Honeywell Farmers Valley Plant - Executive Summary |
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RMP*Submit: Executive Summary Honeywell Farmers Valley Plant The Honeywell International Inc. "Honeywell" Farmers Valley plant is a manufacturing facility located in Farmers Valley, Pennsylvania. It is part of the Specialty Wax and Additives Business Unit of Honeywell. 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 home and industrial control systems. With 2000 sales of approximately $25 billion, the company ranks among the top 100 of the Fortune 500. Honeywell has approximately 120,000 employees at more than 350 facilities in 40 countries. Honeywell operates thirteen major businesses: Home and Building Control, Industrial Control, Aircraft Landing Systems, Aerospace Engines, Aerospace Electronic Systems, Aerospace Services, Federal Manufacturing and Technologies, Polymers, Specialty Chemicals, Electronic Materia ls, Consumer Products Group, Transportation and Power Systems and Friction Materials. More information about Honeywell may be found at its Web Page: www.Honeywell.com. It is the worldwide policy of Honeywell to design, manufacture and distribute its products and to handle and dispose of materials throughout their life cycle. Honeywell does this 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 Farmers Valley Plant 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 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. The following seven elements describe policies, activities and information at the Honeywell Farmers Valley Plant, which are consistent with and support the requirements of the RMP rule. 1. Accidental release prevention and emergency response policies It is the policy of the Honeywell Farmers Valley Plant to operate a safe and environmentally sound facility by identifying and controlling health, safety, and environmental risks related to its operations; by designing its processes to protect people, property and the environment; by conducting and continually reviewing and improving programs for safety, health and environmental excellence; and by establishing processes to assure that all laws and regulatio ns applicable to its operations and products are known and observed. The Honeywell Farmers Valley Plant is committed to assuring that accidental release prevention is integrated into the design and operation of processes affected by the RMP rule. This is accomplished by checking materials compatibility requirements, proper sizing and selection of equipment, providing procedures for monitoring key process conditions, employee training, conducting equipment inspections and preventive maintenance, maintaining communications systems, and observing site security and safety rules. The Honeywell Farmers Valley Plant maintains a professionally trained Emergency Response Team, and emergency response equipment and supplies. The Emergency Response Team meets regularly to review emergency response procedures and conduct drills. The supplies of emergency response equipment are inspected regularly by designated employees to assure availability and adequacy. 2. Stationary source description and regulated substances handled The Honeywell Farmers Valley Plant processes fully refined paraffin and micro crystalline waxes from various petroleum distillate feed stocks. Feed stocks are shipped into the facility via tank trucks and rail cars. Finished products are shipped from the site via the same method. The plant has approximately 133 employees and operates 24 hours per day. There are two chemicals at the Farmers Valley plant that are subject to the RMP regulation: anhydrous ammonia and propane. Anhydrous ammonia is a colorless gas with a strong pungent odor. The ammonia is used as a refrigerant to cool the charge stock to the Deoiling Unit. The normal maximum inventory of ammonia is 19,000 pounds. Propane is also a colorless gas at atmospheric temperature and pressure, it is a flammable chemical with a vapor density of 1.52 (air = 1). The propane is used as a solvent to remove heavy resin from vacuum tower bottoms. The maximum intended inventory of propane is 183,845 pounds. 3. Worst case scenarios and alternative release scenarios EPA's Risk Management Program requires the Farmers Valley plant to prepare an analysis of a hypothetical worst case release of each chemical 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 the worst possible weather conditions. For a number of reasons discussed in this submittal, it is extremely unlikely that this event would ever occur. The Farmers Valley plant is also required to analyze the impact of alternative accidental release scenarios. At the Honeywell Farmers Valley Plant the two chemicals which are currently subject to the RMP rule are anhydrous ammonia and propane. Ammonia is classified as a toxic chemical under the RMP rule and propane is classified as a flammable. Worst Case Scenarios a)The worst case scenario for ammonia involves the failure of an ammonia storage tank containing 6,000 pounds of anhydrous ammonia, assuming the vessel is filled to its capacity. The anhydrous ammonia is released as a gas to the atmosphere. The plant is located in a lightly populated area and the cloud formed by the escaping ammonia would reach offsite endpoints and nearby public receptors. b)The worst case scenario for propane involves the failure of a propane storage tank containing 92,500 pounds of propane, assuming the vessel is filled to its capacity. The entire contents of the propane tank are assumed to be released instantaneously as a vapor and be detonated, thereby giving rise to a pressure wave. Again, this scenario would affect a lightly populated area. Alternative Release Scenarios a)The alternative release scenario considered for anhydrous ammonia would involve the failure of a transfer hose being used to offload a tank truck of amm onia. The excess flow valve on the truck would automatically close and limit the amount of ammonia released. This release of ammonia would have an offsite impact. b)The alternative release scenario considered for propane involves a release of propane through a split in a transfer hose connected to a tank truck. The release is in the form of a two-phase jet of vapor and liquid aerosol that is assumed to remain airborne. The flammable mass within the jet is assumed to detonate, thereby giving rise to a pressure wave. 4. General accidental release prevention program and chemical-specific prevention steps The general, accidental release prevention program at the Honeywell Farmers Valley plant consists of 12 elements. Each of these elements is described below. 