Ausimont USA, Inc.- Thorofare Plant - Executive Summary |
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AUSIMONT USA, INC. THOROFARE PLANT RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies At the Ausimont USA Thorofare Plant, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. We are a member of the Chemical Manufacturers Association (CMA) Responsible Care Program. The CMA Responsible Care Program goes beyond the boundaries of regulatory compliance and strives for continuous improvement in industry operations and processes by incorporating health, safety, and environmental protection into all stages of a products life - design, manufacture, marketing, distribution, use, recycling, and disposal. The Thorofare plant participates in the Mantua Grove Community Advisory Panel of local citizens who meet regularly with plant management to discuss various issues, especially those related to environmental, safety, and health. This mechanism was established to better understand and address the needs and concerns of the local community. Ausimont has been proactive in communicating our risk management program with the community. A RMP Community Awareness event was held on May 1, 1999 and included participation by local industry and the local emergency response community. Everyone was invited to tour our plant and employees and management were available to answer questions. Information was distributed that explains our plant's safety programs, release scenarios, and emergency response program. This information was also put on file in the local library for reference by the community. The following is taken from Ausimont's Corporate Safety Policy: Ausimont USA, Inc. ("Ausimont") is committed to provide a safe and healthy working environment for its employees and the e mployees of contractors working at Ausimont sites, and to provide a safe and healthy environment for the communities in which we operate. It is also the policy of Ausimont that all our operators are in compliance with applicable laws and regulations. Additionally, it is Ausimont's policy to supply all available information pertaining to safe handling and use of its materials to customers. The following specific points are included in Ausimont policy. - Ausimont, in all its operations, is committed to achieving excellence in safety. All other activities should be consistent with this goal. - Compliance with safety and environmental laws and regulations is our top priority. No other operations will take priority over this objective. - It is Ausimont's premise that all accidents and injuries are preventable. Therefore, every reasonable and practical effort will be made in the interest of preventing accidents that cause personal injury or property damage, both inside the corpor ation and outside. - Safety is the direct responsibility of all levels of line management and is an important measure of managerial performance. The Thorofare Plant recognizes and is concerned that every employee shall be furnished a safe and healthful place to work, free from recognized hazards that might cause serious injuries and illness. Every effort will be made in the interest of accident prevention, health preservation, and fire protection. The long established policy of the Thorofare Plant is that: - The personal safety and health of its employees shall be of primary importance and that occupational safety and health always takes precedence over expediency. - Every effort shall be made to prevent or eliminate accidents and health hazards. - Every member of supervision is responsible and accountable for the occupational safety and health of all employees under their direction. - The working environment shall comply with or exceed state and federal regulations. - A ll employees shall be trained and encouraged to develop and use safe work habits. 2. Stationary Source and Regulated Substances Ausimont USA has developed and currently markets a family of fluorine based products that are noted for their exceptional resistance to chemical agents and environments which attack and degrade other materials. Produced at the Thorofare, NJ facility are various grades of HYLAR. PVDF, which are used in the formulation of corrosion resistant coatings for aluminum and steel as well as long-life decorative finishes on building panels. The Thorofare plant, which became fully operational in 1985 and was purchased by Ausimont USA in 1990, was the world's first PVDF manufacturing facility to gain ISO 9002 certification. In our processes, we use the following chemicals that are covered by the EPA's RMP regulations: Toxics Chlorine is used at Ausimont as a catalyst in the manufacture of Vinylidene Fluoride (VF2), which is used to produce Polyvinylidene Fluoride ( PVDF). Chlorine is stored in railcars and is fed directly to the process. Hydrogen Fluoride is used at Ausimont as a raw material in the manufacture of Vinylidene Fluoride (VF2), which is used to produce Polyvinylidene Fluoride (PVDF). Hydrogen fluoride is offloaded from railcars into storage tanks located in the process area. Flammables Vinylidene Fluoride (VF2) is produced at our facility and is either used to produce Polyvinylidene Fluoride (PVDF) or sold. