BOC Gases - Lumber City - Executive Summary |
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The BOC Gases Lumber City facility, owned and operated by The BOC Group, Incorporated is located at 7 Pine Street, Lumber City, GA. The management and employees of the Lumber City facility are committed to the prevention of any accidental releases of anhydrous ammonia. If an accidental release should occur, the facility is prepared to work with the local fire department, or other authorities to mitigate any release and minimize the impact of the release to the community and the environment. The facilities primary operation is the separation of air into there main components. A support process to this operation involves the use of ammonia. Ammonia is received and stored in a 12,000 gallon tank. The ammonia is then sent to a Dissociator where the ammonia is separated into it's component elements of hydrogen and nitrogen gas. The process of separation occurs when ammonia gas flows through a dissociator where separation (cracking) is accomplished over a catalyst at 1750 degrees Fahr enheit. The cracking reaction is an endothermic reaction with no potential of runaway. From the dissociator the cracking products, hydrogen and nitrogen gas, are cooled by a cross-exchanger and further cooled by use of an aftercooler. The final product, (H2-N2) is fed to a argon purification skid. The worst-case scenario, based on the EPA's definition for a toxic gas release, would be the rupture of the 18,000 gallon Ammonia Tank. The results would be a maximum release of 46,000 lbs of ammonia over a 10 minute period. The endpoint of 0.14mg/L (EPRG-2 Level) was determined to be 2.6 miles using the RMP*Comp. (1.06) software. The weather conditions used were a wind speed of 1.5 meters/sec., Stability Class F, an air temperature of 77 degrees F and urban topographical terrain. The impacted area would affect 530 residents and several special receptors which includes one Nursing Home and several churches and the Ocmulgee Academy School based on the 1990 US Census data obtained from " Land View III". Several business and industries are also within the endpoint. No passive/active mitigation or administrative controls were considered in this assessment. The alternative release, or more probable, scenario which was determined involved the uncoupling of the 2" fill hose during filling of the tank from a road trailer. This release would result in the 10 second release of 15 gallons (77 lb) of liquid anhydrous ammonia prior to the activation of the emergency shut-off valve. The Excess Flow Valve would shut-off the liquid pump along with the activation of the Emergency Shut-off Valve by the driver, resulting in termination of the release. The release endpoint of 0.14mg/L (EPRG-2) was determined to be 0.13 miles using the RMP*Comp. (1.06) software. The Weather conditions used were a wind speed of 3.0 meters/sec., Stability Class D, and air temperature of 77 degrees F and urban topographical terrain. The affected area would include 16 homes with approximately 41 residen ts and one businesses (Amercord) based on actual observations. Passive and Active Mitigation systems in place that would reduce the likelihood of a release or the release itself. These include check valves in the fill lines, Excess Flow Valves and Emergency Shut-off Valves on the Delivery vehicle, a preventive maintenance schedule for the system, safeties and UT testing of the tank. The facility has developed a comprehensive prevention program designed to prevent accidental releases of ammonia. The program utilizes state-of-the-art technology, sound engineering practices, administrative controls and active employee participation. Employees serve on task groups and teams in developing and maintaining risk management program elements. They are frequently consulted concerning the various aspects of the program and ways to continually improve the safety of the process. Written process safety information was developed for the ammonia system to enable managers, supervisors, and empl oyees to identify and understand the process hazards. This information was utilized to develop a Process Hazard Analysis (PHA) which assists management and employees in making decisions for improving safety and reducing the consequences of releases of ammonia. The PHA focuses attention on equipment, instrumentation, utilities, human actions, (routine and nonroutine), and external factors that might impact the process by identifying potential failure points or failure modes in the process. The PHA was review and updated on 7/1/94 and will be updated at least every 5 years. Detailed 0perating procedures exist which describe tasks to be performed, dates to be recorded, operating conditions to be maintained, samples to be collected, and safety and health precautions to be taken. The procedures were reviewed/approved to ensure they are technically accurate by employees, managers and personnel with the technical expertise/knowledge of the process. The operating procedures were review on 2/5/99 and are annually reviewed/revised as necessary to reflect current operations. Employees are thoroughly trained, including maintenance and contractor employees. The training meets and exceeds the requirements as outlined in OSHAs hazard communication standard 29 CFR 1910.1200. Training includes operating procedures, safe work practices, emergency procedures (including alarms), special assignments, evacuation and emergency response; safety rules and procedures; routine and nonroutine work authorization; and other pertinent process safety information. Each employee trained has a defined and documented program based on their job duties. The training goals and objectives have been established and written in clear and measurable terms. Hands-on training is provided to employees to enhance their senses beyond listening. In addition, employees receive traditional classroom instruction including lectures, videos, programmed and on-the-job instruction. Employees are encouraged t o actively participate. The employees are