Aerojet- General P&ES - Sacramento - Executive Summary

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Introduction 
 
A Risk Management Program (RMP) has been implemented at Aerojet Propulsion and Energetic Systems (P&ES) Sacramento site for the reduction of accidental releases of hazardous materials. The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Risk Management Plan is organized to correspond with specific U.S. Environmental Protection Agency (EPA) RMP definitions and requirements, including: 
 
Introduction; 
Aerojet's Commitment to Safety; 
Description of the Stationary Source and Regulated Substances; 
Hazard Assessment; 
General Accidental Release Prevention Program; 
Five-Year Accident History; 
Emergency Response Plan; and 
Planned changes to improve safety. 
 
 
Aerojet-General Corporation is committed to comply with the requirements of the Risk Management Program regulations. We are concerned, however, that the Worst-Case Scenarios required to be disclosed 
under the RMP regulations do not represent accurate definitions of risk. The Worst-Case Analysis, as specified by the RMP regulations, requires the use of very specific assumptions, most of which are unrealistic. For example, in the Worst-Case Analysis, Aerojet must assume that all safety systems currently in place to prevent a catastrophic release will fail and that all cleanup measures for a chemical spill or release will not be implemented. Additionally, it must be assumed that all Aerojet Fire Service and Central Station/Plant Protection personnel (on-site 24 hours a day 365 days a year) cannot initiate contingency plans and will be non-responsive to the situation. Finally, the meteorological conditions required to be used in the Worst-Case analyses, cannot physically exist. The Alternative Release Scenarios are, by definition, more likely to occur than the Worst-Case Scenarios. These Alternative Release Scenarios serve to demonstrate the ability of Aerojet to minimize the impact  
of a more realistic release to the community. If a release were to occur, Aerojet has an array of mitigation measures to reduce the potential impact. When these mitigation systems are taken into account, the impacts of the Alternative Release Scenarios do not extend beyond the Aerojet Sacramento site boundary. 
 
Aerojet's Commitment to Safety 
 
Aerojet management is and has been committed to safety as a number one priority since operations began in Sacramento County in the early 1950s. Strict operating controls and safety standards have been in place from the very beginning, including a system for reporting, investigating, and preventing accidents. Aerojet maintains a staff of Security, Safety, Industrial Hygiene, Fire Service and Environmental personnel to oversee the various programs that implement this commitment. 
 
Today, the experience gained from almost 50 years of rocket manufacturing and testing has resulted in one of the most impressive safety records in the aerospace industry; i 
ncidents involving regulated substances have been rare and minor in nature. Recognition of the potential hazards associated with hazardous materials use and handling has led to the understanding that facilities properly designed, constructed, operated, inspected, and maintained are of paramount importance in preventing accidental releases. 
 
Aerojet's safety record is due in large part to hazard evaluations it performs and the precautionary measures that ensue from these evaluations. Lessons learned from all incidents help to improve the facility, as well as product, design criteria, fabrication, and operating procedures. They also become topics of safety meetings, design reviews, etc. 
    
Aerojet maintains a safety program that allows for multi-disciplinary reviews of all new or modified programs that fall under the RMP program. These reviews typically include a preliminary design review (PDR), process hazard analysis (PHA), final design review (FDR), and a critical safety review (CSR).  
The disciplines represented at these various reviews typically include personnel from process engineering, production and operations, fire service, safety engineering, industrial hygiene, environmental management, and facilities engineering. These reviews are held for all significant new or modified programs at Aerojet. 
 
In 1998, the Aerojet Sacramento site received the Chairman's Merit Award from The Sacramento Safety Center, Incorporated. The Safety Center is a non-profit organization dedicated to promoting safety in the workplace and community. The award, the highest given by the Safety Center, was not only for Aerojet's outstanding safety record, but also for its employee community involvement in the areas of health and safety and for its "continuous improvement of health and safety processes throughout the year." 
 