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. 3. Offsite Consequence Analysis Scenarios EPA's RMP rule requires that we provide information about the worst-case release scenarios and alternative release scenarios for our facility. The following are brief summaries of these scenarios: Worst-case Release Scenario - Toxic The worst case release scenario f or chlorine assumes the loss of the entire contents of a chlorine railcar within 10 minutes with the maximum possible amount (180,000 lbs.) in the railcar at the time of its failure. Based upon the Original EPA Guidance, the distance from the source of the plume to its endpoint would include offsite endpoints and nearby public receptors. Worst-case Release Scenario - Flammable The worst case release scenario for vinylidene fluoride assumes the loss of the entire contents of the largest storage tank on site with the maximum possible amount (265,000 lbs.) in the tank at the time of its failure. Based upon the Original EPA Guidance, the distance form the source of the vapor cloud explosion to its endpoint would include offsite endpoints and nearby public receptors. Alternative Release Scenario - Chlorine The alternative release scenario for chlorine is a gasket failure, equivalent to a 1/8 inch hole in a chlorine railcar unloading line. Based upon the Original EPA Guidance, the di stance from the source of the plume to its endpoint would include offsite endpoints and nearby public receptors. Alternative Release Scenario - Hydrogen Fluoride The alternative release scenario for hydrogen fluoride is a flange leak equivalent to a 1/4 inch hole in the transfer line. Based upon the Original EPA Guidance, the distance from the source of the plume to its endpoint would include offsite endpoints and nearby public receptors. Alternative Release Scenario - Vinylidene Fluoride The alternative release scenario for vinylidene fluoride is a flange leak equivalent to a 1/8 inch hole in the transfer line. Based upon the Original EPA Guidance, the distance form the source of the vapor cloud fire to its endpoint would not extend offsite. 4. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The facility is regulated under the OSHA Process Safety Management Standard and the New Jersey Toxic Catastrophe Prevention Act (TCPA) which regulate th e management of process safety. TCPA predates the OSHA standard and exceeds federal requirements, including annual self-auditing, submission of an Annual Report to the State, and annual inspection by the NJ Department of Environmental Protection (NJDEP). Our management systems address each of the key features of successful prevention programs including: Process Safety Information: We keep a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters, and equipment design basis/configuration information. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. Process Hazard Analysis: A comprehensive program ensures that hazards associated with the various processes are identified and controlled. Within this program, each process or process change is systematically examin ed to identify hazards and ensure that adequate controls are in place to manage these hazards. This is performed by a team which identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes recommendations for additional prevention and/or mitigation measures when deemed necessary. Standard Operating Procedures: Operating procedures for each area provide clear daily instructions for safely conducting activities involved in each process, consistent with the process safety information. The written procedures address steps for each operating phase, operating limits, emergency shutdown procedures, and safety and health considerations. Training: We have established a comprehensive training program to certify operators in both unit operations and emergency response procedures. This requires operators to demonstrate (through written testing and hands-on examinations) that they have adequate knowledge before they can work independentl y. This training includes emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. There is annual refresher training for all operators on the operating procedures and chemical hazards of the process. Mechanical Integrity: An established preventive maintenance and equipment integrity program promotes that all process equipment is operating within approved limits. The initial and on-going integrity of process equipment is ensured by determining that the equipment is designed, installed and maintained properly. This includes testing and inspection of equipment and quality assurance checks of equipment, spare parts and maintenance materials. Any deficiencies which are found are required to be corrected before the equipment is returned to service. Management of Change: A compliance program ensures that changes to equipment, chemicals, technology (including process operating conditi ons), and operating procedures are properly reviewed and authorized before being implemented. Changes are reviewed to confirm that adequate controls are in place to manage the change and that existing controls have not been compromised by the modification. All changes are verified with a pre-startup safety review, all relevant process safety