Honeywell/Metropolis Works - Executive Summary

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Introduction/Accidental Release and Emergency Response Policies 
The Metropolis Works facility is a manufacturing plant located in Metropolis, IL employing 350 people.  It is part of the Specialty Chemical Business of Honeywell International Inc.   Headquartered in Morris Township, New Jersey, Honeywelll is an advanced technology and manufacturing company serving customers worldwide with aerospace and automotive products, chemicals, fibers, plastics and advanced materials. With 1998 sales of approximately $15 billion, the company ranks among the top 100 of the Fortune 500.  Honeywelll has approximately 120,000 employees in 95 countries.  Honeywell operates twelve major businesses:  Aerospace Equipment Systems, Aerospace Engines, Electronic and Avionic Systems, Aerospace Marketing Sales and Services, Federal Manufacturing and Technologies, Polymers, Specialty Chemicals, Electronic Materials, Consumer Products Group, Turbocharging Systems, Truck Brake Systems,  and Fric 
tion Materials.  More information about Honeywelll may be found at its Web Page: 
It is the world wide policy of Honeywelll to design, manufacture and distribute its products and to handle and dispose of materials throughout their life cycle in a manner that protects the environment and safeguards employees, customers and the public from unacceptable risk.  Honeywell's complete Health, Safety and Environmental Policy may be found at the Honeywell  Web Page. 
This facility participates in the Responsible Care program of the Chemical Manufacturers Association.  The Community Awareness and Emergency Response Code of Responsible Care brings chemical plants and local communities together through communications and cooperative emergency planning.  The plant has formed a Community Awareness Committee (CAC) to formally communicate items of concern, including process safety enhancements, accidental releases, etc., to the local community. 
The Process Safety Code of Responsibl 
e Care is designed to prevent fires, explosions and accidental chemical releases.  The code requires safety audits, inspection and maintenance programs, and safety training for employees and contract workers.  Facilities are encouraged to listen to the concerns of the community and to consider these concerns when designing and implementing process safety systems. 
Plant equipment and facilities have been designed and installed to operate safely.  Periodic safety reviews are performed by Hazard Review Committees, by corporate environmental and safety audit teams, and by various regulatory agencies.  Emergency preparedness and response plans have been developed, most notably the Radiological Contingency Plan and the Emergency Response Plan, and training has been given to in-plant personnel.  A full drill is held at least annually to test the effectiveness of the plans. The Emergency Response Plan is directed through the local ESDA (Emergency Services Disaster Agency) Coordinator for off- 
site response.   
The Metropolis Works (MTW) Plant Manager participates actively in the UF6 (uranium hexafluoride) Safety Working Group.  This group consists of the world's five major UF6 converters.  Once per year, this group meets and discusses items of mutual concern involving safety.  This group has helped to spread the "best practices" of each converter to all other converters, thereby enhancing the safety of all five operations.  
Stationary Source and Regulated Substances 
Honeywell/Metropolis Works produces uranium hexafluoride, sulfur hexafluoride, iodine pentafluoride, antimony pentafluoride, and liquid fluorine.  Liquid fluorine is produced for internal consumption only; all others are chemicals that we sell.  Operations to produce these chemicals are continuous and operate on a 24-hour basis.  In the production processes, we use the following chemicals that EPA has identified as having the potential to cause significan 
t off-site consequences in the event of an accidental release. 
>  Toxics 
Anhydrous hydrofluoric acid (AHF) is stored in tank farm facilities in three storage vessels.  Additionally, an AHF tank car may be on site for unloading purposes.  AHF is used in the manufacture of fluorine and the conversion of uranium dioxide to uranium tetrafluoride. 
Ammonia (NH3) is stored in tank farm facilities in two storage vessels.  Additionally, an NH3 tank car may be on-site for unloading purposes.  NH3 is for the production of hydrogen gas, which is consumed on-site for the reduction of uranium ore concentrates to uranium dioxide. 
Liquid fluorine is produced and stored in insulated trailers.  It is cooled with liquid nitrogen contained in a jacket that surrounds the product container.  Liquid fluorine is produced as needed for the manufacture of iodine pentafluoride and antimony pentafluoride. 
Worst-case and Alternate Release Scenarios and Administrative and Mitigation Controls in Place to Limit  
the Impact of the Release 
+  EPA's Risk Management Program requires the Metropolis plant to prepare an analysis of a hypothetical worst case release of the chemicals covered by the RMP regulation.  EPA defines a worst case release as the release of the largest quantity of the chemical from a vessel or process line failure.  EPA also assumes that the failure takes place over 10 minutes and that all safety systems fail to operate.  In addition, the release is assumed to take place during the worst possible weather conditions.  For a number of reasons discussed in this submittal, it is extremely unlikely that this event would ever occur. 
+  In addition, the Metropolis plant is required to analyze the impact of an alternative accidental release scenario. 
