Indspec Chemical Corporation - Executive Summary |
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The INDSPEC Chemical Corporation (INDSPEC) Petrolia, Pennsylvania facility, is the world's largest and North America's only commercial producer of Resorcinol. Resorcinol is used primarily as a bonding and stiffening agent in the manufacture of tires. Other major uses are in high-performance wood adhesives and fire-retardent plastic additives. Our 330-employee workforce is comprised of production, maintenance, technical, clerical, and management personnel. Many of our employees have been with us for 25 years. We are proud of our facility and the stability of our workforce. The Federal Accidental Release Prevention Requirements under the Clean Air Act Section 112(r), codified in 40 CFR Part 68, were written to help prevent the accidental release of extremely hazardous substances and to minimize the consequences of any such release. All facilities with threshold quantities (TQs) of the listed regulated acutely toxic and flammable substances are subject to these provisions. The listed substances include 77 toxic chemicals with TQs ranging from 500 lbs. to 20,000 lbs., while the 63 flammable substances all have a TQ of 10,000 lbs. INDSPEC has three chemicals that meet the toxic and flammable substances TQs, and thus, these substances must be included in a Risk Management Program for their respective operations. The chemicals are oleum, ethyl ether, and formaldehyde . The TQ for oleum and ethyl ether is 10,000 lbs, while the TQ for formaldehyde is 15,000 lbs. Oleum is a fuming sulfuric acid, made up of sulfur trioxide and sulfuric acid. Oleum has a very fuming, cloudy and oily appearance. Oleum can be used as a chemical intermediate in the production of vegetable, marine and petroleum oils, dyes, and in detergents and lubricants. Oleum is used in a variety of industries that include: metal and metalworking, mining, petroleum refining and distribution, pulp and paper, textiles, and waste disposal. Ethyl ether is a colorless liquid with a pungent, sweetish odor . Ethyl ether is principally used as a solvent, as a starting material for the manufacture of chemical products, and as an anesthetic. Formaldehyde is a colorless liquid with a pungent odor. Formaldehyde is primarily used in the production of resins to create adhesives in the manufacture of particle board and plywood, and for molding, paper treating and coating, textile treating, and foams for insulation. Formaldehyde is used in the field of medicine as an embalming fluid for the preservation of tissues, a skin disinfectant, in cough drops and in mouthwashes. Formaldehyde also has many other uses in various industries that include: an insecticide and fungicide in agriculture, a stabilizer in gasoline, and a corrosion inhibitor in the metal industry. The major Clean Air Act Section 112(r) requirements with which INDSPEC must comply for use of oleum, ethyl ether and formaldehyde include: - Management System development and documentation, - Hazard Assessment for each af fected process, - Prevention Program completion, - Emergency Response Program coordination, and - Risk Management Plan submittal. In addition, INDSPEC recognizes its responsibility under Section 112(r)(1) (the "general duty clause") to handle all Extremely Hazardous Substances safely to prevent their accidental release and to minimize the consequences of any such release. Additional chemicals on site, not meeting their TQ or not identified in the 112(r) list rule, are managed using approprite risk-management principles similiar to those applied to our chemicals fully covered by 112(r). INDSPEC follows a prevention program including the use of process safety information, operating procedures, employee training, mechanical integrity, management of change, pre-startup review, incident investigation, compliance audits, "hot work" by permit only, and evaluation of contractors. This Executive Summary to INDSPEC's Risk Management Plan (RMP) provides an overview of how we are effectively meeting our responsibilities to the community through compliance with the 112(r) rule. MANAGEMENT SYSTEM INDSPEC has established a management system to oversee the implementation of its Risk Management Program responsibilities. The management system is designed to help ensure that each element of our program is fully and effectively completed. A qualified individual has been assigned overall responsibility for the development, implementation, and integration of the program elements. In addition, we have engaged SE Technologies, Inc. (SET) as an expert consultant to prepare and help us implement our program. Responsibility for implementing individual requirements of INDSPEC's program have also been delegated to competent individuals. An organization chart has been prepared to identify the responsible personnel and lines of authority for implementing the program. Record-keeping responsibilities are also included in the management system. HAZARD ASSESSMENT The Hazard Assessment portion of the 112(r) rule requires facility owners or operators to prepare "worst-case" and "alternative" release scenarios as appropriate to the operations. From the release scenarios, facilities are then to determine offsite impacts using specified offsite consequence analysis (OCA) parameters for worst-case releases and more realistic parameters for alternative releases. As described by the U.S. Environmental Protection Agency (USEPA) the worst-case scenario involves the release of the largest quantity of a listed toxic substance that is estimated to generate the greatest distance in any direction to a toxic endpoint defined in the 112(r) regulation. The probability that a worst-case release might occur or the possible causes of such a release are not considered. Also, the alternative scenario involves an accidental release that is "more likely" to occur than the worst-case release scenario. Scenarios to consider include transfer hose splits or uncoupling, p rocess piping failures, process vessel or pump cracks and failures, vessel overfilling and spill or overpressurization and venting through relief valves or rupture disks, and shipping container mishandling and breakage or puncturing leading to a spill. INDSPEC prepared worst-case release scenario analyses and alternative release scenario analyses for oleum, ethyl ether, and formaldehyde, based on requirements given in the 112(r) rule. Worst-Case Release Scenarios: - For oleum, we assumed a rupture of a single railcar and subsequent release of 180,000 pounds. The release forms an evaporating pool, a portion of which is contained within the oleum spill containment system. - For ethyl ether, we assumed a rupture of both tanks and subsequent release of 164,688 pounds. The release forms a pool that results in a vapor cloud explosion. - For formaldehyde, we assumed a rupture of a single tank and subsequent release of 184,500 pounds in 10 minutes into a containment dike. The release forms an evaporating pool that is contained entirely within the dike. Note that we evaluated the potential impact from the complete loss of oleum from a single 90 ton railcar rather than the largest process tank located inside the Acid House building. Under Section 68.25(h), the Risk Management Program rule requires that in selecting a worst-case scenario, a scenario that includes: "(1) Smaller quantities handled at higher process temperature or pressure; and (2) Proximity to the boundary of the stationary source" should be considered "if such a scenario would result in a greater distance to an endpoint defined in [the rule]." Complete loss of oleum within the Acid House building would result in a distance to the toxic endpoint of less than 6 miles (9.2 km) and a complete loss of a railcar would result in a distance of over 25 miles (40 km). Therefore, the catastrophic release of oleum from a 90-ton railcar should be cons idered the "worst-case" scenario. Sulfur trioxide, a component of oleum, reacts with any water it contacts to produce sulfuric acid and heat. We anticipate this interaction would tend to decrease the distance to the toxic endpoint (for sulfur trioxiode) given in our offsite consequence analysis. Sulfuric acid is not identified as a regulated acutely toxic or flammable substance under the 112(r) rule. Oleum was assumed to remain at 40 degrees Celsius during the duration of a release. Alternative Release Scenarios: - For oleum, we assumed a railcar line disconnect and a subsequent liquid release of 19,920 pounds in 3 minutes. The release forms an evaporating pool, all of which is contained within the oleum spill containment system. The total evaporation period is 10 minutes, which takes into account the drainage capacity of the oleum spill containment system and the migration of residual liquid from the surface of the containment into the drain. - For ethyl ether, we assumed a gasket failure in a 3 inch recirculation line and a subsequent release of 6,000 pounds. The release forms a pool that results in a vapor cloud explosion. - For formaldehyde, we assumed a gasket failure in a 2 inch recirculation line and a subsequent release of 1,500 pounds in 5 minutes. The release forms an evaporating pool. The OCA of each chemical release was analyzed separately by SET using appropriate air dispersion analysis and modeling techniques. Air dispersion modeling is the use of a computer to simulate the spread of air pollutants. Dispersion modeling can be used to determine the movemnt and concentration of toxic and flammable gases emitted from an accidental release. Note that in both cases "worst-case" weather conditions were used to simulate poor dispersion of the chemicals, even though the 112(r) rule allows the use of more favorable dispersion conditions, such as increased wind speeds and a greater dilution factor, for the Alternative Release Scenario analysis. The topography surrounding the INDSPEC operations will frequently contribute to poor dispersion conditions, especially at night and through early morning. Therefore, use of "worst-case" meteorology is prudent. To determine the OCAs of worst-case and alternative releases of oleum, ethyl ether, and formaldehyde, INDSPEC used the most-recent version of several air dispersion models and modeling techniques, as follows: - RMP*Comp is based on the U.S. Environmental Protection Agency's (EPA's) RMP Offsite Consequence Analysis Guidance (May 1996), as updated. RMP*Comp provides rough estimates of offsite impacts from evaporating pools of chemicals and vapor clouds. - ALOHA (Areal Locations of Hazardous Atmospheres) dispersion model, developed