Pueblo, CO Facility - Executive Summary |
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INTRODUCTION The BFGoodrich Aerospace Pueblo 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. 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 Pueblo 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 vehicles and equipment. The Pueblo School District 70 Technical Academy is located within the northwest portion of the BFGoodrich West Building. 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 the National Fire Protection Association (NFPA) 58 code, 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 2 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 of the flammable vapor in the cloud is assumed to participate in the explosion. Other assumptions include Atmospheric Stability Class F, an ambient temperature of 77? F, a wind speed of 1.5 meters per second, and 50% relative humidity. USEPA's 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 Propane Guidance requires the calculation of the area surrounding the release point that is subjected to an overpressure greater than or equal to the endpoint. The endpoint (EP) is defined as the distance an explosion from an accidental propane release will travel before dissipating to the point that serious injuries from short-term exposures will no longer occur. For propane, the EP is an overpressure of 1 pound per square inch (psi). An overpressure below 1 psi is 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 mile. The population within this area is estimated to be 9 people, using the 1990 Census data and the LandView III database and mapping software package. Of this population, 2 people are between the ages of 0 and 9, and one person is 65 years of age or older. The District 70 Technical Academy is also within the worst-case impact radius. Although this school is on the facility property, it is still considered to be a public receptor because it is used by non-employees. Andres Gallaraga Field, a public recreational area, is located just outside the boundary of the radius of impact. There are no 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 (1) the storage tank is designed and constructed in accordance with industry standards (i.e. ASME and NFPA 58 Codes); (2) the tank is equipped with two safety relief valves to prevent overpressurization and catastrophic release, (3) the perimeter of the facility is fenced and access to the site is controlled to prevent tampering; (4) the propane tank is protected from vehicle traffic within the facility by a guard rail; and (5) the external surface of the tank is visually inspected on a regular basis. An alternative release scenario is also required for the propane process, 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, facilit y or industry 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 tank is overfilled, and one of the 2-inch safety relief valves (set at 255 pounds per square inch gauge) lifts to relieve the excess pressure. The valve is assumed to have a flow capacity of 8,300 Standard Cubic Feet (Air) per Minute, and is assumed to remain open for 5 minutes. 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 0.13 mile. There are no residential populations within this distance, but the District 70 Technical Academy is within the radius of impact. There are no environmental receptors 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 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. ETHANE The facility maintains a fleet of three ethane trailers, two of which are on-site at any given time. Each trailer consists of eight storage vessels (maximum capacity 1,875 pounds of ethane). The third trailer is stored off-site, where it is filled by the ethane supplier. Upon notification by the facility, the third trailer is brought on-site and exchanged for an empty trailer. The maximum inventory of ethane is equal to the capacity of two full trailers (30,000 pounds of etha ne). For a worst-case release scenario, the facility must assume that the entire contents of one of the storage vessels (1,875 pounds) on an ethane trailer is released, a vapor cloud forms, and 10% of the cloud detonates. Other assumptions include Atmospheric Stability Class F, an ambient temperature of 77?F, and 50% relative humidity. The distance to the endpoint (EP) is defined as the distance an explosion from an accidental ethane release will travel before dissipating to the point that serious injuries from short-term exposures will no longer occur. For ethane, the EP is an overpressure of 1 psi. An overpressure below 1 psi is not likely to cause injuries that result from flying glass from shattered windows or falling debris from damaged structures. EPA's RMP*Comp (a computer software package) calculated the distance to the endpoint for a worst-case ethane release to be 0.1 mile. The population affected by a worst-case release scenario for ethane was estimated using information from the 1990 Census data and LandView III, and then modified after a drive-around survey of the facility and surrounding areas. LandView III calculates populations within defined impact areas using two methods: the Block Group Uniform Population Density Method and the Block Group Centroid Method. The first method tallies data for each Census Block that has any portion within the defined radius of impact. It then prorates the results based on the ratio of the portion of the Census Block that is actually inside the radius of impact. This method distributes the people in the Census Block evenly across the land area and counts only those assigned within the radius of impact. This method is useful when only small portions of the Census Block are located within the radius of impact. The second method, the Group Centroid Method, finds all Census Blocks that have their centers inside the defined radius of impact. The populations of these blocks are added together, regardless of whether the entire block is inside the radius of impact or not. This method is most useful with impact radii greater than 1 mile in densely settled areas. Because the worst-case impact area for an ethane release at the facility is relatively small, neither of these population estimation methods provide accurate results. The Group Centroid Method fails to provide any data because there are no centroids located within the radius of impact. The Block Group Uniform Population Density Method estimates one person within the worst-case impact radius. However, surveys of the surrounding area have shown that no residences are located within a 0.1 mile radius of the ethane trailers. The method is more useful for larger radii (e.g., those used for the propane release scenarios). Based on drive around surveys, it is appropriate to assign zero population within the ethane worst-case impact radius. Additionally, there are no public or environmental receptors located in the impact radius. The ethane proces s is eligible for Program 1 of the Risk Management Program Rule because: (1) there are no residences or other public receptors within the worst-case impact area for ethane, (2) the facility has had no accidental release history with respect to ethane, and (3) the facility has coordinated response