Akzo Nobel Chemicals Inc. - Executive Summary |
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RISK MANAGEMENT PLAN EXECUTIVE SUMMARY 1. Policy Statement Akzo Nobel Chemicals Inc., Morris Plant, is committed to excellence and leadership in all aspects of safety, health and the environment. The company actively supports the guiding principles of the Business Charter for Sustainable Development of the International Chamber of Commerce and the Responsible Care( initiative of the Chemical Manufactures Association. These principles are applied throughout the plant site and are not limited solely to those areas or processes covered by regulation. Safety, health and environmental issues are integral parts of the company's business plans. Specific annual goals in each of these areas are set forth in the annual business plan and individual employees have safety, health and environmental goals within their own personal objectives. Akzo Nobel Chemicals Inc. works towards the prevention of all accidents associated with its activities and those of its contractors. The company p rotects the community and the environment by preventing or reducing the impact of its activities and its products through appropriate design, maintenance, distribution, use, and disposal practices. In the event of an emergency, the Emergency Response Plan is designed to minimize hazards to human health and the environment from fires, explosions, or releases of hazardous materials to air, soil, or surface water. The plan provides for the coordination between Federal, State, and Local agencies depending upon the nature, extent, and severity of the incident. Akzo Nobel Chemicals Inc. supports these policies through extensive training of its employees in both standard plant operations and emergency response. Documentation of procedures and training requirements are maintained through the site documentation control system. The company has also committed to supporting the Local Emergency Planning Commission with both monetary and personnel resources. 2. Facility Description and Regulat ed Substances 2.1 Facility Description The Morris plant is located approximately 6 miles northeast of the city of Morris, IL, just south of Route 6 on Tabler Road in Grundy County. The site comprises a total of 285 acres with the actual manufacturing facilities occupying 26 acres. An additional 80 acres of the site is used for environmental treatment of waste water before it is discharge to Aux Sable Creek, a tributary of the Illinois River. The plant, which began operating in 1973, employs 135 people and is a manufacturer of industrial chemicals, primarily cationic surfactants, derived from naturally occurring fats and oils. The basic raw materials are tallow and grease, by-products of the meat packing industry, and vegetable oils including coconut oil and soybean oil. Additional raw materials include ammonia, hydrogen, methyl chloride, acrylonitrile and formaldehyde solutions. The major processing units at the site include a fat splitter, a nitrile unit, continuous and batch hydrogenation units, nitrile treatment, amine and fatty acid distillation units, amine esterification unit and a quaternization unit. The fat splitter utilizes hot water and high pressure steam to convert the natural occurring fats and oils into organic fatty carboxylic acids and glycerin. The glycerin is a by-product and is recovered and sold for further processing into soap and personal care products. The fatty acids are transferred to the nitrile unit where they are reacted with ammonia in the presence of a catalyst to form fatty nitrile. The nitrile is then reacted with hydrogen in the presence of catalyst in either the continuous or batch hydrogenation units to form primary, secondary, and tertiary amines. The addition of acrylonitrile or formaldehyde solutions can also be made in the batch hydrogenation units to form additional variations of secondary and tertiary amines. In the quaternization unit tertiary amines are reacted with methyl chloride to form quaternary ammonium compounds. The major products produced at the site are primary, secondary and tertiary amines, diamines, esteramines, and quaternary ammonium compounds. These intermediates and products are used as surfactants in agricultural products, personal care products, detergents and fabric softeners. They are also used as surfactants in a wide range of other industrial processes including food, chemical, highway paving, metal processing, mining, petroleum, paint, ink, paper, pharmaceutical, rubber and polymer processing industries. 2.2 Regulated Substances The site has four substances that are covered by the Risk Management Plan regulations. These substances are all raw materials and are acrylonitrile, ammonia, formaldehyde solutions and methyl chloride. A fifth raw material, hydrogen, is listed in the regulations but it is not covered by the regulation at the site because the maximum quantity at the site is below the minimum threshold quantity listed in the regulation. The maximum qua ntities of these materials in process at the plant site at anytime is as follows: Acrylonitrile 421,000 lbs Ammonia 348,000 lbs Formaldehyde Solutions 361,000 lbs (as 100% Formaldehyde 167,000 lbs) Methyl Chloride 468,000 lbs These quantities represent full storage tanks and one full delivery container. Under normal operating conditions the quantity stored on site is approximately one half of the maximum quantities listed above. 