Honeywell International Inc., Geismar Plant - Executive Summary |
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RMP*Submit: Executive Summary Honeywell Geismar Plant 1000 0008 5061 EPA RMP Facility Identifier 2082 LDEQ Facility ID Number 1. Introduction The Honeywell International Inc. (Honeywell) Geismar Site is a manufacturing facility located in Geismar, Louisiana. It is part of the Specialty Chemicals Business Unit of Honeywell International Inc. Headquartered in Morris Township, New Jersey, Honeywell is an advanced technology and manufacturing company serving customers worldwide with aerospace and automotive products, chemicals, fibers, plastics and advanced materials. With 1999 sales of approximately $24 billion, the company ranks among the top 100 of the Fortune 500. Honeywell has approximately 125,000 employees in 95 countries. Honeywell is a diversified technology and manufacturing leader, serving customers worldwide with aerospace products and services; control technologies for buildings, homes and industry; automotive products; power generation systems; specialty chemicals; f ibers; plastics; and electronic and advanced materials. More information about Honeywell may be found at its Web Page: www.honeywell.com. It is the world wide policy of Honeywell 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. The Honeywell Geismar Site 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 Process Safety Code of Responsible Care is designed to prevent fires, explosions, and accidental chemical releases. The code requires safety audits, inspection and maintenanc e 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. The Honeywell Geismar Site endeavors to accomplish this by sponsoring and regularly meeting with established local Community Advisory Panels. Honeywell's Geismar site participates in community advisory panels for both Ascension and Iberville Parishes. 2. Plant Description The Honeywell Geismar Site is located primarily in Ascension Parish on the Mississippi River at Mile 187.0 and is bounded by highways 75, 3115 and 30. Honeywell shares the site with three other chemical manufacturing facilities. The area is predominately rural with adjacent and nearby chemical manufacturing facilities. There are no immediate residential neighbors. The plant employs approximately 180 company and about 90 contract workers. The Honeywell Geismar Site's three covered processes m anufacture new generation ozone friendly refrigerants, inorganic acids and fluoropolymer resin. The Hydrogen Fluoride Plant manufactures hydrogen fluoride. The Multiproducts Plant manufactures 1,1,1,2 tetrafluoroethane (HFC 134a), pentafluoroethane (HFC 125) and 1-chloro-1,2,2-tetrafluoroethane (HCFC 124). The Aclon Resin Plant manufactures fluoropolymer resin. HFC 134a is used as a refrigerant in automotive applications. HFC 125 is used as a refrigerant in residential air conditioners and commercial refrigeration units such as supermarket freezers, display cases and ice machines. HCFC 124 is used in medical sterilants, rigid foam insulation manufacturing and in medium temperature refrigeration blends. Anhydrous hydrogen fluoride is used as a raw material in the manufacture of refrigerants, fluorocarbons, and gasoline as well as other chemical derivatives. Aqueous solutions of hydrogen fluoride are used in the manufacture of electronic components and circuit boards, steel, high purity quartz, light bulbs and television and computer monitor screens. Aclon Resin is used in the manufacture of film used in medicinal and food bubble packaging. The Geismar site also stores and uses oleum and chlorine. Because the Geismar site stores and uses hydrogen fluoride, oleum, chlorine, trifluorochloroethylene and 1,1 - difluoroethylene in more than the threshold quantities specified in the EPA Risk Management Program (RMP) regulation the site is covered by the regulation. 3. Accidental release prevention and emergency response policies: It is the policy of the Honeywell Geismar Site to operate a safe and environmentally sound facility by * identifying and controlling health, safety, or environmental risks related to its operations; * designing its processes to protect people, property and the environment; * conducting and continually reviewing and improving programs for safety, health and environmental excellence; and * establishing processes to assure that all laws and regulations applicable to its operations and products are known and observed. The accidental release prevention and emergency response policy associated specifically with the plant's use of hydrogen fluoride, oleum, chlorine, trifluorochloroethylene and 1,1 - difluoroethylene involves * the integration of safety programs, devices and technologies inherent in the design of the process, * safe operational procedures and management practices, * operator training, * the preparation and testing of site emergency response plans, * the maintenance of onsite emergency response equipment, and * a professionally trained Emergency Response Team, coordinating our efforts and resources with local emergency response services, and communicating with the community. The Geismar site has a well established Process Safety Management System and Health Safety and Environment Management System (HSE MS). Both management systems are integrated with all other