Description of the Stationary Source and Regulated Substances 
 
The Aerojet Sacramento site is located approximately 15 miles east of downtown Sacramento at Highway 50 an 
d Hazel Avenue. The property covers about 8,500 contiguous acres. It extends between Sunrise Boulevard in Rancho Cordova on the west and Prairie City Road in Folsom to the east, and from Folsom Boulevard on the north to White Rock Road on the south. Surrounding land uses include open agricultural (south and east of the property), commercial or light industrial (west, south, and north), and residential (to the north on the opposite side of Highway 50).  The primary business of Aerojet at its Sacramento site is the manufacture and testing of rocket propulsion systems. The substances regulated by the RMP at the Aerojet Sacramento site include fuels and oxidizers for the testing of liquid rocket engines and materials for the manufacture of solid rocket motors.  Aerojet does not have any RMP regulated flammables above the 10,000 pound threshold. 
 
Hazard Assessment  
 
As part of the RMP requirements, Aerojet is required to conduct a hazard assessment, which includes a worst case scenario (WCS 
) analysis and an alternative release scenario (ARS) analysis. The assumptions required by U.S. EPA for use in the WCS analysis are very conservative (and, in many cases, unrealistic) and provide results that Aerojet believes are highly unlikely to occur. One reason for this belief is the fact that the WCS requirements do not allow Aerojet to take into account the systems and controls in place to prevent a catastrophic failure. Another reason is the fact that the meteorological conditions required to produce the distance to endpoint could not physically occur as specified by U.S. EPA. Consequently, the distance to the calculated endpoint estimated under these worst-case conditions should not be considered a zone in which the public is in danger; rather, the worst-case scenario is intended to encourage communication between the facility and the possible exposed population. 
 
The ARS are, by definition, more likely than the worst-case scenarios; however, they are still very unlikely given 
Aerojet's prevention program. The ARS serve to demonstrate the ability of Aerojet to minimize the impacts of a release to the community. If a release were to occur, Aerojet has an array of mitigation measures to reduce potential impacts. When these mitigation programs are taken into account, the impacts of the alternative scenarios do not extend off Aerojet's site. 
 
The RMP rule requires facilities to develop one WCS for each regulated toxic substances.   Additional WCSs are required if different public receptors would be affected and this is the case for Aerojet. In addition, one ARS is required for each regulated toxic substance. For the various analyses, Aerojet used the Toxic Release Analysis of Chemical Emissions (TRACE) dispersion modeling program developed by Safer Systems Inc., of Westlake Village, California. Various versions of the TRACE program have been in use by Aerojet for over 10 years. 
 
The WCS for regulated toxic substances at the Aerojet Sacramento site involves an i 
nstantaneous release of Aerozine50 rocket fuel from a storage vessel in the test area. Aerozine50 (A50) is a liquid rocket fuel that is a mixture of 50% hydrazine and 50% 1,1-dimethylhydrazine (also known as unsymmetrical dimethylhydrazine [UDMH]), both of which are regulated under the RMP program.  This scenario is extremely unlikely given the safety systems in place. Further, although there are numerous control measures that, in an actual event, would mitigate the release, no active mitigation systems can be considered in the WCS analysis according to the regulations. The WCS analysis shows that the 1,1-dimethylhydrazine (known as UDMH) component of the plume of A50 will travel off site before dispersing enough to no longer pose a health hazard. This endpoint corresponds to the Emergency Release Planning Guideline (ERPG)-2 concentration of 4.9 ppm. 
 
A second WCS involving the instantaneous release of the entire contents of a 55-gallon drum of toluene 2,4-diisocyanate (2,4-TDI) would  
potentially affect different public receptors because it is located at the other end of the Aerojet Sacramento site. The WCS release of the 55-gallon drum of 2,4-TDI would also travel off site before it reaches the ERPG-2 concentration of 1.0 ppm. 
 
