Radford Army Ammunition Plant - Executive Summary |
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Executive Summary Accidental Release Prevention and Emergency Response Policies We at Radford Army Ammunition Plant (RFAAP) are committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program that covers design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. In the unlikely event that such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with the Montgomery County Local Emergency Response Committee that provides additional emergency response expertise. RFAAP has been in operation since 1941. During that 58-year period, there have been no releases that are either in the "alternate" or the "worst-case" category desc ribed in this plan. The Regulated Substances and Applicability RFAAP has more than the threshold planning quantity of four regulated substances and is therefore subject to the requirements of 40 CFR 68. The RFAAP primary activities are Chemical and Propellant Manufacturing (NAICS Codes 325188 - Basic Inorganic Chemical Manufacturing and 32592 - Explosives Manufacturing.). The four substances stored at RFAAP that are subject to the provisions of 40 CFR 68 are Nitric acid (CAS No. 7697-37-2), Ethyl ether (60-29-7), Ammonia (7664-41-7) and Oleum (8014-95-7). Table 1 summarizes RFAAP's listed substances, processes, stored quantities and Part 68 applicability status. Table 1 RFAAP Covered Processes Area Regulated Substance Maximum Quantity Stored Part 68 Applicability Ammonia Oxidation Plant Ammonia 570,000 lbs. Program 3 Manufactured Acid Storage Nitric Acid 2,100,000 lbs. Program 3 Purchased Acid Storage Oleum 760,000 lbs. Program 1 Nitrocellulose Acid Storage Nitric Acid 180,000 lbs. Program 3 Oleum 250,000lbs. Program 1 Solvents Area Ethyl Ether 1,200,000 lbs. Program 1 Propellant Manufacturing Area Ethyl Ether 100,000 lbs. Program 1 The Worst-Case and Alternative Release Scenarios EPA's General Guidance for Risk Management Programs includes the following statement concerning worst-case release assumptions. The distance to the endpoint estimated under worst-case conditions should not be considered a zone in which the public would likely be in danger; instead, it is intended to provide an estimate of the maximum possible area that might be affected in the unlikely event of catastrophic conditions. Distances greater than about 10 kilometers are particularly uncertain. EPA intends the estimated distances to provide a basis for a discussion among the regulated community, emergency responders, and the public, rather than a basis for any specific actions. RFAAP has followed EPA's regulatory requirements and their published guidance in developing our worst-case release scenarios. Worst-Case Release Scenarios RFAAP evaluated a total of seven worst-case release scenarios. Worst-case release scenarios represent highly unlikely events occurring during the worst meteorological conditions, which are a wind speed of 1.5 meters per second and an atmospheric stability class of F. For toxic substances EPA requires the evaluation of a catastrophic release of the entire contents from the largest vessel. For flammable substances the EPA prescribed worst-cas e release scenario assumes that the total quantity of the flammable substance is released forming a vapor cloud that detonates. As a conservative assumption, 10 percent of the flammable vapor in the cloud is assumed to participate in the explosion. To evaluate the worst-case scenarios, we have used the equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as the DEGADIS 2.1 air dispersion model and EPA's RMP*Comp(TM). The following provide details of the chosen worst-case release scenarios. The worst-case release scenario from the Ammonia Oxidation Plant involves a catastrophic release of 143,400 pounds of ammonia in a gaseous form over 10 minutes. Passive mitigation controls such as dikes are taken into account for the evaluation of this scenario. However, other safety features including active engineering controls and emergency response are not considered. Under worst-case meteorological conditions, modeling determined that this worst-case rel ease scenario would have an off site impact and is therefore subject to the provisions of Program 3. The worst-case release scenario of from the Manufactured Acid Storage Area involves the catastrophic release of 524,806 pounds of strong Nitric Acid. Passive mitigation (secondary containment) was considered in this scenario, however, active mitigation, such as the response of area personnel was not considered. Under worst-case meteorological conditions, modeling determined that this worst-case release scenario would have an off site impact and is therefore subject to the provisions of Program 3. Purchased Acid Storage was evaluated under EPA's worst-case release assumptions and found to have no impact on public receptors. Therefore, this process qualifies as a Program 1 process. The worst-case scenario for this process involves the release of 760,000 lb. of Oleum (Fuming Sulfuric acid). Passive mitigation (secondary containment) was considered in this scenario, however, active mi tigation, such as the response of area personnel was not considered. Under worst-case meteorological conditions, the maximum distance to the toxic endpoint is less than that to the nearest public receptor. The worst-case release scenario from the Nitrocellulose Manufacturing Area involves the catastrophic release of 180,000 pounds of strong Nitric Acid. Passive mitigation (secondary containment) was considered in this scenario, however, active mitigation, such