>   Worst-Case Release Scenario - Regulated Toxic Chemicals 
A release of 180,0 
00 pounds of anhydrous HF from a tank car was the worst case modeled. The release would extend off-site and reach public receptors. 
>  Alternate Scenarios 
Alternate scenarios were developed for the following classes of chemicals that are present at the Honeywell/Metropolis Works facility:  toxic gases (anhydrous ammonia, anhydrous hydrogen fluoride, and fluorine).  In addition, the following 3 chemicals at Metropolis can form hydrogen fluoride through their reaction with water vapor:  iodine pentafluoride, antimony pentafluoride and uranium hexafluoride. 
' Due to a split in a hose, 320 pounds of liquid anhydrous ammonia would be released through an orifice having a diameter of 2 inches.  The release is terminated after 10 seconds by the closing of automatic shutoff valves.  The release has an off-site impact. 
' Due to a split in a hose, 1130 pounds of liquid anhydrous hydrogen fluoride would be released through an orifice having a diameter of 1.5 inches.  The release is terminated a 
fter 1 minute by the closing of automatic shutoff valves.  The release has an off-site impact. 
' Due to a joint failure in a pipe, two pounds of fluorine would be released through an orifice with a diameter of 1 inch.  The release occurs for only 6 seconds because of the closure of a remote actuated shutoff valve.  The release has an off-site impact. 
' Due to joint failure in a pipe, 100 pounds of anhydrous hydrogen fluoride vapor are released through an orifice with diameter of 0.53 inches.  The release occurs for 10 minutes until a manual valve can be shut off.  The release extends off-site. 
' In a period of 20 minutes, 2000 pounds of iodine pentafluoride are released to the floor of a 500 ft2 building.  The release does not have an off-site impact. 
' Due to puncture in a shipping container, 530 pounds of antimony pentafluoride are spilled within a building during a period of two minutes.  The release does not have an off-site impact. 
' Due to failure of a pigtail connector, ura 
nium hexafluoride is released through an orifice with a diameter of 0.75 inches.  The release takes place for one minute until a manual valve can be shut off.  The release has an off-site impact. 
5-Year Accident History 
There have been no releases of RMP listed chemicals in the last five years; however, within the last five years there have been releases of iodine pentafluoride and uranium hexafluoride which, when released into the atmosphere, generate hydrogen fluoride. 
In May, 1995, 2000 pounds of iodine pentafluoride were released.  On site, sixteen (16) people received plant first-aid treatment.   In October 1997, 5 grams of iodine Pentafluoride were released.  One minor HF burn occurred to one person on-site.  The following improvements were identified and implemented in response to these events: 
1. Installed manually operated remote shutdown stations 
2. Installed HF monitors with automatic shutdown and vent closure capability 
3. Installed new scr 
ubber to reduce fugitive and release emissions 
4. Installed instrument upgrades 
5. Installed fence line HF monitors 
In January 1998, three people were treated for minor HF burns after 33 grams of uranium hexafluoride were released.  More rigorous procedures for handling uranium hexafluoride have been implemented and check lists have been developed to insure compliance with these procedures. 
Emergency Response Program 
Metropolis Works has an Emergency Response Plan (ERP) for chemical releases.  In the event of an emergency, a plant siren is sounded and personnel evacuated to certain plant areas for head count.   Emergency response personnel are directed  to the area of the emergency where they provide assistance as necessary.  In the event of a release that will impact the public, the Crisis Manager will coordinate off-site emergency response through the Massac County 911 emergency system. The Massac County 911 system may notify, based on the ne 
ed expressed , the fire department,  the Sheriff, ambulance as necessary, and the Massac County Illinois Emergency Services and Disaster Agency (ESDA) Coordinator.  
The Massac County Fire Department will be utilized in the event an emergency  exceeds the capability of the Metropolis Works Emergency Response Team. The Sheriff will coordinate activities with the Illinois State Police that may be necessary as the result of the plant emergency. The ESDA Coordinator is responsible for the sounding of eight community sirens.   The sirens are sounded in accordance with the "Metropolis-Massac County Emergency Services and Disaster Agency -Massac County Siren System Procedure".   
The Metropolis Works Emergency Response Team consists of approximately  60 people.  Each person is given 24 hours of  initial emergency response training  and 24 hours of refresher each year.  MSDS's (Material Safety Data Sheets) are reviewed at Plant Safety meetings and are available in operating manuals. Additional 
ly, MSDS's for Plant chemicals are supplied to the local fire department.   Approximately 100 plant personnel are trained in first aid and given refresher training each year. Each of the local hospitals is trained in HF first aid treatment and contamination control. 
Plant and community sirens are tested for operation monthly.  Plant emergency response headcount drills are provided quarterly and at least one major scenario drill coordinating off-site and on-site response is performed yearly.  
General Accident and Chemical Specific Accident Prevention Program 
The general accident prevention for a Program 3 RMP facility is very comprehensive, consisting of twelve elements.  These elements are part of Occupational Safety and Health Act - Process Safety Management Regulations (OSHA 1910.119). Metropolis Works is in compliance with OSHA 1910.119. The general accident prevention elements are as follows. 
