevention program. Protect
ion and continuous improvement are the themes of the site's program.
The ways that employees are involved in the accident prevention program are documented in an employee participation plan maintained at the plant. Specifically, teams are formed to promote process and personal safety. The teams are comprised of members from various units in the plant including operations, maintenance, engineering, and plant management.
1.4.11 Hot Work Permits
Ferro-Hammond has an array of work practices in place to safeguard worker and process safety. One of these is a permit procedure to control spark-producing activities (i.e., hot work). This procedure (and others), along with training of personnel, form a system that ensures operation and maintenance activities can be performed safely.
Ferro-Hammond uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Some contractors work on or near process equipment so the plan
t has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) are trained and have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, Ferro-Hammond evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
1.5 Chemical-Specific Prevention Steps
The processes at Ferro-Hammond have hazards that must be managed to ensure safe operatio
n. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility.
1.5.1 Universal Prevention Activities
The accident prevention program is applied to all RMP-covered processes at Ferro-Hammond. Various activities combine to prevent potential accidents that could result from equipment failure and/or human error.
1.5.2 Specialized Safety Features
Ferro-Hammond has safety features in place that (1) quickly detect a release, (2) contain/control a release, and (3) reduce the consequences of (mitigate) a release. The following examples illustrate some of the safety features that are used in the covered processes:
7 Chlorine sensors continuously monitor ambient air.
7 An air quality system monitors the perimeter of the plant.
Release Containment and Control
7 Automatic isolation valves within the process.
7 Curbing or diking to control liquid releases.
7 Redundant equipment and instrum
7 Ongoing efforts to minimize on-site inventory of toxic chemicals.
7 Fire extinguishing systems.
7 Trained Emergency Responders and routine training drills.
7 Arrangements with off-site responders.
1.6 Five-Year Accidental Release History
For the two processes covered by the rule there have been 4 accidental releases with on-site affects and 0 accidental releases with off-site affects during the past five-years (1994 to 1998) that are reportable in this section under the criteria established in 40 CFR Part 68.42. RMP reportable releases of ethylenediamine occurred in 1994 and 1995. The largest of 20 pounds occurred in April 1995. These releases are reportable because of their on-site affects, which resulted in OSHA recordable injuries of 3 employees.
RMP reportable releases of chlorine occurred in 1997 and 1998, each release was approximately 1 pound. These releases are reportable because of their on-site affects, which resulted in OSHA record
able injuries of 2 employees.
Each release resulted in an incident investigation and corrective actions, if necessary. Please see the appropriate section for additional information on how incident investigations help the Ferro-Hammond site to prevent future releases and to continuously improve our processes.
1.7 Emergency Response Program Information
Ferro-Hammond maintains a written Emergency Action Plan (EAP) which is followed to protect worker and public safety and the environment during an emergency. The plan includes procedures for responding to a release of a regulated substance. The procedures address emergency response, including first aid and medical treatment for exposures, evacuation, personnel accounting, notification of local emergency response agencies and the public, and post-incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instruc
tions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The EAP is updated when necessary and is sent to local, county and state authorities.
The overall emergency response program is coordinated with the Hammond Fire Department. This coordination includes periodic meetings between Ferro-Hammond personnel and the Hammond Fire and Police Departments personnel. Ferro-Hammond has 24-hour communications capability with the Hammond Fire Department. They have the ability to communicate to all state, federal and county agencies as to needed equipment (i.e., firefighting equipment, manpower, ambulances, hospitals, law enforcement, and HAZMAT operations). In addition to periodic meetings with the Hammond Fire Department personnel, Ferro-Hammond conducts periodic emergency drills that involve the Hammond Fire Department and emergency response organizations. The plant provi
des annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant.
1.8 Planned Changes to Improve Safety
Ferro-Hammond maintains a continuous improvement program. Some elements in that program include:
< Process Hazard Analysis
< Management of Change
< Compliance Audits
Additionally, Ferro-Hammond continues to explore state-of-the-art changes that could either reduce the use of air toxics or flammables or make the processes even safer.