site management systems. The se systems contain documented procedures for safe work practices, management of change, maintenance of process safety information, work permitting, emergency response, environmental monitoring, pollution prevention and employee health monitoring. The emergency response plan is a documented modular procedure that covers activation, response, notification, personnel protection, decontamination, evacuation and incident critique. The site's emergency brigade personnel are regularly trained to maintain a high level of readiness and expertise. Drills are routinely held within the plant, with adjacent manufacturing facilities and with local agencies. The plant participates in hazardous materials response activities with local public safety agencies. The site maintains its own fire truck and ambulance. Certified medical first responders are present onsite at all times. A plant nurse maintains the plant's medical clinic during normal business hours. The plant has provided medical treatme nt information on plant hazardous materials to local health, public safety and emergency response organizations. The plant has conducted familiarization activities with local medical facilities. 4. Worst Case and alternative release scenarios and administrative and mitigation controls are in place to limit the impact of a release. EPA's Risk Management Program requires the Honeywell Geismar site 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 must take place during infrequent weather conditions which would inhibit dispersion of any vapor cloud. For a number of reasons discussed in this submittal, it is extremely unlikely that this event would ever occur. In addit ion, the Honeywell Geismar site is required to analyze the impact of an alternative accidental release scenario for the chemicals covered by the RMP regulations. The offsite consequence analysis for a "worst-case release scenario" at the Geismar Site was performed for the largest single storage vessel for each RMP toxic and flammable chemical. The offsite consequences for each identified scenario were modeled pursuant to EPA's Offsite Consequence Analysis Guidance. The worst case scenario for toxic chemicals was identified as a release of anhydrous hydrogen fluoride. The largest anhydrous hydrogen fluoride storage vessel is a horizontal, cylindrical steel tank located in an outdoor tank park in the hydrogen fluoride plant. The elevated tank is located within the designated process containment for the process area. The tank's actual maximum operational storage content is 720,000 pounds. This is intentionally below the tank's maximum design capacity. The release and meteorologic al parameters used for the worst-case release scenario for the hydrogen fluoride source were those defined and pre-set by EPA in the RMP Rule for toxic gases. The occurrence of the specified release and meteorological conditions, either individually or concurrently, is considered extremely unlikely. In accordance with the Rule, the maximum 720,000 lb. full capacity contents of the vessel were assumed to be released as a vapor at a constant rate over a 10-minute period. The methodology recommended in EPA's Offsite Consequence Analysis Guidance document was used to determine the distance traveled by the hydrogen fluoride vapors before the concentration of the vapors decreased to an endpoint concentration of 0.016 milligrams per liter of air. This endpoint concentration was selected by EPA and listed in the RMP Rule specifically for hydrogen fluoride. The HGSystem dispersion model and PAVE pool evaporation model were used to determine the offsite impact of the Geismar Site's wors t-case hydrogen fluoride release. Under these unlikely release assumptions, this hypothetical release would have an impact beyond the boundaries of the Geismar site and would reach public receptors during meteorological conditions specified by EPA for RMP worst case scenarios. The Geismar site has numerous programs, systems and controls in place which make the occurrence of the described worst case scenario extremely unlikely. These systems and controls are described elsewhere in this document. The worst case scenario for flammable chemicals was identified as a release of trifluorochloroethylene in the Aclon Resin Plant. The contents of the tank were assumed to be released instantaneously to the atmosphere followed by a vapor explosion. There would be no offsite impact from this release. Because of the safety systems and prevention programs in place, the site focussed emergency planning resources on release scenarios which, although unlikely, represent some potential for occurre nce. The facility evaluated process hazard analyses conducted on the regulated processes and reviewed incident histories to identify potential release scenarios. Alternative release scenarios for the materials are described below: Hydrogen Fluoride Plant a) Anhydrous hydrogen fluoride Anhydrous hydrogen fluoride is pumped from intermediate storage to distillation for impurity removal. The transfer line has a flange connector at the discharge of the pump. The partial separation of this flange connector was chosen as the alternative release scenario. Multiple systems exist to mitigate a release resulting from separation of the distillation feed pump discharge flange. First, the