Akzo Nobel Polymer Chemicals LLC - Executive Summary |
|
AKZO NOBEL Chemicals Inc., Edison site, has a Risk Management Program which meets the requirements of OSHA - PSM, EPA - RMP, New Jersey - TCPA and CMA - Responsible Care guidelines. The site is a OSHA VPP Star site and it's Quality and Environmental management systems are certified for ISO 9001 and ISO 14001 standards. The Process Safety Information documentation and updating functions are assigned to different department managers and detailed in the "Site Employee Participation Plan" document. Process Hazard Analysis are coducted on a five year schedule by suitable process hazard analysis teams. The teams are composed of a team leader, personnel having knowledge of production and maintenance procedures and a production operator. Normally the What If / Checklist method is used. The recommendations are tracked by quarterly followup reports. The Process and Quality (PQC) Manager is responsible for implementation of this RMP element. The Standard Operating Procedures (SOP's) are writte n and updated by the process and production engineers / supervisors. The Production Manager is responsible for keeping the SOP's current. The SOP's are verified and certified for correctness once a year. Hard copies of SOP's are available in the applicable production areas. The training is planned and tracked by the Safety and Training Manager according to the annual training plan. The training materials include manuals, lesson plans, video tapes, overheads and field equipment. The uderstanding of the training is verified by written tests, oral examinations and demonstrations. Any one or all of these may be employed. The training activities are tracked by a training database. The Maintenance Superintendent is responsible for implementation of the Mechanical Integrity Program. The program consists of equipment lists and specifications, equipment history files, preventive maintenance procedures and an automated work order system. Work permits, entry permits and hot work permits have b een incorporated in the Safety Procedures Manual. Yearly reports are issued to verify that all regulated equipment is tested and inspected as per the documented program. The Safety and Training Manager is responsible for implementation of the Management of Change (MOC) Program.The detailed MOC procedure and the Pre - Startup Procedure has been incorporated in the Safety Procedures manual. A committee consisting of various technical personnel reviews and approves all MOC requests. The completion of all action items is tracked and documented. Annual and tri - annual compliance audits are coordinated by the PQC Manager. Normally they are led by corporate expert personnel. Deficiencies are noted and scheduled for system improvements by the responsible managers. The completion of recommendations is tracked and documented by the Management Safety Committee. The Incident Investigation Program consists of a detailed procedure incoporated in the Safety Procedures Manual. All regulated che mical releases are investigated by the area supervisor and issued as preliminary reports to a committee. The committee reviews the reports to ensure that root causes have been identified and suitable corrective actions have been proposed. The Safety and Training Manager then issues a final incident investigation report by incorporating information and feed back from all sources and reviews. The final reports are distributed to all supervisory personnel, who in turn discuss these with their employees in their safety contacts. All action items are tracked and the completion is documented. There is a written Employee Participation Plan document, which describes the major requirements of various RMP elements and how the employees participate in their implementation. The program is implemented by the PQC Manager. The Contractor Program follows the OSHA - PSM and NJ - TCPA requirements. The program is implemented by the Safety and Training Manager. Nine hundred fifty thousand pounds of Titanium Tetra Chloride are inventoried to produce Catalysts and Catalyst Components for the Polymer industry. The Worst Case toxic release of Titanium Tetra Chloride is calculated at 1.9 miles by RMP*Comp. The Alternate Case toxic release of Titanium Tetra Chloride is calculated at 0.1 mile by RMP*Comp. Site release prevention and chemical specific prevention used are relief valves, rupture discs, vents, check valves,scrubbers, quench systems,automatic shutoffs, interlocks, keyed bypasses, grounding, and purge systems. Mitigation systems used are dikes, sumps, sprinkler systems, deluge systems, water curtains, hazmat foam system, fire fighting foam systems, mineral oil dump systems and neutralization. Most of process areas are monitored by leak detection and alarms systems for toxic and flammable leaks.Operator refresher training is conducted on prescribed basis of the operator training program. The preventive maintenance program conducts inspections and tests to assure operation o f preventive devices. Management of Change procedure assures that all changes are reviewed for their hazards before implementation. All incidents are investigated to determine the root cause and corrective actions are implemented to prevent future incidents. The site had no reportable accident during last five years. The site emergency response program meets the requirements of the EPA Integrated Contingency Plan Guidance. The plan defines the response organization, coordination with local emergency response committee, equipment, response procedures, training, notification procedures, and drills. The plan is updated according to the recommendations from the system deficiencies uncovered by the periodic drills and the incident reports. The safety improvements being implemented at this time are a toxics monitoring system at the perimeter and a fire water containment system. |