Danville Works - Executive Summary |
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RMP*Submit: Executive Summary Honeywell Danville Plant ILD005463344 Facility ID Number 1. Introduction The Honeywell International Inc. (Honeywell) Danville Plant is a packaging and bulk distribution facility located in Danville, Illinois. It is part of the Performance Polymers and Chemicals Business Unit of Honeywell International Inc. 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 materials. With 1999 sales of approximately $24 billion, the company ranks among the top 100 of the Fortune 500. Honeywell has approximately 125,000 employees in 95 countries. Honeywell is a diversified technology and manufacturing leader, serving customers worldwide with aerospace products and services; control technologies for buildings, homes and industry; automotive products; power generation systems; specialty chemicals; fiber s; plastics; and electronic and advanced materials. More information about Honeywell may be found at its Web Page: www.Honeywell.com It is the world wide policy of Honeywell to design, manufacture and distribute its products and to handle and dispose of materials throughout their life cycle in a manner that protects the environment and safeguards employees, customers, and the public from unacceptable risk. The Honeywell Danville 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 Honeywell Danville Plant endeavors to accomplish this by participating on and cooperating closely with the Vermilion County Local Emergency Planning Committee. 2. Plant Description The Honeywell Danville Plant is located at 209 Brewer Road in Danville, IL, county of Vermilion. The area is bounded on the north by woods, on the east by a railroad switching yard, on the south by farmland and on the east by several residences. The plant employs 21 workers. The Honeywell Danville Plant's one covered process is comprised of storage tanks and bulk loading and unloading facilities for difluoroethane (HFC 152a) and methyl ether (also known as dimethyl ether). Both HFC 152a and methyl ether are used as propellants for various personal care products, primarily hair spray in cans. 3. Accidental release prevention and emergency response policies: It is the polic y of the Honeywell Danville Plant to operate a safe and environmentally sound facility by ? identifying and controlling health, safety, or environmental risks related to its operations; ? designing its processes to protect people, property and the environment; ? conducting and continually reviewing and improving programs for safety, health and environmental excellence; and ? establishing processes to assure that all laws and regulations applicable to its operations and products are known and observed. The accidental release prevention and emergency response policy associated specifically with the plant's use of difluoroethane and methyl ether involves: ? the integration of safety programs, devices and technologies inherent in the design of the process, ? safe operational procedures and management practices, ? operator training, ? the preparation and testing of plant emergency response plans, ? the maintenance of onsite emergency response equipment, and ? a trained Emergen cy Response Team, coordinating our efforts and resources with local emergency response services, and communicating with the community. The Danville plant has a new Process Safety Management System and a well-established Health, Safety and Environment Management System (HSE MS). Both management systems are integrated with all other plant management systems. These systems contain documented procedures for safe work practices, management of change, maintenance of process safety information, work permitting, emergency response, environmental monitoring, pollution prevention and employee health monitoring. The emergency response plan is a documented procedure that covers activation, response, notification, personnel protection, evacuation and incident critique. The plant's emergency response personnel are regularly trained to maintain a high level of readiness and expertise. Emergency response drills are held within the plant and we plan to hold them with local emergency response age ncies. 4. Worst Case and alternative release scenarios and administrative and mitigation controls in place to limit the impact of a release EPA's Risk Management Program requires the Honeywell Danville plant to prepare an analysis of a hypothetical worst case release of the chemicals 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 instantaneously and that all safety systems fail to operate. In addition, the release must take place during infrequent weather conditions that would inhibit dispersion of any vapor cloud. For a number of reasons discussed in this submittal, it is extremely unlikely that this event would ever occur. In addition, the Honeywell Danville plant is required to analyze the impact of an alternative accidental release scenario for the chemicals covered by the RMP regulations. The offsite consequence anal ysis for a "worst-case release scenario" at the Danville Plant's was performed for a full rail car of each RMP flammable chemical. The offsite consequences for each identified scenario were modeled pursuant to EPA's Offsite Consequence Analysis Guidance. The worst case scenario for flammable chemicals was identified as a release of methyl ether from a rail car. The contents of one car, 110,000 pounds, were assumed to be released instantaneously to the atmosphere followed by a vapor cloud explosion. There would be an offsite impact from this release. Because of the safety systems and prevention programs in place, the plant focussed emergency planning resources on release scenarios that, although unlikely, represent some potential for occurrence. The facility evaluated process hazard analyses conducted on the regulated processes and reviewed incident histories to identify potential release scenarios. The worst case alternative release scenario is described below: Methyl ether (D imethyl ether) A review of the methyl ether handling system was conducted to identify an alternative release scenario. Methyl ether is transferred to tank trucks through 20 feet sections of 2- inch diameter hose connected to transfer piping with "Camlock" style connectors. The failure of a hose connector was chosen for planning purposes. It was estimated that should this situation occur, the incident would be discovered and the transfer activity ceased within 10 minutes. The plant emergency brigade could respond and direct water to mitigate the vapors shortly thereafter. It is estimated that about 1,480 pounds of methyl ether would be released. The AEROPLUME Module of the HGSYSTEMS Model indicates that such a release would not result in an offsite impact. 