periodically evaluated to ensure they posses the necessary skills and knowledge via written tests, observation and/or oral interviews. The training program was last reviewed on 2/15/99. A contractor screening process has been established and is designed to ensure that contractors hired or used can accomplish their assigned tasks without compromising the safety and health of employees and the public. The screening program involves obtaining information on the contractor's safety performance, including injury and illness rates, and experience. In addition, the contractor's safety performance, job skills, knowledge, and certifications (such as pressure vessel welders) are also verified. The contractors safety procedures were last review in Feb. 1999. PreStart-up Safety Reviews (PSSR) are used for new or modified processes to improve the design and construction of the process from a reliability and quality stand point. The PSSR recommenda tions are resolved before final installations are complete. Other items completed prior to initial process startup include piping and instrument diagrams, operating procedures, and ensuring operating personnel are fully trained. The initial startup and normal operating procedures are fully evaluated as part of the PSSR to assure a safe transfer into the normal operating mode for meeting the process parameters. The last PreStart-up Safety Review was conducted on May 1995. An on-going mechanical integrity program (maintenance) is used to ensure safe process operations. Equipment used to store, process, or handle ammonia has been designed, constructed, installed, and maintained to minimize releases. The mechanical integrity program includes the identification and categorization of equipment/instrumentation, inspection/tests and their frequencies, development of maintenance procedures and training of maintenance personnel, criteria for acceptable test results, documentation of test/insp ection results, and documentation of manufacturer's recommendations to prevent failure of equipment and instrumentation. This program was review on 2/15/99. Hazardous work or nonroutine work is controlled in a consistent manner. The hazards identified is communicated to those performing the work and to operating personnel whose work could affect the safety of the process. The BOC Hazardous Work Program describes the steps that a supervisor, contractor representative or other authorized issuer needs to follow to manage hazardous work. The program references and coordinates applicable lockout/tagout procedures, line breaking, hot work authorization, elevated work/fall protection, controlling access to covered process areas, and excavation procedures. BOC's Confined Space Entry Program is a separate permitting system designed to manage it's employees/contractors in performing this type of work. This Program was review in 9/3/98 for both employees and contractors. Management of Chan ge (MOC) procedures have been developed for permanent changes to process chemicals, technology, equipment and facilities. MOC procedures are designed to ensure that prior to any change occurring, that technically qualified personnel with knowledge and expertise of the chemical process, reviews and approves the proposed changes. This would include both technical and mechanical changes. Process changes include all modifications to equipment, procedures, raw materials and processing conditions other than "replacement in kind". A Process Change Authorization is required for all changes. Management of Change procedures were review on 2/15/99. Process incidents which result in or could reasonably have resulted in a release of ammonia are investigated, including "near misses", within 48 hours of the incident. The purpose of the incident investigation is to identify the underlying causes of the incident and to implement corrective action to prevent similar incidents and avoid past mista kes. Process incidents are investigated by a Team which include both management and employees and is multidisciplinary. An incident report is prepared following the investigation which includes the findings, conclusions, and recommendations. The Facility Manager is responsible for ensuring that all report recommendations are completed or resolved by those individuals responsible for follow-up. All resolutions are communicated to all affected employees. The facility has an emergency preparedness/response plan. The plan outlines what actions employees are to take when there is a release of ammonia. The plan complies with OSHA standard 29 CFR 1910.38 and has been coordinated with local emergency response agencies. The facilities Emergency Response plan was review in 2/15/99 and tested at that time. The facility receives a compliance audit in accordance with EPA's Risk Management Standard Part 68 at least once every three years. The audit includes an evaluation of the design and ef fectiveness of the risk management system and a field inspection of the safety and health conditions, and practices to ensure compliance. The Team uses an audit tool to document each audit step and ensure an effective audit is conducted. A Protocol Policy has been developed to ensure that proper follow-up is accomplished. BOC Gases will make available all information, including any Trade Secret information as it relates to compliance with this regulation. The facility has an Emergency Response Plan which has been integrated with the local community Emergency Response Plan. All employees and contractors are trained in the plan prior to commencement of work. The Emergency Plan is tested and critiqued twice a year to insure that it is current. Changes are made and reviewed if deficiencies are found. The site does not have trained Emergency Responders at the technician level, however, BOC maintains trained technician level Emergency Responders on 24hr. call through out the US. Safety improvement is an on-going process at the facility. Periodic evaluations are performed to assess the maintenance of safe conditions. There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. |