3. Consequence Analysis 3.1 Worst Case Scenario (WCS) The potential impact of the dispersion of the four chemicals listed in section 2.2 resulting from the rupture of the largest single vessel containing each of the chemicals was conducted using the OCA Guidance document and the RMP Comp dispersion model. The generic weather data from the OCA Guidance Document was used. The analysis revealed that the WCS for the site is a catastrophic rupture of a railcar containing 220,000 lbs of acrylonitrile. The potential impact zone is defined by a cir cle with a radius of 15 miles and its center at the unloading station on the site. Using census data, provided by the U.S. Bureau of the Census on their Landview III CD ROM, the estimated population that could potentially be impacted by this release is 95,000 people. The potential impact zone also contains a number of small communities, state parks and local historic sites. 3.2 Alternative Release Scenarios (ARS) Alternative Release Scenarios as defined by the regulation were developed for each of the four regulated chemicals. The scenarios were chosen based upon a review of prior accident history, Process Hazard Analysis results and maintenance history. The requirement that the release have an offsite consequence was also a major consideration. A team comprised of operating, maintenance, and engineering personnel conducted the review. The ARS for each of the chemicals was defined as a split or sudden uncoupling of a transfer hose during unloading operations. In the case of ac rylonitrile, ammonia, and methyl chloride the action of an excess flow device was considered as a mitigating factor in limiting the release. The release of formaldehyde solution is mitigated by the intervention of operation personnel. As a result of this analysis an automated mitigating device is being engineered for the formaldehyde solution scenario. The offsite consequence analysis for each of the Alternative Release Scenarios was developed using the dispersion modeling program SAFER( Trace and the Landview III census data. The resulting analysis is as follows: Regulated Amount Released Potential Impact Potential Affected Chemical (lbs) Zone Radius(mile) Population Acrylonitrile 500 0.2 30 Ammonia 190 0.4 50 Formaldehyde 26,800 1.0 210 Solution Methyl Chloride 470 0.3 40 The formaldehyde solution has an additional potential to impact a local historic site and a neighboring chemical manufacturing facility. 4. Accidental Release Preve ntion Program The RMP regulated chemicals on Akzo Nobel Chemicals Inc. Morris site are also regulated by the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard. The PSM standard is used as a model throughout the site for all processes whether or not the chemical or process is regulated. This program is driven by the company's goal to meet the intent of the Chemical Manufacturers Association Responsible Care( initiative. The following summary addresses each of the PSM elements and how they are implemented through the management system of the site. 4.1 Employee Participation Employee participation is a key element in Akzo Nobel Chemicals Inc. Morris site process safety program. Teams composed of representatives from management, engineering, operations and maintenance conduct Process Hazard Analyses. Similarly, employees from these groups within the facility participate in the development of training programs, operating procedures, inci dent investigations, emergency planning and response, pre-startup reviews and compliance audits. There is a written plan of action for Employee Participation. It states the policy and elements for employee participation in the plant's Process Safety Program. This plan is reviewed with all employees of the facility and a copy of the plan is available to all employees. 4.2 Process Safety Information Complete and accurate written information concerning process chemicals, process technology, and process equipment is essential to an effective Process Safety Management Program and to a Process Hazard Analysis. This section has three areas as follows: 4.2.1 Information pertaining to the hazards of the highly hazardous chemicals in the process This information is mainly provided by MSDS that are available to all personnel through the company computer Intranet. Additional technical information is available in the form of technical brochures and publications located in the Engineering De partment. 