Honda of America Mfg., Inc., Anna Engine Plant - Executive Summary

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The Risk Management Plan Executive Summary 
 
 
 
The Accidental Release Prevention and Emergency Response Policies at the Honda of America Mfg., Inc.'s Anna Engine Plant: 
 
Honda of America Mfg., Inc. ("Honda") has developed and implemented two policies  
which directly impact and influence Honda's accident release prevention and emergency  
response activities.  First, Honda's Safety Policy expresses Honda's commitment to: 
 
- provide a safe and healthful working environment, 
- conduct its operations with the highest regard for associate safety, 
- continually improve the safety management system,  
- train associates in respects to safety related to their job, and 
- comply with all applicable safety and health requirements and standards mandated by  
federal, state, and local law. 
 
Second, Honda has developed and implemented an Environmental Policy which  
expresses Honda's commitment to: 
 
- comply with all applicable environmental requirements mandated by federal, state,  
and local law, 
- oper 
ate and continually improve an environmental management system, and  
- implement methods to prevent pollution, conserve natural resources and reduce  
waste. 
 
With these policies as a foundation, Honda's Anna Engine Plant (Honda/AEP) has made  
a significant effort to ensure compliance and good management in all areas relating to  
chemical safety.  Many of the Risk Management Plan (RMP) requirements are similar or  
identical to requirements covered by the Occupational Safety and Health Administration  
(OSHA) Process Safety Management (PSM) program, and the two Honda processes  
subject to RMP regulation are already subject to PSM requirements.  Moreover, even  
before the OSHA PSM standard was adopted as a final rule, Honda/AEP maintained a  
high level of protection from potential chemical exposures for all AEP associates.  This  
was accomplished through: operational controls, systems design, mechanical integrity 
and associate training.  Upon OSHA's final implementation of the PSM standard 
, existing  
Honda/AEP procedures were reviewed, and if needed, revised and upgraded to  
assure that the plant met all applicable PSM requirements.  In many respects, procedures 
to prevent or control unwanted releases at Honda/AEP currently exceed PSM requirements 
relative to mechanical integrity and associate training.  For example, Honda/AEP uses  
fixed head monitoring devices to detect leaks and/or releases, uses grade-specified  
components, replaces hardware prior to manufacturer-suggested replacement intervals,  
and has implemented comprehensive associate training. 
 
A Brief Description of the AEP Facility and the Regulated Substances Handled: 
 
Honda/AEP primarily consists of six manufacturing departments.  These  
departments are divided into two manufacturing groups, the Engine Manufacturing  
Group and the Suspension Manufacturing Group. 
 
The Engine Manufacturing Group: 
 
1. Aluminum Die Cast Department. 
 
In the Aluminum Die Cast Department, raw aluminum ingots are melted in  
alumin 
um furnaces.  The molten aluminum is then injected into dies either  
by low-pressure casting or by high-pressure casting.  Low pressure casting  
is used to produce engine cylinder heads.  High pressure casting is used to  
produce engine blocks and transmission casings. 
 
2. Aluminum Machining Department. 
 
Engine blocks and cylinder heads from the Aluminum Die Cast Department  
are machined into finished products for use in the Engine Assembly  
Department.   
 
3. Engine Assembly Department. 
 
The Engine Assembly Department consists of three assembly lines.  "0 line"  
assembles the Civic, Goldwing, and Valkyrie engines.  "1 line" assembles  
four cylinder engines for the Accord and Acura models.  "2 line"  
assembles four and six cylinder engines for the Accord and Acura models. 
 
The Suspension Manufacturing Group: 
 
1. Ferrous Casting Department. 
 
In the Ferrous Casting Department, scrap metal is melted in a cupola and  
poured into sand molds to form brake disk rotors, brake drums, and  
cylind 
er sleeves.  In the Quick Cast Knuckle furnace, iron is melted and  
poured into an alloy die to make front knuckle suspension pieces.  Sulfur  
dioxide, a regulated substance, is used to "cure" or harden resin coated sand  
cores used in the "disk core" manufacturing process.  Disk cores, in turn are  
used in the formation and molding of cast metal disk brakes. 
 
2. Ferrous Machining Department. 
 
In the Ferrous Machining Department, the brake disk rotors, brake drums,  
and cylinder sleeves poured in ferrous casting are machined into finished  
products.  In addition, inboard, inner, and outboard driveshaft parts are  
forged, machined, and heat-treated.  Crankshafts are also machined and  
heat-treated.  Anhydrous ammonia, a regulated substance, as well as propane, are used in the  
heat-treating (nitriding) furnace to chemically harden the surface of the  
crankshafts. 
 
(Note:  Because of a stay of propane applicability issued by the U.S. Court of Appeals on April 27, 1999, Honda's initial J 
une 16, 1999 RMP submittal did not address propane.  In light of the August 1999 amendments to Section 112(r) of the Clean Air Act set forth in the Chemical Safety Information, Site Security and Fuels Regulatory Relief Act, and in light of the anticipated dismissal of the stay, Honda has revised its RMP to fully address propane. 
 