information is updated, and all affected employees are notified of the change. Pre-startup Safety Review: A pre-startup safety review is performed for all modifications which resulted in a change in the process safety information. This review ensures that all construction and equipment is in accordance with the design specifications; the safety, operating, maintenance, and emergency procedures are current and adequate; a process hazard analysis has been performed if required and that all recommendations have been addressed; and that employees have been trained on the change. Compliance Safety Audits: An annual audit is performed to verify th at all procedures and practices developed under the process safety standard are adequate and are being followed. This is performed by a audit team of both hourly and management personnel. All findings of the audit are promptly addressed and are tracked to ensure they have been corrected. Incident Investigation: We promptly investigate all incidents, however minor, and take corrective actions to prevent reoccurrence. A team is assembled, consisting of both operations and management, to determine the facts and develop recommendations which are tracked to completion. These are reviewed with all employees during monthly safety meetings, as well as any recommendations from our employee safety committee. Employee Participation: We encourage employees to participate in all areas of process safety management, including the conduct and development of process hazard analysis and other process safety information. The Employee Safety Committee meets once per month to review new informati on and address the concerns of the plant employees. Hot Work Permit: A permit is required to be issued before any hot work operations can be performed on or near a processing area. This ensures that all fire prevention and protection have been implemented and that employees in the area are aware of the activity. Contractors: All contractors working in the plant receive training on all facility rules and regulations, chemical/process hazards, and emergency procedures. The contractor's safety records are pre-screened before they are hired, and they are periodically audited to ensure that they are working safely and following all plant rules and regulations. Inspections: The employee safety committee participates in quarterly plant inspections to help find and correct any unsafe working conditions. There are also weekly process unit safety inspections by the operators and periodic management inspections. Monitoring: A computer controlled monitoring and process system continuousl y evaluates key system conditions with alarms/interlocks/shutdown to a manned control room and routine checks are conducted every work shift to promote safe operations. As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Chlorine Alarms: Sensors immediately alert both operators in the chlorine unloading area and the continuously monitored computer system in the control room if a leak were to occur. The chlorine railcar is equipped with automatic shutoff valves that can be activated remotely. System Design: The chlorine piping systems are designed to vent to a scrubber. Chlorine railcars are covered by the Chlorine Institute requirements for design, as well as DOT regulations for operations and maintenance. All chlorine railcars are also equipped with a relief valve to prevent overpressure of the car and an excess flow valve to stop flow in the case of a line rupture. Hydrogen Fluoride Alarms: Computer controlled monitorin g and process system that monitors key system conditions with alarms/interlocks/shutdown to a manned control room. The hydrogen fluoride storage tanks are equipped with high level alarms and automatic shutdown valves which can be activated remotely from the control room. A video camera system allows 24 hour remote monitoring of the facility. System Design: The HF storage tanks and piping are constructed of materials which are resistant to corrosion and the HF storage tanks are contained in a diked area which drains to a sump. The hydrogen fluoride railcars are constructed to meet the DOT requirements and are inspected periodically. All HF railcars are also equipped with a relief valve to prevent overpressure of the car and an excess flow valve to stop flow in the case of a line rupture Vinylidene Fluoride Alarms: Computer controlled monitoring and process system that monitors key system conditions with alarms/interlocks/shutdown to a manned control room. All Vinylidene Fluori de process equipment is equipped with instrumentation and alarms to notify operators of high level and pressure conditions and is cooled to low temperatures. System Design: Storage tanks and piping are kept at low temperatures and are constructed of corrosion resistant materials. The process piping is double-walled with coolant in the outer layer. The process is equipped with overpressure protection and a fire protection system to prevent weakening due to fire. 5. Five-year Accident History There has not been an accident from a covered process that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage involving chlorine, hydrogen fluoride or vinylidene fluoride in the past five years at this facility. 