activities with local emergency response agencies. FIVE-YEAR ACCIDENT HISTORY There have been no accidental releases of ethane at the facility in the last five years that have resulted in injury, death or significant property damage on site or off-site death, injury, evacuation, sheltering in place, property damage, or environmental damage. There have been no accidental releases of propane at the facility in the last five years that have resulted in death or significant property damage on site or off-site death, injury, evacuation, sheltering in place, property damage, or environmental damage. One minor on-site injury has occurred during the last five years involving a propane release. Th e incident took place on July 10, 1998 at approximately 1:00 pm when a contract employee performed an unauthorized procedure, resulting in a release of less than 30 pounds of propane through a furnace off-gas pipe. The release lasted for approximately five to six minutes during which time the propane ignited and caused minor injuries to the contract employee. The accident was brought to the attention of facility employees who stopped the release by shutting the control valve located between the furnace and the point in the off-gas line that had been cut. The contract employee suffered minor burns and received first-aid treatment at the facility, and was transported to an urgent care facility. Medical professionals at the urgent care facility applied salve to the burns, and did not require the contract employee to remain under medical observation. The employee suffered no permanent disability or disfigurement as a result of the propane release. The incident was reviewed immediately , and recommendations to prevent recurrence included additional training for all future contract employees and a meeting with the contractor company to stress the importance of following all BFG procedures, including lockout/tagout and contractor safety procedures. This type of incident has not recurred. The facility currently follows a formal incident investigation procedure and completes a report to capture any future events that might cause an accidental or unexpected release of propane. Additionally, the facility now implements a Contractor Safety Program, which allows BFGoodrich to select contractors who have the best safety records and are willing to provide written safety plans to ensure that their employees will comply with the facility's rules and regulations. All future contractor injuries and illnesses are to be recorded in a log, and will be reviewed at least annually to during a performance evaluation of the contractor. PREVENTION PROGRAM BFGoodrich has develop ed a Risk Management Program that includes all of the required Program 3 prevention elements for the propane system. Although a prevention program is not required for the ethane system due to its Program 1 status, the ethane system is subject to OSHA's Process Safety Management regulations, and BFGoodrich has developed similar prevention program elements to satisfy the PSM requirements for the ethane system. The key components of the prevention program developed for the propane process 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 system. -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 assume s that employees that utilize the propane system are the 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 system using the Hazard and Operability (HAZOP) study method. A team with expertise in engineering, operations, maintenance, and safety evaluated the existing propane system in June 1997, 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 siting; (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 recommendation s have been resolved. 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 system. 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 process. -Formal authorization systems (i.e., management of change procedure, pre-startup safety rev iew) are in place to ensure that system changes or expansions are as safe as the original design and that an independent 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 system are "pre-qualified" based on their knowledge of the system, 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 tank are used to detect any indication of potential failure that could lead to a release. -Utilization of safety systems, including pressure relief valves, manual shut-off valves, and safety interlocks. -Proper design, including adherence to recognized safety codes. -Adherence to fire codes, including National Fire Protection Association (NFPA) 58, and preparation for fires, storms, or events that could impact the propane system. -Planning in accordance with the Pueblo 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. Note that as of the date of resubmission (January 2000), the facility's first RMP compliance audit had not yet been co mpleted. The compliance audit is required every three years, which would correspond to June 2002 - three years from the date of the original submission (June 1999). The resubmission was required in anticipation of the removal of the judicial stay that precluded BF Goodrich from submitting the RMP propane information in June, 1999. EMERGENCY RESPONSE PROGRAM The BFGoodrich Pueblo Facility is subject to the following regulations which are related to emergency response: -OSHA's Emergency Action Plan Regulation - 29 CFR 1910.38(a) -OSHA's Process Safety Standard - 29 CFR 1910.119 -OSHA's HAZWOPER Regulation - 29 CFR 1910.120 The Pueblo Facility has consolidated these requirements into the Integrated Contingency Plan (ICP). The ICP allows the facility to effectively manage its emergency response-related efforts while eliminating redundancy and excessive documentation. Issues addressed in the facility's emergency response program include: ? Emergency escape procedures and emerg ency escape route assignments; ? Procedures to be followed by employees who remain to operate critical plant operations before they evacuate; ? Procedures to account for all employees after emergency evacuation has been completed; ? Rescue and medical duties for those employees who are to perform them and procedures/facilities for off-site emergency medical care; ? The preferred means of reporting fires and other emergencies; ? Names of persons or departments who can be contacted for further information or explanation of duties under the plan; ? Designation and training of a sufficient number of persons to assist in the safe and orderly evacuation of employees; ? The names of personnel: (1) responsible for maintenance of equipment and systems installed to prevent or control ignition, and (2) responsible for control of fuel source hazards; ? Regular and proper maintenance of systems installed on heat producing equipment to prevent accidental ignition of combustible materials; ? Procedures for handling releases of propane; ? Pre-emergency planning and coordination with outside parties (e.g., fire department, police department, hospital); ? Emergency recognition and prevention; ? Decontamination; ? Emergency medical treatment and first aid; ? Emergency alerting and response procedures; and ? Personal Protective Equipment (PPE) and emergency equipment. |