5. The general accidental release prevention program and chemical specific prevention steps for the Honeywell Danville plant: The general accidental release prevention program at the Honeywell Danville Plant for the affecte d stationary sources includes the following elements: a) established process safety management system for oversight and control of the handling processes, b) process design review to minimize hazard potentials, c) development and implementation of accurate procedures for safe operation and maintenance of the process, d) a system to review and manage changes to the processes and process safety information, e) an on-going mechanical integrity program that ensures critical process equipment is designed, constructed, and installed in accordance to codes and standards, f) formalized, documented inspection protocols integrated with preventive and predictive maintenance programs such as vessel thickness testing and non destructive testing to ensure the reliability of equipment, g) performance of process hazards analyses with prompt resolution of any recommendations, h) use of safety shutdown, relief systems, dikes and other secondary containment installations, control instrumentation, and process monitoring for early warning and detection, i) performance of incidence investigations to establish root causes and identify corrective actions, j) process safety compliance audits, k) safety reviews of new or modified processes prior to activation, l) involvement of employees in development of operating procedures, process audits, incident investigations, m) contractor qualification programs that evaluate long term contractor safety performance and work qualifications, n) contractor work requirements which include pre-service orientation of supervisors and employees, regular self-audits and incident investigation and correction, o) comprehensive general and process-specific training programs for process operators and maintenance personnel, and p) Provision of safe havens for critical control functions to allow for orderly shutdown of processes should an incident occur. Chemical specific prevention steps include: a) designing the process technology and process equipment based on a thorough understanding of the hazardous properties of all hazardous chemicals, b) developing an understanding among the operators of the hazardous properties of all hazardous chemicals, the process chemistry and safe operational process limits such as temperatures, pressures, and flows, c) understanding the consequences of unsafe chemical handling and inadvertent mixing of incompatible chemicals, d) continuous review of process, response and mitigation technologies, e) designing and installing active and passive mitigation facilities such as a water curtain system, a liquid containment dike and closed circuit monitoring systems f) clear labeling of all vessels and containers to ensure contents are known, g) having knowledge of the requirements, capabilities and limitations of both personal protective and emergency response equipment and maintaining easily accessible inventories of each, and h) maintaining a response team trained to a high level of readiness. 6. The Danv ille plant's five year accident history: A review of the plant's incident records for significant events involving chemicals covered by the RMP rule was conducted. Danville has handled both chemicals within the past five years, but has not had any amount of either chemical on site since the RMP rule became effective in June 1999. There have been no incidents, accidents, or injuries associated with the storage, transport or other handling of these chemicals within the past five years. 7. The emergency response program: The Honeywell Danville plant has an emergency preparedness planning and response program designed to deal with accidental releases and other unplanned events associated with the facility's use of hazardous chemicals. The plant has a written Emergency Response Plan that addresses various types of contingencies including specific actions for responding to accidental releases. The Plan provides for both internal plant and external community emergency alerting a nd notification using established protocols. The plant has multiple means of communication established to alert public safety agencies. The plan addresses emergency health care, sheltering in place, evacuation, emergency responsibilities, response, control procedures, and emergency equipment. The Plan provides for the implementation of an Incident Command System to direct and coordinate the Plant's response activities. The Plan has been coordinated with the local emergency planning committee that would direct all offsite community response activities. The Honeywell Danville plant maintains a trained Emergency Response Team (ERT) which is knowledgeable and prepared to respond to incidents involving accidental releases. The ERT holds annual plant emergency response drills and other regular training exercises. The Danville plant utilizes audible warning systems for both onsite and offsite notification. The onsite notification system is activated in the control room. This system has siren and voice capability for live announcements. The system is tested monthly and during routine drills. Notification of persons off the site property is accomplished in conjunction with the local public safety agencies by activation of an audible warning system located on Honeywell property and maintained by plant personnel. This system also has siren and voice capabilities. The system is tested monthly. 8. Planned changes to improve safety: Honeywell pursues a philosophy of continuous improvement in all aspects of its operations. Improvements are identified and implemented throughout the facility's planning and operating cycles. The plant's systematic safety review program identifies action items that improve upon the existing safeguards at the Danville plant and further reduce the potential for accidental release. The process hazard analyses for the Danville handling processes will be reviewed and revalidated every five years. Continuous improvement of the plant's pr ocesses and systems provides the highest level of protection from chemical incidents. |