The ARS selected for A50 propellant systems is a break in a piping system from the tank to the test stand that releases 23 gallons of A50. Typical weather conditions were assumed. Dispersion modeling calculations estimate that the UDMH component of A50 would travel 830 feet before dispersing to a concentration that no longer poses a health hazard. This distance is within the Aerojet fenceline. Existing detectors and automatic shutoffs would likely result in a smaller release than the ARS. These safety systems would ensure that no off-site impacts would occur. ARS for other regulated toxic substances are described in Section 4.0 of this document. 
 
The ARS for the 55-gallon drum of 2,4-TDI involves a forklift puncture of the drum 1 foot from t 
he bottom of the drum. Using typical weather conditions, the dispersion model estimated the 1.0 ppm ERPG-2 concentration would reach 130 feet. This distance is within the Aerojet fenceline. 
 
General Accidental Release Prevention Program 
 
Aerojet began a Process Safety Management (PSM) program in the mid 1990s. When the RMP standard was promulgated, Aerojet created the Process Safety and Risk Management (PSRM) program, a combination of the PSM and RMP programs. The PSRM is a key component of the Aerojet prevention program and is documented in Aerojet's Health and Safety Directive (HSD)-75.   Some specific activities in the prevention program include: 
 
-Process safety information is provided to all employees upon hire and is accessible at all times. 
-In-depth process hazard analyses are completed every five years by qualified personnel using techniques approved under the PSM standard. 
-Written operating procedures (kept up-to-date) are used for training and guiding the work of operators. 
 
-Training is provided to all employees upon hire, and refresher training is given annually or upon request. 
-Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety. 
-Pre-startup safety reviews are conducted to insure that conditions for safe operation have been satisfied prior to starting new or modified equipment. 
-A program is in place to maintain the mechanical integrity of the process, which includes written procedures, training requirements, equipment deficiency requests for employees, work orders, scheduled maintenance, and computerized documentation. 
-A hot work permit system assures that work is done safely and properly. 
-A management of change system is in place to ensure that changes are managed safely. 
-Incidents are investigated and actions are taken as part of a continuous improvement effort. 
-Routine audits are conducted to assure that safe practices are being 
followed. 
 
Five-Year Accident History 
 
The RMP regulations require facilities to provide information on any accidents in the last 5 years involving RMP-regulated substances that resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage off site. 
 
Aerojet has had no accidents or incidents from any covered process within the last 5 years that apply to the regulatory definitions above. 
 
Emergency Response Program 
 
Overall safety at the Aerojet Sacramento site is a function not only of programs to prevent accidental releases from occurring, but also of programs to mitigate the effects of accidental releases should they occur. The Aerojet Sacramento site has an emergency response program that is designed to protect lives, the environment, and property in the area. Aerojet Fire Service personnel are on site 24 hours a day, 365 days a year. The Aerojet Sacramento site is also use 
d as a training facility for outside emergency response personnel. Several of Aerojet Fire Service personnel are Certified Hazardous Materials Emergency Response Instructors. Aerojet response personnel are among the most highly trained in the state. Fire Service personnel also attend design reviews, hazard analyses, and critical safety reviews. 
 
Planned Changes to Improve Safety 
 
Safety has been a part of the working culture at Aerojet since operations began in Sacramento in the early 1950s. Chemical exposure risks to employees and the public have been minimized through ongoing internal risk reduction efforts, as well as regulatory requirements. Aerojet conducts numerous design and operational safety reviews prior to any program startup. A final critical safety review and test readiness review are held to review the entire program by a multi-disciplinary team, including representatives from safety engineering, industrial hygiene, environmental management, fire service, facilities engin 
eering, and operators or engineers from the specific process area for technical expertise. 
 
Recommendations developed as a result of these reviews and other programs such as process improvement, equipment inspections, safety meetings, lessons learned, industry experience, technology improvements, and employee suggestions, are all evaluated and implemented as required.
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