area is actively monitored by operations, quality control and maintenance personnel. Many of these persons maintain radio communications and would immediately alert the control room of any abnormal condition. Second, the area is monitored in the control room through closed circuit television. The contr ol room can rapidly secure operation of the pump should an incident occur. Systems exist to isolate the feed system to prevent further release. It is estimated that system deactivation would occur within 2-3 minutes of occurrence. In addition, the facility is equipped with several remotely controlled water spray monitors. Hydrogen fluoride is readily absorbed in water. The water mitigation system can be controlled from within the control room or from a second remote control station. The control room is equipped as a safe haven for continued occupancy during a release. Three of the system's nine monitors are capable of being directed onto the anticipated release point. The other monitors can be used to create a dense water curtain to mitigate any vapor release. It is estimated that with rapid shutdown of the pump, less than 600 pounds of hydrogen fluoride would be released. Prompt activation of the water spray mitigation system would greatly reduce the impact of the release. EPA's Offsite Consequence Analysis Guidance indicates that vapor concentrations would decrease to less than 0.016 milligrams per liter of air beyond the boundary of the Geismar site. Public receptors within the affected area include adjacent chemical manufacturing facilities, a railroad and a state highway. b) Oleum A review of the oleum handling system was conducted to identify an alternative release scenario. Oleum is transferred to the hydrogen fluoride Plant via an interplant pipeline. A partial flange separation on this line was selected for planning purposes. It was estimated that should this situation occur, the incident would be discovered and the transfer activity ceased within 10 minutes. The plant emergency brigade could respond and direct water to mitigate the vapors shortly thereafter. It is estimated that about 4,000 pounds of oleum would be released. Of the 4,000 lbs., a fraction would vaporize. EPA's Offsite Consequence Analysis Guidance indicates that vapor concentrations would decrease to less than 0.01 milligrams per liter of air beyond the boundary of the Geismar site. Public receptors within the affected area include adjacent chemical manufacturing facilities, a railroad and a state highway. c) Chlorine An evaluation of the facility's use and handling of chlorine was conducted to identify an alternate release scenario. Chlorine is injected into the facility's water intake stream prior to clarification. The injection rate is controlled by a rotameter, a metering device with a calibrated glass tube through which the injection rate is measured. A break of this tube was judged as the alternate release scenario. It was estimated that about 14 pounds of chlorine would be released in 20 minutes. Plant operations personnel or emergency response personnel would secure the release. EPA's Offsite Consequence Analysis Guidance indicates that vapor concentrations would decrease to less than 0.0087 milligrams per liter of air beyond the b oundary of the Geismar site. Public receptors within the affected area include adjacent chemical manufacturing facilities and a railroad. Multiproducts Plant a) Anhydrous hydrogen fluoride Anhydrous hydrogen fluoride is pumped from intermediate storage as feed to the reactors. The transfer line has a flange connector at the discharge of the pump. The partial separation of this flange connector was chosen as the alternative release scenario. Multiple systems exist to mitigate a release due to separation of the feed pump discharge flange. First, this process is computer controlled. A loss of flow or pressure in the feed line would be quickly highlighted as a deviation by the process control system. Second, the area is actively monitored by operations, quality control and maintenance personnel. Many of these persons maintain radio communications and would immediately alert the control room of any abnormal condition. Thirdly, this particular process area is continuously monitored in the control room by closed circuit television. Once alerted, the control room can immediately secure operation of the pump should an incident occur. Systems exist to isolate the feed system to prevent further release. It is estimated that system deactivation would occur well within 1-2 minutes of occurrence. In addition, the facility is equipped with several remotely controlled water spray monitors. Hydrogen fluoride is readily absorbed in water. The water mitigation system can be controlled from within the control room or from a second remote control station. The control room is equipped as a safe haven for continued occupancy during a release. Two of the system's six monitors are capable of being directed onto the anticipated release point. The other monitors can be used to create a dense water curtain to mitigate any vapor release. It is estimated that with rapid shutdown of the pump, less than 700 pounds of hydrogen fluoride would be released. Prompt activation of th e water spray mitigation system would greatly reduce the impact of the release. EPA's Offsite Consequence Analysis