6. Emergency Response Program The Emergency Response Program is designed to assure that the Ausimont USA employees are prepared to respond to emergency situa tions which may occur at the facility. The Program involves the following elements: Emergency Response Plan- We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. The plan includes instructions for: emergency reporting and plan activation, notification of emergency responders, emergency shutdown procedures, establishment of a emergency command center and field command post, duties of key individuals, procedures for fire, chemical release, off-site spills, hurricane, and bomb threat, evacuation procedures, HAZMAT procedures, and emergency response equipment information. Our Emergency Response Plan has been coordinated with local emergency management services. Local community emergency responders also participate i n annual drills at the facility. There is a post-drill review of all exercises to access the effectiveness of the Emergency Response Plan. Ausimont is currently an active member of the mutual aid organization, Tri-State Fire and Safety Group. Equipment from surrounding companies is made available in the event of an emergency. Also, the plant retains emergency response contractors, OHM Corporation and HHMTTC, with an estimated response time of two hours. Emergency Response Training- All emergency response team members receive annual training in: alarm identification and response, response to an EHS or other type of release, use of personal protective equipment, rescue procedures, evacuation procedures, medical / first aid procedures, action plans dealing with specific scenarios, specifically assigned emergency response duties, regulations review, hazard communication / toxicology / health hazard review, air monitoring equipment, incident command system, work zones and decontami nation, containment procedures and spill control techniques, confined space review, and comprehensive testing to verify understanding of the material. Emergency Response Equipment and Systems- In the event of an emergency, the following is some of the response equipment available onsite so mitigation activities can begin immediately: - Highly trained emergency responders on every shift - Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) - Valves to permit isolation of the process (manual or automated) - Automated shutdown systems for specific process parameters (e.g., high level, high temperaure) - Vessel to permit partial removal of the process inventory in the event of a release (e.g., dump tank) - Curbing or diking to contain liquid releases - Fire suppression and extinguishing systems - Deluge system for specific equipment - High pressure firewater system with remote and manual water spray suppression systems to coo l equipment and to dilute and disperse vapors - Video camera system offers 24 hour remote monitoring of the facility - Chlorine "C" Kit to seal leaks from the railcar unloading valves - Spill containment equipment and supplies - Plidco Flanges to stop pipeline flange leaks of gases or liquids - Redundant equipment and instrumentation (e.g., backup power supply for process control system, backup firewater pump) - Air monitoring equipment - Meteorological equipment - Neutralization of liquid spills - Two-way radio communication with emergency responders - Hazardous Material Response Vehicle An off-site Emergency Command Center (ECC) is set up and includes telephone, fax, and PC capability for use in the event of a major release. The ECC will be activated by the Emergency Response Coordinator and used by the plant management to coordinate auxiliary response efforts. 7. Planned Changes To Improve Safety In preparation for submittal of our RMP, Ausimont US A has just completed installation of several new and upgraded safety systems at our facility. Automated valves have been installed at the chlorine railcar unloading area which can be activated remotely to automatically close the valves on the railcar. Larger railcars have been utilized to decrease the number of changeovers required and the piping has been simplified in this area, in order to reduce the chances of problems during railcar switching. The chlorine detectors have also been upgraded in this area. The firewater system in the plant has also just been upgraded to include additional high pressure monitors and nozzles throughout the processing and storage areas. These nozzles can be activated and controlled remotely from the control room, allowing operators to begin mitigation activities immediately. When used in conjunction with the plant's video camera system, they can be remotely directed to knock down plumes and to dilute and disperse vapors. Ausimont is currently eva luating the following items for future use in our facility: new process technology which we foresee as a possible replacement for Hydrogen Fluoride in our process; perimeter monitors; and the upgrading and simplification of process vessels and piping. We will continue to incorporate the findings from incident investigations and the recommendations developed during process hazard analysis as a means of continuously improving the safety at the Thorofare Plant. |