BFGoodrich - Carbon Products Santa Fe Springs(fed) - Executive Summary |
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INTRODUCTION The BFGoodrich Aerospace Santa Fe Springs facility produces carbon brakes for aircraft. Carbon textile material is received by the facility and is first cut, sized and prepared for the brake production process. The textile is then sent to the furnace deck area where it undergoes carbonization and densification in a series of furnaces. All the process furnaces use propane. Next, the densified carbon brake parts are machined to the appropriate configuration. Finally, the non-wearing surfaces of the brakes are coated with an oxidation inhibitor and mounting hardware is attached. Some reprocessing of used brakes is also conducted at the facility. In addition to the direct manufacturing activities, a variety of support operations are involved at the Santa Fe Springs facility. On-site laboratories perform both research and development, and quality assurance/quality control functions. Both routine and non-routine maintenance is also conducted on equipment. PROPANE The facility uses propane in the brake production process. The propane storage tank (18,000-gallon capacity) is located outside the southwest corner of the furnace deck building. In accordance with , National Fire Protection Association Code 58, the propane tank is never filled to more than 88% of capacity. The storage tank is designed and constructed in accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Section VIII), and contains two safety relief valves. The propane tank is protected from vehicle traffic within the facility by a guard rail. The perimeter of the facility is fenced and access to the site is controlled to prevent tampering. The worst-case release scenario evaluated for propane at the facility involves the release of the entire tank (67,000 pounds) over a 10-minute period. The propane is assumed to form a vapor cloud within the upper and lower flammability limits, and the cloud is assumed to detonate. Ten percent o f the flammable vapor in the cloud is assumed to participate in the explosion. Other assumptions include Atmospheric Stability Class F and an ambient temperature of 770 F. USEPAs Risk Management Program Guidance for Propane Storage Facilities (the Propane Guidance) was used to estimate the distance to the endpoint for this release scenario. The endpoint (EP) is defined as the distance an explosion from an accidental release will travel before dissipating to the point that serious injury or property damage will be unlikely. The Propane Guidance requires the calculation of the area surrounding the release point that is subjected to greater than or equal to an overpressure of 1 pound per square inch (psi). Overpressures below 1 psi are not likely to cause injuries that result from flying glass from shattered windows or falling debris from damaged structures. The distance to the worst-case endpoint for propane provided by the Propane Guidance is 0.3 miles. The residential populat ion within this area is estimated to be 1,107 people, using the 1990 Census data and the LandView III database and mapping software package. Of this population, 153 people are between the ages of 0 and 9, and 114 people are 65 or older. The Lakeland School and the grounds of the Metropolitan State Hospital are also within the worst-case impact radius. There are no public recreation areas or environmental receptors within the worst-case impact radius. Although a worst-case consequence analysis is required by the RMP Rule, a worst-case occurrence is a highly unlikely event. The possibility of a catastrophic failure of the storage tank is extremely remote because: The storage tank is designed and constructed in accordance with industry standards, National Fire Protection Association Code 58 and American Society of Mechanical Engineers codes. The tank is equipped with two safety relief valves to prevent overpressurization and catastrophic failure of the tank. The tank area is moni tored with meter for detecting flammable gases in concentration above the lower explosive limit and a audible alarm will sound if explosive conditions exist. The perimeter of the facility is fenced and access to the site is controlled to prevent tampering. The propane tank is protected from vehicle traffic within the facility by a guard rail, and the external surface of the tank is visually inspected on a regular basis. All personnel working with the tank and the associated brake manufacturing process are trained and follow written standard operation procedures. An alternative release scenario is also required for the propane tank, and is considered more likely to occur than the worst-case scenario, but must still be significant enough to impact off-site areas (i.e., achieve at least the EP at the plant fence line). The following sources of information were evaluated during the selection of a credible alternative-release scenario: Previous hazard assessments, facility or industr y incident reports, maintenance work orders, incident recall, technical judgment, and the scenarios listed in the Propane Guidance. The alternative release scenario chosen represents the incident that is most likely to occur but is still severe enough to achieve the EP at the facility fence line. This scenario assumes that the propane truck driver forgets to remove the hoses between the storage truck and the transfer vehicle following delivery of propane. In this case, the 15 foot length of unloading hose, 2-inch diameter hose. The active mitigation measures such as breakaway fittings and valves work as designed limiting the release to 10.35 ponds of propane, the contents of the hose. Other assumptions used include Atmospheric Stability Class D and an ambient temperature of 770F. The Propane Guidance was used to estimate the distance to the EP, assuming the same vapor cloud explosion described in the worst-case scenario (the released vapor forms a cloud, of which 10 percent ignites). The distance to the EP (1 psi) is calculated to be 0.02 miles. There are no residential populations within this distance, but the truck distribution center adjacent to the plant would be affected. No hospitals, schools, recreation centers or environmental receptors are located within this impact radius. Although an alternative-release consequence analysis is required by the RMP rule, a failure and release of propane that is large enough to reach an EP beyond the fence line is not likely because: the facility has a preventive maintenance program in place to maintain the ongoing integrity of the system, and the propane vendor follows a procedure designed to ensure that the filling of the tank is safely accomplished by qualified