4.2.2 Information pertaining to the technology of the process. Examples of information pertaining to technology that are available are operating procedures for each process, process chemistry, maximum intended inventory levels, safe upper and lower limits for such items as temperatures, pressures, flows or compositions, and evaluation of the consequences of deviations, including those affecting the safety and health of employees The location of this documentation and the responsibilities for maintaining the documentation are contained in the site Process Safety Management Plan 4.2.3 Information pertaining to the equipment in the process. Information in this area includes materials of construction, piping and instrument drawings, area electrical classification, relief system design and design basis, design codes and standards, material and energy balances, and safety systems. This documentation relating to this information includes the piping material specifications, pr ocess equipment lists, relief valve lists, relief valve engineering files, process flow diagrams (PFDs), piping and instrument drawings (P&IDs), area electrical classification drawings, site engineering standards manual and plant operating procedures. The location of this documentation and the responsibilities for maintaining the documentation are contained in the site Process Safety Management Plan 4.3 Process Hazard Analysis (PHA) Akzo Nobel Chemicals Inc. Morris site uses the Hazard and Operability Study (HAZOP) as its PHA. The HAZOP is one of the most important elements of the process safety management program. The HAZOP is a detailed description of deviations, factors, causes, consequences, indications and recommendations. This analysis is completed for each piece of the process. This site uses the computer software PHA Works to assist with evaluation and documentation of possible hazards. The recommendation section of the HAZOP directs efforts to establish a written schedul e of what actions will be taken. The documentation will vary and depend on the recommendation. Many will require capital expenditure requests, training or process change requests. HAZOP team members represent all departments associated with the process. These departments include engineering, maintenance, management, safety, and operations. Input from all members is key to a successful HAZOP. All team leaders are trained in conducting HAZOP analysis. One member of the team is knowledgeable in the specific hazard analysis methodology being used. Also, at least one team member has experience and knowledge specific to the process being evaluated. The process hazard analysis depends upon the quality of the Process Safety Information. Akzo Nobel uses this information primarily to identify and evaluate potential hazards. The goal is to prevent a hazardous situation. If one should occur, the secondary goal is to minimize the effects of that situation. All HAZOP and revalidation documentati on is kept in the Engineering Department. 4.4 Operating Procedures Akzo Nobel Chemicals Inc. operating procedures are an integral part of the safe operations of the plant. All procedures are part of the facilities document control system based upon the system used for ISO 9002 compliance. The steps for each operating procedure include (1) initial startup, (2) normal operations, (3) temporary operations, (4) emergency operations including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner, (5) normal shutdown and (6) startup following a turnaround, or after an emergency shutdown. Operating limits are contained in the operating procedures and they include the consequences of deviation and the steps required to correct or to avoid deviation. The safety systems and their functions are also contained in the operating procedures for each unit. Copies of the procedures are located in the areas where they are used and are readily accessible to all employees who work in or maintain that process. These procedures are also available through the company computer Intranet. All procedures are reviewed every twelve months or every time a process change request is filed. This ensures that they reflect current operating practices. 4.5 Training To complement the written operating procedures for process operations, Akzo Nobel Chemicals Inc. has incorporated a company training plan for all employees involved in process operations. Initial training is performed with all new employees. Each new employee is required to complete the necessary orientation paperwork, safety/health, and procedural training before being trained in process operations. Operations training consists of both classroom and field training under the instruction of a dedicated training operator. Each employee is trained in an overview of the process and in the operating procedures. This training is completed before the employee is allowed to operate any process without supervision. Training and its effectiveness is documented by two different methods. The first method is to administer a written test and the second is to perform a walk through/simulation with the area supervisor. These are used to evaluate the employees on the necessary knowledge, skills and abilities required by the job. Detailed training records are maintained. Refresher training is performed every three years or earlier if significant changes occur to the process. This training is provided to each employee involved in operating the process to ensure that all employees understand and adhere to current operating procedures for the process. Detailed documentation for refresher training is also maintained. 