Cognis Corporation, Cincinnati Plant - Executive Summary |
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INTRODUCTION At Cognis Corporation's Cincinnati, Ohio manufacturing plant, protection of employees, the public and the environment is considered to be the most important responsibility. A key element of the plant's protection program is the development and implementation of plans to prevent accidental chemical releases. In addition, if an accidental release should occur, plant personnel are prepared to respond in an organized and effective manner. The plant's accident prevention and emergency response programs have been developed in accordance with federal and state regulations, industry standards, and guidance from local emergency response organizations. Although these programs have been highly successful - the plant has never had a significant chemical release - efforts are continually being made to improve them. The plant's Risk Management Program (RMP) plan was prepared to comply with federal regulatory requirements regarding the prevention of accidental chemical releas es (40 CFR 68, Chemical Accident Prevention Provisions). The purpose of the regulation is to reduce the potential for an accidental chemical release and strengthen emergency response planning at the facility and within the community. The RMP plan describes the incidents that would have the most catastrophic effects (the "worst-case release scenarios") and several scenarios of lesser magnitude ("alternative release scenarios"). Although it is technically infeasible for the worst-case release scenarios described in this plan to occur, the information is provided to support conservative emergency response planning. In this way, the community is well prepared to respond to incidents of lesser magnitude, which are more likely to occur. Areas that could be impacted by an accidental chemical release were identified using RMP*Comp (Ver 1.06), which was developed by U. S. EPA for accidental chemical release modeling. COGNIS CORPORATION Cognis Corporation, which was previously part of Henk el Corporation and is now a wholly-owned subsidiary of the worldwide Henkel Group (headquartered in Dusseldorf, Germany), manufactures products that improve people's lives. Cognis produces chemical ingredients that are used in many industries, including personal care (such as soap and shampoo), nutrition, automotive, construction, paint and agriculture. The Henkel Group has more than 55,000 employees serving in more than 330 companies in 70 nations. Respect for the environment is a central tenet of Cognis. Cognis facilities were instrumental in Henkel Corporation being cited by the U.S. Environmental Protection Agency as an Environmental Champion for its performance in the voluntarily 33/50 pollution prevention program. Cognis voluntarily participates in the Chemical Manufacturers Association Responsible Care ? initiative and is implementing its environmental, health and safety codes of practice on a worldwide basis. ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The poli cy at Cognis Corporation's Cincinnati plant is to prevent all releases of potentially harmful substances. Senior management is responsible for release prevention and response programs, and considerable time and resources have been invested in this effort. The plant has detailed procedures to ensure that safety is considered in the design, installation, operation and maintenance of each process. Plant personnel receive regular safety training, and employee input is solicited on every aspect of safety performance improvement. Failure to follow safety policies is grounds for dismissal. If a release were to occur, trained personnel would control and contain the release. The standard procedure is to technically evaluate each situation, identify potential on-site and off-site impacts, evacuate or shelter employees as necessary, contain the release and contact the local fire department to control the release and minimize its consequences. DESCRIPTION OF STATIONARY SOURCE The Cogn is Corporation's Cincinnati, Ohio plant is a chemical manufacturing facility located at 4900 Este Avenue. A variety of processes are operated at the plant to produce 370 different products derived from animal fat or vegetable oil. The plant, originally constructed in 1885, is situated on 105 acres of land. Of this, about 70 acres have been developed. Part of the plant is located in the City of Cincinnati and part is located in the City of St. Bernard. The two parts are separated by the Mill Creek, a tributary of the Ohio River. Fatty acids and fatty alcohols are the major products produced at the Cincinnati plant. Glycerin, esters and surfactants are also produced. These products are used in household and industrial cleaners, personal care products, biodegradable synthetic lubricants, adhesives, agricultural products, plasticizers, and other special applications. The plant is subject to numerous environmental, health and safety regulations and is regularly inspected by agency representatives. The following activities are specifically regulated: ? Air emissions - permits issued by Ohio EPA, ? Wastewater - discharge permit issued by the Metropolitan Sewer District, ? Oil spill prevention - subject to OPA-90 regulations, ? Storm water - permit issued by Ohio EPA, ? Hazardous waste management - U. S. EPA ID# OHD093903235, ? Process safety - subject to OSHA Process Safety Management Rule, ? Emergency planning - subject to SARA 311/312 reporting, and ? Toxic chemical release reporting - subject to SARA 313 reporting (ID # 45232 HNKLC4900E). DESCRIPTION OF REGULATED SUBSTANCES The Cincinnati plant handles two chemicals in sufficient quantities to be covered by the RMP regulations. Ammonia, which is regulated as toxic substance, is used as a refrigerant in the Solvent Separation process. Hydrogen, which is regulated as a flammable substance, is used as a process ingredient in the Hydrogenation processes that are part of the Fatty Alcohol and Stearic Acid man ufacturing operations. All of these processes have