by the National Oceanic and Atmospheric Administration and the EPA, incorporates specific chemical release characteristics that pr ovide somewhat more refined estimates of offsite impacts from gaseous releases and evaporating pools of chemicals. ALOHA is part of the CAMEO (Computer-Aided Management of Emergency Operations) system used by many emergency response teams. - SLAB, developed by the Lawrence Livermore National Laboratory, is an EPA-recommended dense- gas model that provides more refined estimates of offsite impacts from heavier-than-air chemical releases. - SCREEN3, by U.S. EPA, is recommended for "neutrally buoyant" gases. This model is contained within the TSCREEN air-toxics screening model, which is recommended by U.S. EPA for 112(r) modeling. - ARCHIE, (Automated Resource for Chemical Hazard Incident Evaluation) flammable-gas model (prepared for the Federal Emergency Management Agency, U.S. Department of Transportation, and U.S. EPA) estimates downwind dispersion of a chemical release and is especially usefu l for analysis of explosions and fires. Note that the affected areas within the oleum and formaldehyde circles are above the Emergency Response Planning Guideline-Level 2 (ERPG-2). According to U.S.EPA documentation, this level represents the "maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action." The estimated population within the oleum worst-case release circle is 280,000, while the estimated population within the oleum alternative release circle is estimated at 3,600. The population beyond the circle should not experience an impact level of concern from an oleum release. The estimated population within the formaldehyde worst-case release circle is 960, while the estimated population within the formaldehyde alternative release circle is 1,200. The population beyond the circle should not experience an impact level of concern from a formaldehyde release. The endpoint for the consequence analysis of a vapor cloud explosion of a regulated flammable substance is an overpressure of 1 pound per square inch (psi). This endpoint was chosen as the threshold for potential serious injuries to people as a result of property damage caused by an explosion (for example, injuries from flying glass from shattered windows or falling debris from damaged houses). The estimated population within the ethyl ether worst-case release circle of 1 psi overpressure is 720, while the estimated population within the ethyl ether alternative release circle is 120. The population beyond the circle should not experience an impact level of concern from an ethyl ether release. Should an accidental release occur that has potential for offsite consequences, plant-wide alarms will sound. The emergency response team will provide an immediate and rapid respo nse and emergency shutdowns systems and procedures will be activated. Modeling Limitations and Assumptions Air-dispersion models are limited in their ability to accurately predict the impact of a chemical release. Their limitations increase as the complexity of the topography surrounding the release site increases. The EPA-recommended models used for the INDSPEC worst-case and alternative release scenarios have likely over-estimated the impact distance, because of several complicating conditions: - Near the oleum, ethyl ether, and formaldehyde tanks and piping are large industrial buildings and structures. These features disrupt and redirect air flow, but the models used assume winds are steady and moving in a straight line. - Beyond plant property, buildings, structures, vegetation, and terrain features also serve to disrupt and redirect air flow. - The chemicals emitted are assumed to have no reaction with the ground, other chemic als, or other potential release conditions. However, it is likely that releases of oleum, ethyl ether, and formaldehyde will deposit on the ground and other surfaces as they disperse from a ground-level source. These chemicals may also react with other chemicals or with fire. In each case, the resulting impact distance is likely to be less than the distance predicted by the models. Note that a "synergistic effect" can occur from two chemicals interacting during an accidental release. Such synergism results when the effect of two substances acting together "is greater than the sum of their individual effects." Synergistic effects are not expected to occur. Interaction of these chemicals would likely serve to reduce impact downwind. Some interaction of these chemicals with other chemicals on site is possible during a catastrophic release. This interaction would tend to decrease the distance to the toxic endpoint (TE) give n in our offsite consequence analysis. Furthermore, in non-uniform terrain, ambient-air concentrations tend to remain higher as the gas plume is constricted within the valley. That is, downwind distances to the TE may be longer along a valley and shorter across a valley. Therefore, the distance to the TE may be understated in situations with narrow valleys. At the INDSPEC plant, potential releases would be affected by both their proximity to plant buildings and hilly terrain. These topographic features would tend to concentrate emissions close to the facility and lessen concentrations farther away. PREVENTION PROGRAM The Prevention Program ensures that regulated