personnel. Additionally, the tank is not re-filled until it has reached 30% capacity or less. The off-site consequence analysis considered external events that include seismic activity, transportation accident, onsite fire that results in a BLEVE , tank overfilling, tank overpressurization, and pressure relief valve failure. These potential causes for releases were evaluated for their likelihood and severity of off-site consequences. The seismic analysis prepared for the site Risk Management Prevention Plan considered all active faults with facility equipment impacts including surface fault rupture, liquefaction, subsidence, landslide, tsunami and seiche. The seismic analysis included a review of vulnerable components such as furnace piping and furnace tanks. BFG anticipates that the worst case release is representative of the potential impacts from seismic activity under the worst case conditions. Other external events considered were reviewed for alternate case off-site consequence and the one external event with the greatest combined likelihood and severity is included in the RMP. FIVE-YEAR ACCIDENT HISTORY The BFGoodrich Santa Fe Springs facility has not had an accident involving the propane systems during the past five years which resulted in any deaths, injuries, or responses or restoration activities for an exposure of an environmental receptor. PREVENTION PROGRAM BFGoodrich has developed a Risk Management Program that includes all of the required Program 3 prevention elements for the propane systems. The key components of the prevention program are summarized below: ^ The development, documentation, and operator availability of critical process safety information regarding the hazards of Propane and the design of the system and equipment. This information is used to fully understand and safely operate the propane systems. ^ The development of an extensive employee participation program, which includes employees from all levels of the organization and from all areas within the plant (i.e., production and maintenance). This program also assumes that employees that utilize the propane systems are most knowledgeable about it and are able to easily, effectively, and regularly recommend changes or improvements which enhance safety. ^ The performance of a formal process hazard analysis (PHA) on the propane systems using the what-if/checklist technique. A team with expertise in engineering, operations, maintenance, and safety evaluated the existing propane systems in depth and analyzed recommendations to improve the safety and operability of the system. The PHA addressed: (1) process hazards; (2) previous incidents; (3) engineering and administrative controls applicable to the hazards; (4) the consequence of control failures; (5) facility citing; (6) human factors; and (7) a qualitative evaluation of possible safety and health effects of control system failures. The PHA resulted in several procedural and/or hardware recommendations to improve the safety and operation of the systems. These recommendations are targeted for resolution before the end of the second quarter of 1999. The PHA will be updated and revalidated every five years. ^ Written operating procedures (OPs ) are used to provide the basis for proper and safe operation of the propane systems. The OPs include procedures for normal operations, startup, shutdown, emergency operations, and emergency shutdown. They also describe safe operating limits for temperature and pressure, the consequences of operating outside these safe operating limits, and a description of safety systems and how they operate. ^ Propane system operators receive refresher training at least every three years. The training content is based on the process safety information and operating procedures. The training program ensures that the operators understand the nature and causes of problems arising from system operations and serves to increase awareness with respect to the hazards particular to the propane processes. ^ Formal authorization systems (i.e., management of change procedure, pre-startup safety review) are in place to ensure that system changes or expansions are as safe as the original design and that an in dependent recheck confirms that the changes are consistent with the engineering design and in a condition to be safely operated prior to startup. ^ Events that might (or did) cause an accidental or unexpected release of propane are subjected to a formal investigation. The objective of the investigation is to correct deficiencies in such a way as to prevent recurrence. ^ Contractors that are hired to work on, or adjacent to, the propane systems are pre-qualified based on their knowledge of the systems, understanding of applicable codes and standards, written safety and training programs, and their demonstrated ability to work safely. ^ Prior to the performance of any hot work (i.e., spark or flame producing operations such as welding, cutting, brazing, grinding), management must approve the work by executing a written hot work authorization permit to verify that precautions to prevent fire have been implemented. ^ Periodic inspections of the external surface of the propane vessel s to detect any indication of potential failure that could lead to a release. ^ Replacement of pressure relief valves on the propane system every year. ^ Utilization of safety systems, including pressure relief valves, automatic shut-off valves, and manual shut-off valves, and safety interlocks. ^ Proper design, including adherence to recognized safety codes. ^ Adherence to fire codes, including National Fire Protection Association Code 58, and preparation for fires, storms, or events that could impact the propane systems. ^ Planning in accordance with the Santa Fe Springs Fire Department to ensure a rapid response to potential incidents with the system or external events. ^ Prevention program compliance audits performed every three years to verify that the appropriate management systems are in place and are being properly implemented. Any deficiency found is corrected. EMERGENCY RESPONSE PROGRAM The Santa Fe Springs facility has consolidated these requirements into the Eme rgency Response Plan (ERP). The ERP covers the regulatory requirements for emergency response training, evacuation procedures, procedures for notifying the public, government agencies, and local emergency response agencies of a release, procedures for the maintenance of emergency response equipment, and emergency management and organization structures. The ERP also contains complete instructions for responding to specific emergencies, including fires, medical emergencies, indoor and outdoor oil spills, flammable materials releases, natural disasters, workplace violence, and bomb threats. |