ISP ALGINATES, INC. - Executive Summary |
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RISK MANAGEMENT PLAN (RMP) EXECUTIVE SUMMARY-ISP ALGINATES SAN DIEGO PLANTIntroduction ISP Alginates San Diego Plant is a food ingredients manufacturing operation located on the harbor in the city of San Diego. Our products are derived from natural materials, and most are used to create desired textures in foods. Some of our products fulfill special pharmaceutical needs, and others impart valuable flow properties in industrial applications. We employ over 170 people in our San Diego operations. Our business has operated safely in San Diego for 70 years. Policies Our accidental release prevention policies are based on investment in state-of-the-art chemical handling systems, and operating by OSHA's Process Safety Management (PSM) program. The chemical handling systems, and our PSM program, are detailed later in this document. Our approach to emergency response is based on developing on-site expertise, to work in conjunction with community emergency service professionals. Our on- site Emergency Response Team (ERT) is comprised of volunteer employees with a wide variety of expertise from throughout the organization. The team is well-trained and equipped to perform initial on-site containment and remediation of chemical releases. Included in the team's training is detailed understanding of hazardous materials systems in our facility. The team works according to an incident command system like that used by Fire Departments and other emergency response agencies. The site has a 24-hour staffed emergency reporting telephone to assure rapid communication of any incident requiring immediate response by either the ERT, or outside agencies such as the Fire Department, or paramedics. The San Diego Fire Department is has good familiarity with our facility, and stands ready to back-up our ERT if ever needed. Although we have never had a chemical release incident with community impact, the Fire Department has the expertise and resources to assist the community with n otification, shelter-in-place, evacuation or other community protection methods appropriate for a given situation. Regulated Substances & Chemical Specific Prevention Steps Our operation has two chemical processes regulated by the RMP, one using chlorine and the other using propylene oxide. Chlorine is a toxic gas with a sharp, irritating odor, greenish-yellow in color. We handle chlorine in cylinders constructed of 1 1/4" thick steel plate. Each cylinder contains about 165 gallons of chlorine, or one-ton. Chlorine is used directly from the cylinders, with no other storage vessels. The key safety components of our chlorine installation are a containment building, a continuous air monitor, a scrubber and a vacuum piping system. Upon arrival at the plant the chlorine cylinders are unstrapped from the delivery truck and moved a short distance using a dedicated overhead hoist into an adjacent chlorine containment building. The containment building has a continuous air monit oring sensor and alarm. If one part per million chlorine is detected inside the containment building, an audio alarm and a flashing light outside the building indicates chlorine is present. If three parts per million chlorine is detected (a level safe for extended exposure), a building exhaust scrubber activates which captures the atmosphere of the containment building. The scrubber is charged with liquid capable of absorbing and converting the full contents of one chlorine cylinder to stable sodium hypochlorite (common bleach) solution. Chlorine is drawn into our manufacturing process through individual vacuum regulator valves mounted on each active cylinder. Chlorine can only flow through the vacuum regulator valves if the process piping is under vacuum. A vacuum eductor at each use point pulls chlorine through the piping. Any break or leak would cause the piping to lose vacuum, and the vacuum regulator valves would automatically shut off chlorine flow at the cylinders. Propylene oxide is a liquid solvent whose vapors are toxic if inhaled, though much less toxic than chlorine. Propylene oxide is delivered in sealed rail cars, and stored in two triple-contained underground storage tanks. Some of the key safety features of the propylene oxide system are rail cars with all valving on the top of the car, vapor return lines to capture propylene oxide vapor, nitrogen blankets in the headspace of all storage tanks, triple-contained, state-of-the-art storage tank design, and continuous storage tank leak detection. Propylene oxide is pumped from the top of the rail car to the underground storage tanks through welded steel piping that is inspected daily for leaks. Nitrogen headspace pressure in the storage tanks, and in the rail car provides an atmosphere that does not support combustion, and that delivers propylene oxide into the production process. Worst Case Scenario Modeling indicates that our worst case scenario release, as defined by the RMP reg ulations, would be the discharge of a one-ton cylinder of chlorine directly to the atmosphere, outside of our containment building, within a 10 minute period, during worst-case nighttime air conditions. This would be a release rate of 200 pounds per minute. In our operation, there is no known failure mechanism that could result in a release rate this high. According to EPA guidance, the downwind safe distance from this worst case scenario release is 1.3 miles. In our operation, the only time that chlorine cylinders are outside of the containment building is during biweekly delivery of chlorine cylinders to the site, which only occurs during daytime hours. The safe downwind distance for a worst case daytime release is 2000 feet. Alternate Scenarios The RMP regulations also require an analysis of alternate release scenarios. In 1995, we identified three release scenarios each for chlorine and propylene oxide for our California Risk Management and Prevention Program (RMPP). We bel ieve the largest of these release scenarios are the appropriate ones to use for the RMP alternate scenarios. For chlorine, the alternate scenario release is failure of a cylinder outlet valve within our containment building, coincident failure of the air monitoring instrumentation, and assuming one hour to manually start the scrubber. This scenario would result in a safe downwind distance of 427 feet, which would potentially affect our industrial neighbors only. For propylene oxide, the alternate scenario would be a spill of 200 gallons resulting from failure of a transfer hose during the unloading of a rail car. This scenario would result in a safe downwind distance of 712 feet, which would potentially affect our industrial neighbors only. General Accident Release Prevention Program In addition to the installed chemical handling systems described above, our chemical release prevention system employs the full range of practices required by OSHA Process Safety Management. Our plant has been operating under PSM for over five years, and the program is now well developed. Some highlights include: -A Process Hazard Analysis (PHA) is conducted every 5 years or more frequently. We use the Hazop (Hazard & Operability Study) method, because it is a very thorough and rigorous PHA system. This involves a team of experts who use a formal, defined system to review the hazards posed by the chemical, and consider best industry practices for handling the material. Recommendations for improvement are made and priorities set for implementing them. We recently updated our PHA for propylene oxide, and identified a number of improvements. Our last chlorine PHA was completed less than 4 years ago, and there have been very few chlorine system changes. We plan to update our chlorine PHA next year. -A thorough, documented mechanical integrity system provides preventive maintenance for all PSM chemical systems at the plant, including the chlorine and propylene oxide syst ems. This involves inspection and servicing of every portion of the PSM-covered systems on a regular schedule. -Written work instructions provide detailed procedures for employees operating the equipment. Included is a thorough Safety Procedures Manual, which was updated this year. Training is provided before employees are allowed to operate critical equipment without direct oversight. -A documented Management of Change system controls modifications to equipment and operating parameters. Each change is reviewed beforehand by appropriate personnel to determine if there is any impact to system safety. -The site uses a number of contract personnel for a variety of services. Our Contractor/Guest Safety Program requires that contractors be selected using their actual safety performance as a criteria. Training and open communication is maintained with contract employees to identify and control hazards. In addition, we maintain a number of adjunct systems and equipment for spec ific chemicals. Examples include: ? local and remote chlorine alarms to quickly respond to leaks, ? emergency chlorine cylinder repair kits, ? emergency response equipment including self-contained-breathing-apparatus, personal protective gear, and air monitoring equipment, for use by the Emergency Response Team ? foam systems for controlling evaporation rates of spilled propylene oxide, and extinguishing propylene oxide fires. Five Year Accident History The facility has never had a release of chlorine or propylene oxide that resulted in community injury or health impact in over 50 years of using these materials. Emergency Response Program All employees are trained to recognize potential emergency situations, and to call a 24-hour staffed emergency control center located in our Quality Control Lab. Depending on the nature of the emergency, the Fire Department, paramedics, or the on-site Emergency Response Team are activated. Key Emergency Response Team personnel are available by pager. Each Emergency Response Team member receives 24 hours of initial specialized training, 8 hours of First Aid and CPR training, and 8 hours of refresher training annually. Included are hands-on drills, and training about our site's specific hazardous material systems. The Team is well equipped with protective gear and specialized emergency response equipment. The first Emergency Response Team member to arrive on the scene assumes the role of incident commander. The Incident Commander assesses the scene, and develops a response plan. The proper gear and team members are assembled, and take action. If a more qualified responder arrives, like the Fire Department, the Incident Commander will relinquish command. Planned Safety Improvements The CalARP process has caused us to look more closely at our propylene oxide handling methods. We identified a beneficial improvement, now in design, of adding a spring-loaded fail-close valve directly on the rail car before the trans fer hose is installed. This would enable an operator to quickly and remotely shut-off propylene oxide flow in the event of a transfer hose leak. Another safety improvement arising from CalARP is an improved identification of potentially affected neighbors. The list of name and addresses of sensitive receptors required by CalARP will be a valuable tool for the Incident Commander in the event of an actual release. We also invited the San Diego City Fire Department's Hazmat Coordinator to review both our propylene oxide system and our chlorine system, and make recommendations. He recommended verifying the functionality of our foam system for controlling propylene oxide emissions. Indeed, a coordinated response drill involving foam applied to a simulated propylene oxide leak was performed by the Fire Department, and our Emergency Response Team on December 28, 1999. Regarding our chlorine system, he found no improvements needed, and commented that our installed release response capture system was better than anything the Fire Department could provide. |