4.6 Contractors Akzo Nobel Chemicals Inc. may use contractors to perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. In order to ensure the safe operation of the facility and also to ensure the safety of the contractors, the company has developed a Contractor Safety Manual. The manual documents the responsibilities of both the company and the contractor. 4.6.1 Employer responsibilities include (1) evaluating information regarding the contract employer's safety performance and programs, (2) informing contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor's work and the process, (3) explaining to contract employers the applicable provisions of the emergency action plan, (4) developing and implement safe work practices and controlling the entrance, presence and exit of contract employers and contract employees in covered process areas, (5) periodically evaluating the performance of contract employers in fulfilling their obligations, and (6) maintaining a contract employee injury and illness log related to the contractor's work in process areas. 4.6.2 Contract employer responsibilities include (1) ensuring that each contract employee is trained in the work practices necessary to safely perform his/her job, (2) ensuring that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan, and (3) ensuring that each contract employee follows the safety rules of the facility including safe work practices 4.7 Pre-startup Safety Reviews Akzo Nobel Chemicals Inc. performs a pre-startup safety review for all new and modified facilities. The Morris plant Pre-startup Safety Review (PSR) procedure is used for the evaluation. The PSR confirms that (1) construction and equipment is in accordance with design specifications, (2) safety, operating, maintenance, and emergency procedures are in place and are adequate, (3) for new facilities, a HAZOP has been performed and recommendation s have been resolved or implemented before startup and modified facilities meet the requirements contained in the process change authorization, and (4) training of each employee involved in operating a process has been completed 4.8 Mechanical Integrity The purpose of the Akzo Nobel Mechanical Integrity program is to ensure equipment used to process, store or handle regulated chemicals is designed, constructed, installed and maintained to minimize the risk of releases of such chemicals. This section applies to pressure vessels and storage tanks, piping systems (including piping components such as valves), relief and vent systems and devices, emergency shutdown systems, controls (including monitoring devices and sensors, alarms, and interlocks), and pumps The Akzo Nobel Morris Mechanical Integrity Plan documents that the company has established and implemented written procedures to maintain the on-going integrity of process equipment and has trained each employee involved in mainta ining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner. The plan documents specific procedures to ensure that inspections and tests are being performed using recognized and generally accepted good engineering practices consistent with manufacturers' recommendations. The plan also provides for the correction of deficiencies in equipment that are outside acceptable limits (defined by the process safety information) before further use or in a safe and timely manner when necessary means are taken to assure safe operation. The plan also details quality assurance procedures to ensure that (1) in the construction of new plants and equipment, the equipment is suitable for the process application for which they are used, (2) appropriate checks and inspections are performed to ensure that equipment is installed properly a nd consistent with design specifications and the manufacturer's instructions and (3) that maintenance materials, spare parts and equipment are suitable for the process application for which they are being used. 4.9 Safe Work Practices Akzo Nobel Chemicals Inc. Morris site has safe work practices in place to ensure worker and process safety. These procedures include (1) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance procedures, (2) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (3) a permit and procedure to control spark and flame producing activities (hotwork) and (4) a permit and procedure to ensure that necessary precautions are in place before entry into a confined space. These procedures combined with extensive training of affected personnel form a system to ensure that operations and maintenance activities are performed safely. 4.10 Management of Change Akzo Nobel Chemic als Inc. process change authorization (PCA) is an established and implemented written procedure to manage changes to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process. The procedures ensure that prior to any change consideration is given to (1) the technical basis for the proposed change, (2) impact of change on safety and health, (3) modifications to operating procedures, (4) necessary time period for the change, and (5) authorization requirements for the proposed change. The PCA ensures that all process safety information is updated and that all the necessary components of the operating procedures are also updated. Operators, maintenance, and contract employees whose job tasks will be affected by a change in the process are notified and trained on the change prior to start-up of the process or affected part of the process. 