3. Suspension Assembly Department. 
 
In the Suspension Assembly Department, driveshafts are assembled for the  
Accord and Acura models.  Front and rear suspensions are assembled for  
the Accord, Acura, and Civic models. 
 
Worst-case and Alternative Release Scenarios: 
 
(Note:  Because of concerns expressed by various governmental agencies regarding the  
public availability of hypothetical chemical release scenarios, as expressed in the Chemical Safety Information, Site Security and Fuels Regulatory Relief Act of August 1999, Honda has not  
provided descriptions of its release scenarios in this Executive Summary.  The  
detailed descriptions, as required, are incl 
uded in the RMP document itself.) 
 
Honda/AEP has only three regulated substances above currently effective threshold  
quantities: sulfur dioxide, anhydrous ammonia and propane. Sulfur dioxide and anhydrous ammonia, which are used in separate processes, fall into the category of "regulated toxic substances".  The third substance, propane, falls under the "regulated flammable substance" category.  Consequently, Honda/AEP is submitting in its RMP a worst-case release scenario for sulfur dioxide (which has the greatest calculated distance to an endpoint) and alternative release scenarios for both sulfur dioxide and anhydrous ammonia.  For both regulated toxic substances, an environmental consultant was hired to perform computer modeling to predict the impact areas for the release scenarios.  The consultant used the "Process Hazard Analysis  
Software Tools (PHAST) model, version 5.11, to model both chemicals in a gas state.  Honda is also submitting worst-case and alternative-case release s 
cenarios for propane.  The worst-case and alternative-case release scenarios for propane were established by using EPA published guidance documents for propane storage facilities.  
 
1.    Sulfur Dioxide: 
 
Sulfur dioxide is used in the disk core manufacturing process in the ferrous casting  
department.  The disk cores are used in the manufacture of front brake disk rotors  
which will be mounted on the Accord, Civic and Acura models.  In this process,  
two types of sands and two different resins are first mixed together.  The mixed  
core sands and resins are then blown into a "core" box.  Sulfur dioxide,  
which is stored as a liquid in cylinders located in the tank containment room, is  
pumped to the core-making machine where it passes through a vaporizer and is  
transformed into a gas.  A plate is placed over the core box and the sulfur  
dioxide gas is introduced through the plate into the core box to cure the resins.  The  
sulfur dioxide is purged from the core box by compressed air and v 
ented to a  
caustic soda scrubber for neutralization.  The finished cores are removed from the  
core box and inspected prior to their use in the disk manufacturing process.    
 
For sulfur dioxide, the hypothetical worst-case release scenario was modeled  
using an "F" atmospheric stability class based on a 10-minute instantaneous  
release from one of the sulfur dioxide storage vessels in the containment room.     
 
The alternative release scenario conducted for sulfur dioxide analyzed the  
hypothetical release of sulfur dioxide, as a gas, through a break in the line  
connecting two tanks in the containment room.  The model used the "D"  
atmospheric stability class.  
 
2.    Anhydrous Ammonia: 
 
Liquid anhydrous ammonia (metallurgical grade) is stored in an 18,000 gallon-  
capacity tank.  The ammonia is pumped to the nitriding furnace through a series  
of immersion heaters where the liquid is vaporized into a gas.  Through overhead  
piping, the ammonia vapor travels through a shutoff header stand 
and a flowmeter  
stand prior to being introduced into the nitriding furnace.   
 
Due to the high temperature (1,110 degrees Fahrenheit) the ammonia dissociates  
into its components according to the following reaction: 
 
2 Anhydrous Ammonia -> 2 Nitrogen + 3 Hydrogen 
 
The nitrogen combines with the alloying elements in the steel to form nitrides.   
The nitrides form at the steel surface as a hard chemical layer which will  
minimize wear and fatigue.  The remaining component, Hydrogen, (3H2) is  
burned off by the afterburner. 
 
In accordance with the RMP rules and instructions, because the hypothetical  
worst case release scenario for anhydrous ammonia was estimated to affect a  
smaller number of public receptors than the hypothetical worst case release  
scenario for sulfur dioxide, the worst case release scenario for anhydrous  
ammonia is not being reported in the RMP.  
 
The alternative release scenario for anhydrous ammonia analyzed the hypothetical  
release of anhydrous ammonia, as a ga 
s, through a line break during the loading  
of the storage tank.  The model used the "D" atmospheric stability class.  
 
3.  Propane: 
 
Propane is used in the nitriding funace to fuel pilot lights and the flame curtains.  The pilot light is associated with an afterburner attached to the furnace exhaust stack, which is used to incinerate off gases emitted by the furnace.  The flame curtains are used to keep oxygen and other gasses from entering the furnace and contaminating the controlled atmosphere within the furnace.   
 
Propane is also used to react with ammonia within the furnace and the result is the increased surface hardness of the crankshaft. 
 