( Process Safety Information 
( Process Hazard Analysis 
( Operating Procedures 
( Training 
( Mechanical Integrity 
( Management of Change 
( Pre-Startup Review 
( Compliance Audits 
( Incident Investigation 
( Employee Participation 
( Hot Work Permits 
( Contractors 
The Metropolis Works uses its Management of Change (MOC) process to assure plant compliance with many of the elements of OSHA 1910.119.  Any plant process change requires the written approval of Safety, Occupational Health, Environmental, Production and Maintenance organizations including upper management.  During the MOC review of a process change, actions required for compliance with regulatory requirements and plant policy are shown on the review form.  All of these actions must be completed before the change can be made. 
A plant team consisting of both management and union represented employees conducts incident investigations.  The plant burning and welding permit program is also the responsibility of both management and uni 
on represented employees.  A trained in-plant auditor conducts compliance audits.  Contractors receive an extensive indoctrination concerning plant hazards and the plant rules and procedures that have been developed to ensure a safe workplace.  Finally, mechanical integrity is assured by periodic inspections of all critical equipment. 
The chemical specific accident prevention/mitigation measures are shown below. 
( Anhydrous Hydrofluoric Acid 
>  Emergency storage tank and emergency air pollution prevention scrubber for relief valves on HF storage tanks. 
>  Automatic shut-offs on HF tank car-unloading valves. 
>  Nuclear level indicators on HF storage tanks to prevent accidental overfill. 
>  Improved valves in HF service. 
>  Risk assessment by outside consultant/expert. 
>  Foundation improvements to improve earthquake resistance at HF storages. 
>  Use of procedure check lists and improved training for operation of HF storage tanks. 
>  Fence line HF detectors and alarm. 
>  Periodic inspe 
ction of nitrogen pressure regulators and relief valves in HF system. 
>  Periodic inspection and/or replacement of unloading hoses. 
>  Monthly audit of unloading operations by area foreman. 
>  Emergency repair kits for leaking tank cars. 
>  Pipeline color coding and marking. 
( Ammonia 
>  Excess flow valves on ammonia storage tanks and tank cars. 
>  Improved valves in ammonia service. 
>  Foundation improvements to improve earthquake resistance at ammonia storage tanks. 
>  Use of procedure check lists and improved training for Ammonia storage. 
>  Periodic inspection and/or replacement of unloading hoses. 
>  Monthly audit of unloading operations by area foreman. 
>  Pipeline color coding and marking. 
(  Iodine Pentafluoride/Antimony Pentafluoride 
>  Manually operated remote shutdown stations for IF5 process. 
>  HF detectors and automatic shutdown for IF5 area. 
>  Remotely operated shut-off valve for SbF5 packaging. 
>  New air pollution prevention scrubber to reduce both fugitive and rele 
ase emissions. 
>  Instrumentation upgrades. 
>  Use of procedure check lists and improved training. 
(  Liquid Fluorine 
>  Trailers placed on load cells to eliminate trailer movement and potential overfills. 
>  Instrumentation upgrades. 
>  Remote shut-off switches in the fluorine products area. 
>  Use of check lists and improved training. 
( Gaseous Fluorine 
>  Air pollution prevention scrubbers for HF vaporizer relief valves. 
>  Cell maintenance booths air pollution prevention scrubber to reduce fugitive emissions. 
>  High pressure alarms on HF vaporizers. 
>  Level control on fluorine cells. 
>  Use of check lists and improved training. 
>  Pressure switches on fluorine cells. 
( Uranium Hexafluoride 
>  Smoke detectors and cameras in distillation areas for prompt emergency. 
>  Automatic shut-off valves at cylinder fill spots, remotely operated from control room. 
>  Inventory reduction for distillation feed tanks. 
>  Cylinder buggies to reduce handling of hot UF6 cylinders. 
>  Alternate t 
anks for containment of pressure relief. 
>  Automatic sampling system. 
>  Standby power system for critical equipment. 
>  General mechanical integrity program. 
>  SOPs to minimize emissions. 
>  Use of check lists and improved training. 
Planned Changes to Improve Safety 
The antimony pentafluoride and iodine pentafluoride production areas now have HF monitors that on the detection of HF leaks immediately shut down the operation and close all air vents.  A new pollution control device is being installed that has the capability of removing and scrubbing releases in these manufacturing areas. 
The HF unloading facility presently has three (3) storage vessels, a tank car and associated piping.  The present safety system includes remote activated valves on the tank car unloading valves and on storage transfer lines, and alternate tank with air pollution prevention system to receive the entire contents of a storage vessel, as well as an outlet for  
HF exiting vessel relief valves and rupture discs.  The Metropolis Works is presently evaluating additional HF mitigation techniques including water spray mitigation, enclosures for HF storage and tank car unloading, refrigerated storage of HF and combinations of these.
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