been assigned to RMP Program Level 3. OFFSITE CONSEQUENCE ANALYSIS Following U. S. EPA guidance, an offsite consequence analysis (OCA) was performed to determine the potential for an accidental release of a regulated substance to affect the public or the environment. The OCA included both worst-case release scenarios (WCSs) and alternative release scenarios (ARSs). Considering the design of the regulated processes and the plant's accident prevention programs, it is virtually impossible for the WCSs to occur. Although it is highly unlikely that the ARSs would ever occur, the ARSs represent release scenarios that are at least somewhat feasible. The main objective of the OCA was to determine the furthest distance (called the endpoint distance) at which certain conditions might exist as a result of an accidental chemical release. Most people at the endpoint distance would be able to walk away from the exposure without any long-te rm health consequences, although some short-term consequences are possible. WORST-CASE RELEASE SCENARIOS The WCS for ammonia is a catastrophic failure of a high- pressure receiver, resulting in a release of 19,000 pounds of anhydrous ammonia over a 10-minute period. Even though numerous controls are in place to prevent such a release and to mitigate its impact, they were not taken into account in evaluating this accidental release scenario. The maximum distance to the toxic endpoint of 200 ppm (0.14 milligrams per liter) for this WCS is 1.7 miles. The WCS for hydrogen is a catastrophic failure of the liquid hydrogen storage tank, resulting in the release and explosion of 11,000 pounds of hydrogen. Again, no safety controls or mitigation measures were taken into account in evaluating this scenario. The maximum distance to the endpoint (1 psi overpressure for a vapor cloud explosion) for this WCS is 0.2 miles. The facility has modern, redundant systems designed to prevent thes e scenarios from ever happening. See the discussion below under "GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS" for details. ALTERNATIVE RELEASE SCENARIOS The ARS for ammonia is a flange leak in a high pressure transfer line, resulting in a release of 9,500 pounds of liquid ammonia over 19 minutes. The 19-minute release duration is the approximate time it would take for the liquid level in the system to drop below the level of the flange. At that point, emergency response personnel could safely enter the area and close a manual valve to completely stop the leak. Some of the liquid ammonia vaporizes before it can be washed with water into the plant's wastewater treatment facility. No other mitigation measures were taken into account in evaluating this scenario. The maximum distance to the endpoint of 200 ppm (0.14 milligrams per liter) for this ARS is 0.2 miles. The ARS for hydrogen is a rupture of the liquid hydrogen delivery line, resulting in a release and explosion of 7,500 pounds of hydrogen. No mitigation measures were taken into account in evaluating this scenario. The maximum distance to endpoint for a vapor cloud explosion is 0.1 miles. FIVE-YEAR ACCIDENT HISTORY The Cincinnati plant has an excellent record of accident prevention. The RMP regulations require companies to report all significant releases from regulated processes that occurred during the past five years. The plant has not had any releases subject to reporting. There have been a few small chemical releases, but none of them had an offsite impact. Plant personnel are available to answer any related questions. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at the Cincinnati plant. Since processes at the plant that are regulated under the RMP regulations are also subject to the OSHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describe s the management system in place to implement the accident prevention program. Employee Participation The Cincinnati plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the facility accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the plant and addresses each accident prevention program element. In addition, the facility has a number of initiatives under way that address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of th e plant, including operations, maintenance, engineering and plant management. Process Safety Information The Cincinnati plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents, and their location is readily available as part of the written employee participation plan to help employees locate any necessary process safety information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets. This information is supplemented by documents that specifically address known hazards. For specific process areas, the plant has documented safety-related limits for certain process parameters (e.g., temperature, level, composition) maintained in the process operating procedures. The plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The plant also maintains numerous technical documents that provide information about the design and construction of process equipment. The information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis The plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within the program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The plant primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The team identifies and evaluates the hazards associated with a process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigating options in r esponse to a PHA is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least once every five years, and they will continue to be conducted at this frequency until the process is dismantled. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Pro cedures The plant maintains written procedures that address various modes of process operations, such as unit startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. They are reviewed periodically and certified annually as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the Management of Change (MOC) process. In addition, the operating procedures provide guidance on how to respond should an upset situation occur, such as an electrical outage or process alarm. This information, along with written operating procedures, is readily available to operators in the process unit and is provided to other personnel to use as necessary to safely perform their job tasks. Training To complement the written proce dures for process operations, the plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skill demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every three years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors: ? Perform their work in a safe manner, ? Have the appropriate knowledge and skills, ? Are aware of the hazards in their workplace, ? Understand what they should do in the event of an emergency, ? Understand and follow site safety rules, and ? Inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with the necessary training prior to their beginning work. In addition, the plant evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSR's) The plant conducts a PSSR for any new facility or major modification of an ex isting facility. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, process controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic elements of this program include: ? Conducting training, ? Developing written procedures, ? Performing inspections and tests, ? Correcting identified deficiencies, and ? Applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on an overview of the process, safety and health hazards, applicable maintenance procedures, emergency response plans, and applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or an MOC team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that the new equipment is suitable for its intended use and that proper material and spare parts are used when repairs are made. Safe Work Practices The Cincinnati plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: ? Control of the entry/presence/exit of support personnel, ? A lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, ? A procedure for safe removal of hazardous materials before process piping or equipment is opened, ? A permit and procedure to control spark-producing activities (i.e., hot work), and ? A permit and procedure to ensure that adequate precautions are in place before entry into a con fined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The plant has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and to verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The plant promptly investigat es all incidents that resulted in, or reasonably could have resulted in a fire/explosion, a toxic gas release, major property damage, environmental damage, or an OSHA recordable injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are completed. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for a least five years so that the reports can be reviewed during future PHAs and PHA revalidation. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Cincinnati plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. A compliance audit is conducted at least once every three years. The audit team develops findings that are forwarded to plant management for resolution. Corrective action plans developed in response to the audit team's findings are tracked until all items are complete. The final resolution of each finding is documented, and the two most recent reports are retained. CHEMICAL- SPECIFIC PREVENTION STEPS The processes at the Cincinnati plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all RMP-covered processes at the facility. Collectively, these prevention program activities help prevent potential accidental scenarios that could be caused by equipment fa ilure or human error. In addition to the accident prevention program activities, the Cincinnati plant has safety features on many units to help detect, contain/control, and reduce the consequences of a release. The following types of safety features are used in various processes: Release Detection ? Chemical detectors with alarms, Release Containment/Control ? Scrubbers to neutralize chemical releases, ? Valves to permit isolation of the process (manual and automated), ? Automated shutdown systems to a process if an upset condition occurs (e.g., high level, high temperature), ? Curbing or diking to contain liquid releases, ? Redundant equipment and instrumentation, ? Emergency backup power supply for critical controls, ? Special classified electrical equipment in areas where flammable chemicals are used, Release Mitigation ? Fire suppression and extinguishing systems, ? Trained emergency response personnel, ? Personal protective equipment (e.g., protective clothing, self-contai ned breathing apparatus), and ? Blast-resistant buildings to help protect control systems and personnel. EMERGENCY RESPONSE PROGRAM INFORMATION The Cincinnati plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response; including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies if a release occurs, and post-incident cleanup and decontamination. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the proper use of that equipment. Employees r eceive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based upon modifications made to the plant processes or other plant facilities. The overall emergency response program for the Cincinnati plant is coordinated with the Hamilton County Local Emergency Planning Committee (LEPC) as well as the Cincinnati and St. Bernard fire departments and other area businesses. The plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the plant conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the plant provides refresher training to local emergency responders regarding the hazards of re gulated substances in the plant. PLANNED CHANGES TO IMPROVE SAFETY The Cincinnati plant resolves all findings and recommendations from audits, process hazard analyses and incident investigations, some of which result in modifications to the process. At this time, there are no planned changes to the systems described above. |