substances are safely stored, used, and handled. In addition, if a chemical release occurs, the Prevention Program ensures that procedures and equipment are established to detect and mitigate the impact of such a release. The completion of Occupational Safety and Health Administration (OSHA) Process Safety Management (P SM) requirements essentially satisfies the 112(r) Prevention Program requirements for oleum, ethyl ether and formaldehyde in the Prevention Program-level 3 processes. Safeguarding the public from accidental releases through an effective Prevention Program is an important component of the 112(r) rule. The Prevention Program-level 3 elements include: - Process safety information: INDSPEC compiled written process safety information that is completed prior to conducting any process hazard analysis required by the rule. This written information enables INDSPEC and the employees involved in operating the process to identify and understand the hazards posed by those processes involving regulated substances. Minimum information includes hazards data such as that found on a Material Safety Data Sheet, technology information, and equipment information. - Process hazard analysis: A hazard evaluation has been performed by an experience d team to identify, assess, and control the hazards involved in each of the covered areas. The "what- if"/checklist methodology was used for determining and evaluating the hazards of the process. The analysis addressed the hazards of the process, the identification of any previous incident which had a likely potential for catastrophic consequences, engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases, consequences of failure of engineering and administrative controls, stationary source siting, human factors, and a qualitative evaluation of a range of possible safety and health effects of failure of controls. These analyses are being updated and revalidated on a five year basis. - Operating procedures: Written procedures have been developed and implemented to prov ide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information. Elements that are addressed include steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions. Operating procedures are readily accessible to employees who work in or maintain a process. These procedures are reviewed as often as necessary to assure they represent current operating practice. Annual certification helps to assure the currency and accuracy of the procedures. In addition, safe work practices, applicable to employees and contractor employees, are developed and implemented to provide for the control of hazards during a variety of plant operations. - Training: Initial and refresher training is conducted as appropriate for each employee involved in operating a process. INDSPEC ascertain s and documents that each employee has received and understood the required training. - Mechanical integrity: INDSPEC has developed a mechanical integrity program that applies to pressure vessels and storage tanks, piping systems, relief and vent systems and devices, emergency shutdown systems, controls, and pumps in the covered processes. Written procedures, training for process maintenance activities, inspection and testing, correction of equipment deficiencies, and quality assurance are all included in INDSPEC's mechanical integrity program. - Management of change: Written procedures have been established and implemented to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and changes to other stationary sources that affect a covered process. The procedures assure that the technical basis for the proposed change, the impact of the chan ge on safety and health, the modifications to operating procedures, the necessary time period for the change, and authorization requirements for the proposed change are all addressed. Appropriate employees and contractors are informed of, and trained in, the change prior to startup of the process or affected part of the process. Updates to the RMP are made if required by the nature of the change. - Pre-startup review: A pre-startup safety review is performed for new covered processes and for significantly modified covered processes at INDSPEC. Such review confirms that prior to introduction of regulated substances to the process that construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and adequate; for new stationary sources, a process hazard analysis has been performed and for modified stationary sources, ma nagement of change requirements have been met; and training of each employee involved in operating a process has been completed. - Compliance audits: INDSPEC evaluates compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. INDSPEC's compliance audit is conducted by a team consisting of outside auditors, the Manager of Safety & Training and representatives from each covered process. A report of the compliance audit findings is developed. INDSPEC determines and documents an appropriate response to each of the audit findings, establishes a schedule for acting on the findings and documents that deficiencies have been corrected. The two most recent audit reports are retained. - Incident investigation: INDSPEC will investigate each incident that results in, or could reasonably result in a catastrophic release of a regulated substance. This investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident. An incident investigation team will be established with appropriate personnel. A report, which shall be retained for five years, is prepared at the conclusion of the investigation. A system has been established to promptly address and resolve the findings and recommendations of the incident report, with documentation of resolutions and corrective actions. The report shall be reviewed with all affected personnel, including contract employees where applicable, whose job tasks are relevant to the incident findings. - Employee participation: INDSPEC has developed a written plan of action regarding employee participation. Employees and their representatives are consulted with on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in the 112(r) rule. Employees and their representatives are also provided access to process hazard analyses and to all other information required to be developed under the rule. - Hot-work permit: INDSPEC issues a hot-work permit for hot-work operations conducted on or near a covered process. The permit documents that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot-work operations. The permit further indicates the date(s) authorized for hot work and identifies the object on which the hot work is to be performed. The permit is kept on file until the hot-work operations are completed. - Contractors: INDSPEC and contract-company owners and operators comply with the requirements for contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. Contractor issues include, among other responsibilities, evaluation of past contractor safety performance and programs, and informing contractors of known potential fire, explosion, or toxic release hazards related to the contractor's work and the affected processes. (Note that this part of the RMP requirements does not apply to contractors providing incidental services that do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services.) In addition to what is required by the 112(r) rule, INDSPEC is prepared to prevent and mitigate accidental releases by safe process and equipment design, maintenance of equipment, operating safely, and auditing our operations. - Process and Equipment Design: Backup safety systems, pressure relief valves, insulated vessels and piping, and local emergency shut down systems are used to help mitigate the potential for leaks from the affected processes and equipment. - Equipment Maintenance: INDSPEC has a preventive maintenance program in place along with work planning, safety checks and reviews, periodic inspections, and qualified maintenance personnel. - Safe Operations: Operators are trained and certified. Operations are continuously monitored by computer. Written procedures are in place for all operators. - Operations Auditing: Internal and Independent audits of the oleum, ethyl ether and formaldehyde operations are performed. FIVE YEAR ACCIDENT HISTORY For at least the past five years, no reportable accidental releases from covered processes have occurred. EMERGENCY RESPONSE PROGRAM An Emergency Response Program has been developed and will be implemented as required for the purpose of protecting public health and the environment. In-plant emergency response consists of training and planning to prepare for, prevent, respond to, and recovery from emergencies. Those situations identified in INDSPEC's emergency response program include hazardous material release, fire, explosion, floods, severe weather, and terrorism. A plant specific Incident Command System (ICS) has been installed. The ICS is designed to be used for all types of emergencies, and is applicable to both small releases or minor fires and large-scale disasters. This system has established a Chain of Command and assigned responsibilities in order to assess and respond to emergency situations. Plant-wide alarms are activated in the event of an emergency. In addition to in-plant emergency response events, a system has been established in order to notify outside personnel. Depending on the severity and type of event, facilities/agencies notified include, but are not limited to: Penreco and Witco (neighboring industrial facilities), Petrolia and Bruin Fire Departments, local police and ambulance se rvice, Local Emergency Response Committee of Butler County, and the Pennsylvania Department of Environmental Protection (Meadville). PLANNED CHANGES TO IMPROVE SAFETY INDSPEC is committed to providing a safe and healthy work environment for all employees. This program includes our on-going efforts in the area of Process Safety Management of hazardous chemicals. Through the work of well versed work teams performing process hazard analysis and pre-start up safety reviews on new or modified equipment; and the initial, recurrent and update-training sessions for operations and maintenance personnel, we continue to review methods of improving safety in the workplace. INDSPEC has also introduced an enhanced behavioral process approach to safety. This process operates by identifying "Desired Behaviors" and "At-Risk Behaviors" in the workplace through daily contacts and performing plant-wide evaluations. By identifying elevated risk conditions prior to injuries occurring, a pro-active a pproach can be taken to implement corrective actions. |