For propane, the worst case release scenario was determined through the use of reference tables located in the RMP Guidance Document for Propane Storage Facilities.   
 
The alternative release scenario for the hypothetical release of propane was also determined by using reference tables located in the RMP Guidance Document for Propane Storage  
Facilities.  
 
The General Accidental Release Prevention Program and Chemical-Specific Prevention  
Steps at AEP: 
 
In addition to being subject to the RMP requirements, Honda/AEP is subject to and  
complies with the OSHA Process Safety Management (PSM) standard to prevent  
accidental chemical releases from the disk core manufacturing process and the operation of the  
nitriding furnace.  Honda/AEP surpasses the requirements of various elements of the  
standard, including response training, mechanical integrity and chemical-monitoring  
devices to maintain high levels of compliance and prevent accidental releases.   
Monitoring systems have built-in back up systems to insure fail-safe operation/detection  
and therefore are highly reliable.  The plant also exceeds training requirements and has  
appropriate material/equipment to control or stabilize process leaks and releases.  The  
AEP emergency response team conducts intensive annual training regarding chemical  
specific response scenarios a 
nd maintains chemical specific response equipment.  As a  
result, no significant accidental releases have occurred over the life of the various  
processes regulated by the PSM standard. 
 
Five-year Accident History: 
 
In the past five years, there have been two small releases of sulfur dioxide from both the  
tank storage area and the process area.  These releases resulted in minor injuries to  
associates in the area of the process but did not result in any damage to on site property  
nor did these releases result in any damage, injury, or other known impacts offsite.  In the  
same five-year period, there have been no releases of anhydrous ammonia or propane. 
 
The Emergency Response Program: 
 
Honda of America Mfg., Inc., has developed a company-wide Emergency Response Plan  
(ERP), which explains Honda's commitment to emergency response.  This plan describes  
the responsibility and procedures of Honda personnel and establishes a system in which the 
members of each plant's emergency respons 
e team work with local emergency  
response organizations.  This company-wide plan also serves as a model upon which the Honda/AEP  
emergency response team has based its own AEP-specific ERP.  The AEP plan outlines how  
the Honda/AEP emergency response team is to work closely with the Anna Fire  
Department, the Shelby County Hazmat Team, and the Emergency Management Agency  
to promptly respond to any emergency. 
 
The Honda/AEP Emergency Response Team (ERT) meets annually with the Village of  
Anna Fire Chief and members of its response team to review operations at the plant.  This  
meeting also includes an in-depth tour of the plant that includes inspection of sumps,  
hydraulic pump pits and a thorough inspection of the roof.  In addition, during last  
October and November, the Honda/AEP ERT took part in a joint 36 hour training session  
with the Village of Anna Fire Department to train new members of the respective teams.   
The City of Sidney Fire Department conducted the training. 
 
The  
Anna Engine Plant Emergency Response Team is currently made up of 12 to 15  
associates on each of the three production shifts.  The members are volunteers who work  
full-time in their respective production departments.  There are 3 full-time emergency  
response staff members, one for each shift, with one (on a rotating basis) on call 24 hours  
a day, who are responsible for leadership and coordination of team members.  Each  
emergency response team member must meet Fire Fighter Level I state requirements as  
defined in section 1001 of the National Fire Prevention Association (NFPA) manual and  
must attend quarterly training classes and drills.  Training is taught on-site by an outside  
training contractor in accordance with NFPA, section 600 requirements.  Additionally, 5  
to 10 emergency response team members on each shift are trained to the Hazmat  
Technician level as defined in OSHA section 1910.120 requirements.   
 
The emergency response team members are activated by procedures ide 
ntified in the AEP  
Emergency Response Plan.  If plant security, which covers the plant switchboard 24  
hours a day, receives an emergency call, they are trained to activate the alarm system and  
alert the emergency response pagers.  The response team will be activated and respond  
using procedures identified in the response plan. 
 
Outside agencies are activated by plant security by dialing 911 in the event that the  
response team requests their assistance or if the response team is not available to respond  
at full strength.  Public notification of a release will be handled jointly by the Shelby  
County LEPC and Sheriff's Office.  The AEP Emergency Response Plan is reviewed  
annually with the local Emergency Management Agency (EMA), the Village of Anna  
Fire Department, the Shelby County LEPC, and the Shelby County Sheriff's Office. 
 
Planned Improvements to Improve Safety: 
 
In order to greatly minimize the possibility of a worst case release from its anhydrous  
ammonia and propane sto 
rage tanks, Honda has placed these tanks in an isolated, fenced-off area subject  
to restricted entry, thereby limiting the types and amounts of physical activities taking  
place at or near the tanks.  
 
In addition, Honda/AEP is currently investigating alternative manufacturing techniques 
that could reduce or eliminate the use of Sulfur Dioxide.  This potential process modification  
would eliminate one of two AEP processes that are currently regulated by the PSM standard.
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