4.11 Incident Investigation Akzo Nobel Chemicals Inc. investigates all incidents that resulte d 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 documents its findings, develops recommendations to prevent recurrence and forwards these results to the site central safety committee 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. Incident investigation reports are retained for 5 years so that the reports can be reviewed during future PHA re-validations. 4.12 Compliance Audits The purpose of the Akzo Nobel Chemicals Inc. internal audit pr ocedure is to ensure that the site accident prevention program is functioning correctly. It provides a means to document deficiencies and correct them. This evaluation is used to improve the design and effectiveness of the process safety management system and its implementation. Compliance audits are performed at least once every three years. The audit team includes at least one member who is knowledgeable in the process. The team develops a findings report and forwards it to site management who promptly determine and document an appropriate course of action to resolve each of the findings. Corrective actions taken in response to the findings are tracked until completion. The two most recent compliance audits are retained. 4.13 Chemical Release Specific Prevention The processes at Akzo Nobel Chemicals Inc. have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applicable to all RMP regulated processes at the Morris site. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failure and human errors. In addition to the accident prevention program activities the site has safety features on many of its units to help contain/control a release, quickly detect a release, and reduce the consequences of a release. The following types of safety features are used in various processes: Site wide video monitoring for release detection Incineration of specific process relief valves releases Automatic isolation valves for specific processes Automated shutdowns for systems for specific process parameters (e.g. high level, high temperature) Dikes for toxic liquid storage tanks Emergency electrical backup for critical control and safety systems Fire suppression and deluge systems for specific equipment Trained and fully equipped site emergency responders for chemical releases Real time simulation capabilities for accidental releases 5. Five Year Accident History There have been no accidental releases of the regulated chemicals that resulted in any death, injury or property damage on the Akzo Nobel Chemicals Inc. Morris site within the last five years. There has never been a release of the regulated chemicals from the site that has resulted in an offsite consequence to the community or the environment. An offsite consequence is considered to be death or injury to a member of the public, property damage, evacuation, sheltering in place or environmental damage. 6. Emergency Response Program Akzo Nobel Chemicals Inc. maintains a written emergency response program, which is in place to protect workers and public safety as well as the environment. The program consists of procedures for a full response to a release of a regulated toxic substance and a limited response to the release of flammables. The procedures address all aspects of emergency response including proper first aid and medical treatment, evacuation pla ns, accounting for personnel, notification of local emergency response agencies and the public as required. Procedures are also in place to address the maintenance, inspection and testing of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on changes made to the site processes or other facilities at the site. Changes to the emergency response program are managed through the management of change process. The overall emergency response program for Akzo Nobel Chemicals Inc. is coordinated with the Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials and industry representatives. Akzo Nobel Chemicals Inc. has around the clock communications capability with appropriate LEPC officials and emergency res ponse organizations. This provides a means of notifying the public of an incident, if necessary, as well as facilitating a quick response to an incident. In addition to periodic LEPC meetings, Akzo Nobel Chemicals Inc. conducts periodic drills that involve the LEPC and emergency response organizations. 7. Planned changes to Improve Safety Akzo Nobel Chemicals Inc. constantly strives to improve safety of the site processes through periodic safety reviews, the incident investigation program and employee safety meetings. The company resolves findings from the PHAs, some of which result in modifications to the process. The following types of changes are planned during the next 5 years: Improve spill control at hazardous raw materials unloading area Automate emergency shutoffs at hazardous raw materials unloading Install excess flow valve shutoff at formaldehyde solutions unloading area Minimize length of flexible hose used in unloading hazardous raw materials Increase the n umber of trained emergency responders Implement the OSHA Star Safety program at the site |