4a. Process Safety Information Written process safety information is compiled before conducting process hazard analyses for processes using ammonia and propane. This enables the employees involved in operating these processe s to identify and understand the potential hazards associated with the processes. The information compiled includes data on the safe use and handling of ammonia and propane (e.g., Material Safety Data Sheets), data on the process technology (e.g., Process Flow Diagrams, process chemistry, flow rates and storage capacities, operating limits and evaluation of exceedances), and data on the equipment used in the process (e.g., Piping & Instrument Diagrams, materials compatibility, energy ratings and classification, control devices and emergency systems, ventilation systems, design basis including conformance to applicable codes and standards). The process safety information is adequate to show compliance of the process design with generally accepted good engineering practices. 4b. Process Hazard Analyses Process hazard analyses for the processes involving ammonia and propane have been completed in accordance with 29 CFR 1910.119(e) (OSHA Process Safety Management). These process hazar d analyses are updated and revalidated in accordance with 29 CFR 1910.119(e), and are retained on site for the life of the processes. In general, one or more of the following methodologies are used to complete each process hazard analysis: (a) what-if evaluation; (b) checklist; (c) hazard and operability study (HAZOP); (d) failure mode and effects analysis (FMEA); (e) fault tree; (f) process mapping, and; (g) cause and effect matrix. Each process hazard analysis addresses the process hazards, process incident history, process control devices and detection systems, evaluation of failure of process control devices, equipment location, and human factors. Each process hazard analysis is performed by a team of employees having experience and knowledge of the process design and operation, and knowledge of how to complete a process hazard analysis. The Management of Change process (described below) is used to track and document process changes, which occur as a result of recommendations f rom process hazard analyses. 4c. Operating Procedures Written operating procedures are prepared for each of the processes involving ammonia and propane. The operating procedures provide clear instructions for safely conducting activities in the plant. The procedures are updated to reflect current operating practices, and are certified annually for accuracy. Specific information and instructions covered by the operating procedures include startup, normal operation, emergency operation, shutdown, operating limits, operating controls, chemical-specific health and safety information, required personal protective equipment, and use of safety systems. Written procedures are also provided for specific operations such as hot work, lock-out/tag-out, confined space entry and line breaking. 4d. Training Employees currently engaged in operating processes involving ammonia and propane have received training to ensure they have the required knowledge, skills, and abilities to safely carry ou t the requirements specified in the written operating procedures. Refresher training is provided every three years at a minimum, or sooner if warranted by changes to operating conditions, equipment or procedures. If refresher training is required more frequently than every three years, it would be triggered through the Management of Change process (described below). Training records are maintained for each employee to show the date training was conducted, the material covered by the training, and the means used to verify that the training was understood. 4e. Mechanical Integrity The Honeywell Farmers Valley Plant maintains the mechanical integrity of equipment used to process and handle ammonia and propane. Such equipment includes pressurized vessels, storage tanks, piping systems, pressure relief and vent systems, emergency control devices, pumps, and valves. Written procedures are established to define the scope and requirements of the mechanical integrity program. Maintenance employees engaged in carrying out the mechanical integrity program are trained to complete the required tasks in a safe manner. One component of the mechanical integrity program includes inspection and testing of covered equipment. Equipment inspection and testing is conducted in accordance with manufacturer's recommendations and generally accepted good engineering practices. Records of inspections and testing are maintained to show the date, equipment identification, inspector, type of test or inspection performed, and test results or observations. If deficiencies are noted during equipment inspection and testing, corrective actions are taken in a timely manner to assure safe operation of the process. In some cases, equipment inspections are driven by permit requirements as well as the mechanical integrity program. 4f. Management of Change A Management of Change order is required when there is a change (except for replacement in kind) to equipment, process chemicals, technolo gy, procedures, or a change to the facility that will affect a covered process that handles ammonia or propane. Work orders for such changes pass through the Safety Department and Engineering to assure that proper materials of construction and good engineering practices are employed. Engineering will make changes to the P & IDs to keep the process safety information up to date. Process and maintenance personnel are trained prior to start up of a modified process. 