Guidance indicates that vapor concentrations would decrease to less than 0.016 milligrams per liter of air beyond the boundary of the Geismar site. Public receptors within the affected area include adjacent chemical manufacturing facilities, a railroad and a state highway. b) Chlorine An evaluation of the Multiproducts Plant's use and handling of chlorine was conducted to identify an alternate release scenario. Chlorine is injected into the plant's cooling towers. The injection rate is controlled by a rotameter, a metering device with a calibrated glass tube through which the injection rate is measured. A break of this tube was judged as the alternate release scenario. It was estimated that about 5 pounds of chlorine would be released in 10 minutes. Plant operations personnel or emergency response personnel would secure the release. EPA's Offsite Consequence Ana lysis Guidance indicates that vapor concentrations would decrease to less than 0.0087 milligrams per liter of air beyond the boundary of the Geismar site. Public receptors within the affected area include adjacent chemical manufacturing facilities and a railroad. Aclon Resin Plant Trifluorochloroethylene A release of trifluorochloroethylene from an instrument attachment pipe was modeled as a flashing flammable liquid. A water spray mitigation system would be used to reduce the impact area. The predicted endpoint for the release of 2,725 pounds of material in 10 minutes fell within the boundaries of the plant property. No offsite receptors were impacted. 5. The general accidental release prevention program and chemical specific prevention steps for the Honeywell Geismar site: The general accidental release prevention program at the Honeywell Geismar Site for the affected stationary sources includes the following elements: a) established process safety management system f or oversight and control of the manufacturing processes, b) process design review to minimize hazard potentials, c) computer controlled processes with sophisticated interlock and shutdown protocols, d) development and implementation of accurate procedures for safe operation and maintenance of the process, e) documented process safety information describing operating limits, control points and consequences of deviations, f) a system to review and manage changes to the processes and process safety information, g) an on-going mechanical integrity program that ensures critical process equipment is designed, constructed, and installed in accordance to codes and standards, h) formalized, documented inspection protocols integrated with preventive and predictive maintenance programs such as vessel thickness testing and non destructive testing to ensure the reliability of equipment, i) performance of process hazards analyses with prompt resolution of any recommendations, j) use of safety shutdo wn, relief and vent systems, interlocks, dikes and other secondary containment installations, control instrumentation, and process monitoring for early warning and detection, k) performance of incidence investigations to establish root causes and identify corrective actions, l) process safety compliance audits, m) safety reviews of new or modified processes prior to activation, n) involvement of employees in development of operating procedures, process audits, incident investigations, o) contractor qualification programs which evaluate long term contractor safety performance and work qualifications, p) contractor work requirements which include pre-service orientation of supervisors and employees, regular self-audits and incident investigation and correction, q) comprehensive general and process-specific training programs for process operators and maintenance personnel, and r) Provision of safe havens for critical control functions to allow for orderly shutdown of processes should an incident occur. Chemical specific prevention steps include: a) designing the process technology and process equipment based on a thorough understanding of the hazardous properties of all hazardous chemicals, b) developing an understanding among the operators for the hazardous properties of all hazardous chemicals, the process chemistry and safe operational process limits such as temperatures, pressures, and flows, c) understanding the consequences of unsafe chemical handling, process deviations and inadvertent mixing of incompatible chemicals, d) continuous review of process, response and mitigation technologies, e) designing and installing active and passive mitigation facilities such as vapor absorbing water spray systems, rapid inventory transfer systems, liquid containment dikes and closed circuit monitoring systems f) clear labeling of all vessels and containers to ensure contents are known, g) having knowledge of the requirements, capabilities and limitations of both pers onal protective and emergency response equipment and maintaining easily accessible inventories of each hazardous chemical, and h) maintaining a response team trained to a high level of readiness. 6. The Geismar site's five year accident history: A review of the facility's incident records for significant events involving chemicals covered by the RMP rule was conducted. Consideration was given to the amount of material released, injuries which may have occurred, and actual or potential impact both on and off the facility. Two incidents involving an affected chemical occurred at the Honeywell Geismar Site in the past five years. 