Aerojet Fine Chemicals LLC - Executive Summary
A Risk Management Program (RMP) has been implemented at Aerojet Fine Chemicals LLC - 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:
Aerojet Fine Chemicals Commitment to Safety;
Description of the Stationary Source and Regulated Substances;
General Accidental Release Prevention Program;
Five-Year Accident History;
Emergency Response Plan; and
Planned changes to improve safety.
Aerojet Fine Chemicals (AFC) and GenCorp 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 di
sclosed 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, AFC 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 AFC to minimize the impact o
f 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.
AFC'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 and more than 20 years of pharmaceutical manufacturing has resulted in one of the most impr
essive safety records in the industry; incidents 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 Fine Chemicals 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 Fine Chemicals 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 design reviews, process hazard analysis (PHA), critical safety review (CSR) and a readiness review. The disciplines represented at these various reviews typically include personnel from process engineering, production and operations, fire services, and EH&S staff. These reviews are held for all significant new or modified programs at Aerojet Fine Chemicals.
Description of the Stationary Source and Regulated Substances
The Aerojet Sacramento site is located approximately 15 miles east of downtown Sacramento at Highway 50 and Hazel Avenue. The property covers about 8,500 contiguous acres. Aerojet Fine Chemicals covers about 380 acres, wholly within the Aerojet site's 8,500 acres. The Aerojet site 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 t
he 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. Aerojet Fine Chemicals established in 1998, is a custom manufacturer of fine chemicals, intermediates, and bulk active materials primarily for the pharmaceutical industry.
As part of the RMP requirements, AFC 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 Fine Chemicals 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 c
atastrophic 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 AFC's prevention program. The ARS serve to demonstrate the ability of AFC 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 WCS for regulated toxic substances at the AFC
Sacramento site involves the release of anhydrous ammonia from a storage vessel over a ten minute period. 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 ammonia 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 200 ppm.
The ARS selected for the AFC ammonia system was still the unlikely failure of the tank with the contents being released over a ten minute period. However, typical weather conditions were assumed. The RMP*Comp program was again used for the ARS analysis. The RMP*Comp program calculations estimate that the ammonia would travel 0.6 miles before dispersing to a concentration that no lon
ger 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.
General Accidental Release Prevention Program
Some specific activities in the Aerojet Fine Chemicals 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.
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 critical equipment in the process, which includes written procedures, training requirements, work orders, equipment maintenance, and documentation.
-A hot work permit system assures that work is done safely and properly. Line breaking procedures are implemented.
-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.
-A contractor safety program has been implemented.
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 signific
ant property damage on site, or known deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage off site.
Aerojet Fine Chemicals' use of anhydrous ammonia is a new process; therefore, there have been no accidents or incidents that fit the above description.
Emergency Response Program
Overall safety at Aerojet Fine Chemicals 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 used 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. Plant operators are trained to various levels of emergency preparidness to assist Fire Services in the event of an emergency.
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 Fine Chemicals conducts numerous design and operational safety reviews prior to any program startup. A final critical safety review is held to review the entire program by a multi-disciplinary team, including representatives from E, H & S, fire services,management, and operators and engineers from the specific process area for technical expertise.
Recommendations developed as a result of these reviews and other progra
ms such as process improvement, equipment inspections, safety meetings, lessons learned, industry experience, technology improvements, and employee suggestions, are all evaluated and implemented as required.