4g. Pre-startup Review Prior to startup of a new or newly modified process involving ammonia or propane, a pre-startup safety review is conducted. The review is to ensure that the equipment and installation meets design specifications, a process hazard analysis has been completed, employee training has been completed, and safety, operating, maintenance, and emergency procedures are in place. 4h. Compliance Audits Self-assessed compliance audits for processes involving ammonia and propane are conducted every three years a t a minimum to ensure that the elements of the general accidental release prevention program are up to date and are being implemented. The compliance audits are conducted by a team of employees having experience and knowledge of the covered processes, and knowledge of the program requirements. Records of the compliance audit reports are maintained to document the results of the audits and corrective actions taken, if necessary. 4i. Incident Investigation All incidents, which resulted in, or could have resulted in, a release of ammonia or propane are investigated promptly. The incident investigation starts with the completion of an Incident Investigation Report prepared by the supervisor on duty at the time of the incident, and is distributed to the incident investigation team. The incident investigation team is made up of employees having experience and knowledge of the processes affected by the incident, and knowledge of completing incident investigations. Following the inciden t investigation, a report is prepared to include the following information: (a) date, time, and location of the incident; (b) employees involved in the incident, and their roles; (c) date of the incident investigation; (d) names of employees on the incident investigation team; (e) description of the incident, including a chronology of events; (f) root causes and contributing causes, including conditions at the time of the incident, and; (g) recommendations to prevent a recurrence. Follow-up actions, which are taken as a result of the recommendations in the incident investigation report, are documented, and records of the reports and follow-up actions are maintained for a minimum of 5 years for future reference. 4j. Employee Participation All employees at the Honeywell Farmers Valley Plant have opportunities to access and participate in the sharing of information related to process safety for the processes involving ammonia and propane. Employees in the maintenance and operating are as attend monthly safety meetings to review incidents, learn about new or modified processes, and discuss specific safety awareness topics. Employees routinely have opportunities to participate in other safety processes under the prevention program such as process hazard analyses, management of change, employee training and incident investigations. 4k. Hot Work Permits The Honeywell Farmers Valley plant has an established "Hot Work" permit program. Under the program, a "Hot Work" permit must be issued prior to commencing hot work operations in the ammonia and propane units. Hot work operations may include burning, welding, drilling, grinding, torch cutting or other spark producing activity. The "Hot Work" permit indicates the type and method of hot work to be conducted, the equipment the hot work will be performed on, the date, time, and location authorized for the hot work, the presence of fire prevention and protection systems meeting the requirements of 29 CFR 1910.252(a), and sig natures of the supervisory employees authorizing the hot work. A separate "Hot Work" permit must be issued for each hot work operation, and a separate "Hot Work" permit must be issued for each day. A copy of the "Hot Work" permit must be displayed at the job location while hot work is in progress, and the permit is maintained on file after the completion of the hot work. 4l. Contractors Prior to retaining contractor services for work in ammonia and propane units at the Honeywell Farmers Valley plant, the contractor's safety program and performance are evaluated. This evaluation includes a 3-year review of the contractor's Total Case Incident Rate (TCIR), review of OSHA recordable injuries and illnesses, review of Lost Work Day Cases Away (LWDCA), corrective actions, safety policies, training, medical monitoring, and review of any applicable site-specific health and safety plan (HASP) prepared by the contractor. The information supplied by the contractor is retained on site while the contractor is engaged in work activities. Prior to commencing work on site, each contractor employee receives a safety orientation provided by Honeywell. The safety orientation covers information on the hazards associated with the process areas where the work will be performed, safety procedures and systems to be used, overview of the site emergency response program including specific procedures to be followed in case of emergency, and a review of site safety rules and applicable operating procedures. A record of each contractor employee's sign-off on the safety orientation is maintained on file at the site, including the date the training was completed. Once the safety orientation is complete, the contractor is responsible to ensure that each contractor employee performs the assigned work in a manner consistent with the information provided during the safety orientation. If the contractor assigns new employees to the job after work has commenced, the contractor must also en sure that each new employee receives a safety orientation prior to starting work on site. Failure of the contractor or any contractor employee to abide by these requirements is grounds for immediate dismissal from the site. 5. Five-year accident history In the past 5 years, there have been no accidental releases of ammonia or propane from the Honeywell Farmers Valley Plant, which meet the reporting