1. In 1994, during reactivation of the site's refrigerants manufacturing process, a small amount of hydrogen fluoride was released from an instrument flange on a process vessel. One employee was injured. Operations personnel immediately activated the plant's water spray mitigation system and directed the sprays to absorb and disperse the vapors. The empl oyee fully recovered. No offsite impact was observed. A thorough incident investigation was conducted. Changes in maintenance and reactivation procedures were made to prevent recurrence. 2. In 1999, maintenance was being performed on a heat exchanger in the hydrogen fluoride process. The heat exchanger is normally under vacuum. A minor process upset occurred which created a slight positive pressure causing a small amount of vapor to escape. A worker received a minor chemical burn as he exited the area. The worker was wearing personal protective equipment which limited his exposure. The impact of this release was limited to the process structure. No offsite impact occurred. The worker was treated and released and returned to work. A thorough incident investigation was conducted. Changes in operation and maintenance procedures were made to prevent recurrence. 7. The emergency response program: The Honeywell Geismar site has an emergency preparedness planning and respon se program designed to deal with accidental releases and other unplanned events associated with the facility's use of hazardous chemicals. The site has a written Emergency Response Plan that addresses various types of contingencies including specific actions for responding to accidental releases. The Plan provides for both internal site and external community emergency alerting and notification using established protocols. The plant has multiple means of communication established to alert public safety agencies. The plan addresses emergency health care, sheltering in place, evacuation, emergency responsibilities, response, control procedures, and emergency equipment. The Plan provides for the implementation of an Incident Command System to direct and coordinate the Site's response activities. The Plan has been coordinated with the local emergency planning committee and with the local sheriff's agencies that would direct all offsite community response activities. The Honeywell Ge ismar site maintains its own professionally trained Emergency Response Team (ERT) which is knowledgeable and prepared to respond to incidents involving accidental releases. The ERT holds annual site emergency response drills and other exercises that have been conducted jointly with the local public safety response groups. The Geismar site utilizes audible warning systems for both onsite and offsite notification. The onsite notification system can be activated at several locations including control rooms and the plant security gate. This system has siren and voice capability that can use prerecorded or live announcements. The system is tested weekly and during routine drills by Honeywell and other companies which share the site. Notification of persons off the site property is accomplished in conjunction with the local public safety agencies by activation of a regional audible warning system. This system also has siren and voice capabilities. Annually, calendars are hand deliver ed to residents in the audible warning region. These calendars provide residents instructions and recommendations in response to audible warnings. The system is tested weekly. In addition to the audible warning system, community alert networks exist to alert near neighbors. These computer-assisted systems are capable of automatically alerting residents, industries, businesses, and others in the covered area by telephone. 8. Planned changes to improve safety: AlliedSignal, Inc. pursues a philosophy of continuous improvement in all aspects of its operations. Improvements are identified and implemented throughout the facility's planning and operating cycles. The plant's systematic safety review program identifies action items that improve upon the existing safeguards at the Geismar site and further reduce the potential for accidental release. The process hazard analyses for the Geismar manufacturing processes are reviewed and revalidated every five years. Continuous improvement o f the plant's processes and systems provides the highest level of protection from chemical incidents. Hydrogen Fluoride Plant The Geismar Plant recently completed the replacement of the manually controlled water spray mitigation system in the hydrogen fluoride plant with an upgraded, remotely controlled system similar to the system in the Multiproducts Plant. A process hazard analysis of the Honeywell Geismar Site's Hydrogen Fluoride Manufacturing Plant was completed in late 1989. Recertification was completed in 1995. The next recertification of this analysis may identify additional improvements. Multiproducts Plant A process hazard analysis of the Honeywell Geismar Site's Refrigerants Manufacturing Plant was completed in 1994 and was recertified in 1999. Aclon Resin Plant A process hazard analysis of the Honeywell Geismar Site's Aclon Resin Plant was conducted in association with process design in 1999. |