as the response of area personnel was not considered. Under worst-case meteorological conditions, modeling determined that this worst-case release scenario would have an off site impact and is therefore subject to the provisions of Program 3. The Oleum Storage at the Nitrocellulose Manufacturing Area was evaluated under EPA's worst-case release assumptions and found to have no impact on public receptors. Therefore, this process qualifies as a Program 1. The worst-case quantity released is 250,000 lb. of Oleum (Fuming Sulfur ic acid). Passive mitigation (secondary containment) was considered in this scenario, however, active mitigation, such as the response of area personnel was not considered. Under worst-case meteorological conditions, the maximum distance to the toxic endpoint is less than that to the nearest public receptor. The Solvents Area was evaluated under EPA's worst-case release assumptions and found to have no impact on public receptors. Therefore, this process qualifies as a Program 1 process. The worst-case scenario considered for this process involves the release of 68,000 lb. of a flammable substance, namely Ethyl ether. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud detonation. Under worst-case weather conditions, the maximum distance to the flammable endpoint is less than that to the nearest public receptor. The Propellant Manufacturing Area was evaluated under EPA's worst-case release assumptions and found to have no impact on public receptors. Therefore, this process qualifies as a Program 1 process. The worst-case scenario considered for this process involves the release of 30,000 lb. of a flammable substance, namely Ethyl ether. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud detonation. Under worst-case weather conditions, the maximum distance to the flammable endpoint is less than that to the nearest public receptor. Alternate Release Scenarios The EPA requires that at least one alternate release scenario be identified and analyzed for each covered process subject to the requirements of Programs 2 or 3. RFAAP has developed and evaluated alternate release scenarios for the three processes subject to the requirements of Program 3. EPA's General Guidance for Risk Management Programs states that alternate release scen arios are developed to represent a more realistic release and atmospheric conditions. However, the same conservative, protective endpoints are used. For each alternate release scenario the neutral meteorological conditions used in estimating the distance to endpoint was a wind speed of 3 meters per second and an atmospheric stability class of D. To evaluate the alternate release scenarios, we have used the DEGADIS 2.1 air dispersion model. The alternative release scenario from the Manufactured Acid Storage Area involves the release of 524,000 lb. of strong Nitric acid into a dike, which is drained into the waste acid treatment system by operators within 30 minutes of the release. Under neutral weather conditions, modeling determined that the maximum distance to the endpoint is less than the distance to the nearest public receptor. The alternative release scenario for Ammonia involves a release from a rail car located at the Ammonia Storage Facility in the Ammonia Oxidation Proces s. The scenario involves the release of 80,000 lb. of Ammonia in a gaseous form over 10 minutes. It is assumed that operators are notified on the release by the existing Ammonia detection system. Under neutral weather conditions, modeling determined that this release scenario would have an off site impact. The alternative release scenario from the Nitrocellulose Manufacturing Area involves the release of 180,000 lb. of strong Nitric acid into a dike, which is drained into the waste acid treatment system by operators within 30 minutes of the release. Under neutral weather conditions, modeling determined that the maximum distance to the endpoint is less than the distance to the nearest public receptor. The Accidental Release Prevention Program RFAAP takes all the necessary steps to comply with the requirements of the accidental release prevention program set out under 40 CFR part 68. A number of processes at the facility are subject to the OSHA process safety management (PSM) sta ndard under 29 CFR 1910.119. RFAAP is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information RFAAP maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis RFAAP conducts comprehensive studies to ensure that hazards associated with each process are identified and controlled. RFAAP uses several methodologies to complete process hazards assessments (PHA). The PHAs conducted for the covered processes at RFAAP were performed using either a "What If" analysis or Fault Tree Analysis. These studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a minimum of every five years. Any findings related to the hazard analysis are a ddressed in a timely manner. Operating Procedures For the purposes of safely conducting activities,RFAAP has an extensive procedure development and implementation program. An excellent feature that is included in each operating procedure gives the operator the right to refuse to start-up any process at the facility if he does not feel that it is safe. Procedures are written to provide clear instructions for the operation of all processes at RFAAP including processes subject to the requirements of 40 CFR 68. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Each employee involved in the operation of any process is trained using the procedures described in Section 14. All training includes an emphasis on the speci fic safety and health hazards associated with equipment and chemicals, emergency operations, and safe work practices. Each operator receives initial training, which involves the reading of the procedure and a walk through of the process operations with the procedure in hand. Competence in the procedures is determined based on observation by the operator's supervisor. Every time the procedure is changed each operator must be retrained using the same methods as described for initial training. If there are no changes to the procedure, each operator is re-trained in the procedure annually. For each employee at RFAAP a record is kept of that employee's required training, the dates of the last training, and when the employee's refresher training is required. All training records are maintained in the individual operating areas. Mechanical Integrity Radford Army Ammunition Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified personnel carry out maintenance operations with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change RFAAP utilizes a computer-based management of change (MOC) system. MOC procedures and reviews can be accessed through any plant computer that has network access. The system is designed to solicit review and approval from the appropriate personnel prior to implementation. Each MOC document whether it is to perform a process or procedural change contains at a minimum the following information: 7 The technical basis for the proposed change 7 Impact of the change to safety and health 7 Modifications to opera ting procedures 7 Necessary time period for the change 7 Authorization requirements for the proposed change If the MOC system results in a major change to one of the covered processes the RMP will be updated and resubmitted as appropriate. Pre-startup Reviews The Plant Process Control Board (PPCB) at RFAAP conducts pre-start up reviews before the process is allowed to operate. Representatives from Safety, Hazards, Environmental, and Operations attend the pre-startup evaluation to determine if there are any problems that must be addressed prior to the process being allowed to start. If there are deficiencies identified by the PPCB, the process must correct the deficiencies before the process may start up. Compliance Audits Radford Army Ammunition Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audi ts are undertaken in a safe and prompt manner. Incident Investigation All incident investigations at RFAAP are conducted in accordance with written procedures, which are located on the RFAAP computer network, accessible to all employees. The objective of the incident investigation is to obtain the necessary information to prevent the incident/accident from occurring again. Radford Army Ammunition Plant promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Radford Army Ammunition Plant truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issu es and to recommend improvements. RFAAP requires that operators participate in investigations, PHAs, etc. Since the operators work with the equipment daily, it has been determined that they are an excellent resource. Also, all reports generated regarding any operation are available to any operator at RFAAP. Contractors All contractors prior to performing any work are required to read, and certify that they understand and will abide by the rules identified in the "Safety Rules for Contractors and Subcontractors". The booklet was written by Alliant Techsystems and updated in August 1998 and describes general safety procedures such as ladder use and facility specific procedures such as what to do when encountering a vehicle that is transporting propellants or explosives. A copy of this booklet is given to each individual performing contract or subcontract work on plant. The Alliant Safety Department maintains the signed statements indicating that the individual has read, understand s, and will comply with the requirements. Five-year Accident History Radford Army Ammunition Plant has had an excellent record of preventing accidental releases. Due to the excellent facilities and administrative controls, in the last five years, RFAAP has not had an accidental release that resulted in on site deaths, injuries, or significant property damage or offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. In fact, in the 58 years that Hercules Incorporated and Alliant have operated the RFAAP, there has never been a release equal to the seven worst-case or the three alternate release scenarios evaluated in this plan. Emergency Response Plan RFAAP maintains two primary plans, the first is the RFAAP Hazardous Material Emergency Response Plan which was developed to provide a plan for responding to a hazardous material release that cannot be controlled by area standard operating procedures. The plan complements the disaster contro l plan by giving specific direction to the response and control of hazardous material releases. The plan addresses all substances regulated by 40 CFR 68 as well as other potentially hazardous chemicals. The second is the Disaster Control Plan which was developed to ensure that RFAAP is prepared to effect immediate disaster control recovery operations at the installation level in order to ensure the performance of essential functions and responsibilities in times of natural disaster, civil disturbances, and enemy attack. Accordingly, planning and organization detailed in the plan are aimed at effecting recovery from the most devastating possibility, but flexible enough to permit its adaptation to recovery from any disaster of lesser magnitude. |