requirements described in the RMP rule. 6. Emergency response program The Honeywell Farmers Valley Plant has an emergency response program for the purpose of protecting public health and the environment. The program includes a written Emergency Response Plan, employee training in emergency response procedures, procedures to review and update the plan, and procedures for the use, inspection, testing, and maintenance of emergency response equipment. The Emergency Response Plan includes procedures for emergency response after an accidental release of ammonia or propane at the plant. The Emergency Response Plan also includes procedures for administering first aid and emergency medical care as required in case of exposure following a release. The Emergency Response Plan includes notification procedures for informing the public and outside agencies in case an accidental release occurs. Outside agencies such as fire departments, local emergency planning committees and state environmental agencies are notified according to regulatory reporting requirements at a minimum, and as necessary to provide or assist with emergency response. The Emergency Response Plan is coordinated with the local emergency planning committees, and information in the plan is readily available to the local emergency response officials for the purpose of developing and implementing the community emergency response plans. Offsite community response activities are implemented in accordance with the community emergency response plans as developed by the local emergency planning committees. Repre sentatives from the Honeywell Farmers Valley Plant meet regularly with the local emergency planning committees to review procedures, training requirements, equipment needs, and to conduct emergency response exercises. The facility Emergency Response Plan has been communicated to the Local Emergency Planning Committee and approved by the membership. A full-scale drill was conducted on April 20, 1995, at the facility utilizing all personnel, local fire departments, county emergency medical, and state and local police departments. The drill was critiqued by Butler Community College. In 1998 personnel from the Farmers Valley Safety Department took part in a similar drill at the ARG Refinery in Bradford, PA. Emergency Response Procedure: In the event of a chemical release: The Facility Emergency Coordinator or his representative will contact the McKean County Emergency Management by telephone (814-887-5070). This notification will constitute notification of the LEPC. McKean County EMA re sponsibilities: Will immediately notify in order: a. McKean County EMA Director (Ken Mostyn W 887-5070 or H 225-3458) b. Smethport Fire Dept. c. McKean County Commissioners d. Smethport Ambulance Service e. N/A County EMA (Surrounding County EMA, if applicable) f. PA State Police g. Port Allegany Fire Dept. (Mutual aid) h. PEMA Facility Emergency Coordinator responsibilities: Upon determining that an emergency situation exists at the facility he shall: a. Issue initial report to LEPC through the McKean County EMA b. Provide additional information as available to LEPC c. Complete any other notifications required d. Meet emergency response units at the staging area and assist in establishing Command Post. e. Provide additional information or recommendations to Emergency Response Agencies Emergency Management Agency responsibilities: The actions taken by EMA will depend largely on the scope of the situation. The EMA Director will: a. Determine situation (Communicate with FEC) b. Activate EAS as warranted c. Activate EOC as warranted d. Appoint On-Scene Coordinator e. Warn hospitals, if necessary f. Activate Mass Care Centers, as needed g. Notify County Commissioners, PEMA, Keating Township Supervisors, Keating Township EMC, Eldred Township Supervisors & EMC, DEP & PA Fish Commission Smethport Ambulance Service responsibilities: a. Immediate response to the staging area b. Coordinate with on-scene EMA Officers, fire department officers, OSC and participate in establishment of Post and have a designee remain and coordinate communications and activities c. Coordinate with medical command physicians and hospital officials and notify receiving hospitals of situation d. Assist with establishment of Decontamination Zone e. Once patient contact can be made, a triage area will be established and victims treated accordingly f. Coordinate with hospital(s) the transportation of sick and injured Pennsylvania State Police responsibilities: Wil l perform all police functions as required, with assistance of surrounding municipal police departments and the McKean County Sheriff's Department. They shall: a. Control access to restricted areas b. Coordinate manning of designated access control points and traffic control points. TCPs are indicated in Attachment #1 of the facility Emergency Response Plan. c. Dispatch vehicles to alert residents Community Protective Actions: The decision to relocate, shelter-in-place, or evacuate residents is solely that of the county commissioners. Detailed procedures for these actions are contained in the McKean County EOC. Criteria to be reviewed for evacuation and/ or sheltering: a. Quantity of release b. Additional risk facilities c. Rate of the release d. Duration of release e. Chemical released f. Meteorological condition- wind direction and speed More details of the facility Emergency Response Plan can be accessed through the McKean County LEPC. 7. Planned changes to improv e safety The Deoiling Process Unit is currently being reinstrumented with the latest technology in computer operated controls. This improvement will provide the operators a much better means of monitoring the operation of critical equipment. All personnel are being trained to operate new equipment per the facility's Management of Change process. Safety and environmental audits are conducted by trained safety and environmental specialists. Audit reports with recommendations and action item lists, are reviewed by management staff on a regular basis. |