Wah Chang - Executive Summary

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EXECUTIVE SUMMARY  
WAH CHANG 
EPA FACILITY IDENTIFIER - 1000 0010 2925 
 
1. Accidental release prevention and emergency response policies 
 
Wah Chang's basic commitment to responsible stewardship of the environment, protection of the community, protection of employee health, and assurance of product safety extends to the processes covered by the new EPA Risk Management Plan (RMP) requirements.  The Wah Chang (WC) facility at 1600 Old Salem Road in Albany, Oregon has developed management systems in compliance with various applicable regulations to prevent the release of regulated substances especially in locations which may cause detrimental effects to employees, the community, or the environment.  This is accomplished through a systematic evaluation of process design, process technology, operational procedures, maintenance activities, non-routine procedures, emergency preparedness, training, and several other factors. 
 
The facility plans to meet or exceed regulatory requirements. 
 In the attempt to accomplish this goal, the management systems at the facility have been developed in such a way that the hazards are identified, understood, and controlled to prevent accidents.  The RMP regulated chemicals include chlorine, aqueous ammonia, phosgene, and titanium tetrachloride.  
Programs have been developed to comply with OSHA's 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals, and EPA's 40 CFR part 68 subpart D, Accidental Release Prevention Provisions in the Risk Management Program.   
 
2. The stationary source and the regulated substances handled 
The primary purpose of this facility is to extract zirconium and hafnium from zircon sand and produce various metal products.  These products are sold to customers who produce final products for the nuclear industry, the industrial process industry and other related industries.  Zirconium chemical products as well as byproducts are also sold.  
The regulated substances handled at this facility  
are chlorine, aqueous ammonia, phosgene, and titanium tetrachloride. 
The maximum amount of chlorine that is stored at this facility is 1,800,000 pounds. 
The maximum amount of aqueous ammonia that is stored at this facility is 180,000 pounds. 
The maximum amount of phosgene that is stored at this facility is 15,000 pounds. 
The maximum amount of titanium tetrachloride that is stored at this facility is 15,000 pounds. 
 
3. The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. 
 
Each of the regulated substances at the Wah Chang facility is in a separate process.  For this reason, WC has developed worst-case and alternative case release scenarios for each substance.  The development of the worst-case scenario is dictated by the EPA.  The amount of the substance released for the worst-case scenario is equal to the greatest amount held in a single vessel or p 
ipe line.  For toxic chemicals that are normally gases at ambient temperature and are handled as a gas or as a liquid under pressure, the chemical is assumed to be released as a gas over 10 minutes.  The release rate to the atmosphere is calculated as the quantity released divided by 10 minutes unless passive mitigation is in place.   For toxic gases that are handled as refrigerated liquids at ambient pressure, if the released substance is not contained by passive mitigation systems or if the contained pool would have a depth of 1 cm or less, it is assumed that the substance is released as a gas over 10 minutes.  If the released substance is contained by passive mitigation systems in a pool with a depth greater than 1 cm, it may be assumed that the quantity is spilled instantaneously to form a liquid pool and the release rate to the atmosphere is calculated at the boiling point of the substance.  
The alternative case release scenarios for the regulated toxic substances were developed  
by WC based upon experience with the substances.  These scenarios are considered more likely to occur than the worst-case release scenarios.  However, the alternative case release scenarios are still considered unlikely to occur.  As part of its release prevention program, discussed in detail in the next section, WC is constantly monitoring, reviewing, and upgrading its standard operating procedures and equipment.  In addition, WC has developed a detailed Facility Emergency Response Plan (FERP) and individual Departmental Emergency Response Plans (DERPs) to minimize the effects of a release should one occur.  In addition to these administrative controls, WC has automatic release mitigation systems in place for the regulated substances, which are discussed below.   
With the exception of the worst-case scenario for phosgene, the distance to the toxic endpoint for the worst-case and alternative case scenarios for each substance was calculated using EPA's RMPComp computer modeling program 
.   The Dense Gas Dispersion (DEGADIS) model version 2.1 was used to calculate the distance to the toxic endpoint for the worst-case scenario for phosgene.   The RMPComp model is considered conservative and would generally give longer distances than computer model developed specifically for WC. 
 
Chlorine-Worst-Case and Alternative Case Release Scenarios 
Worst-Case Scenario 
The largest vessel of chlorine on-site is a 180,000 pound capacity railcar.  Since the chlorine contained in the railcars is a liquid under pressure, the worst-case release rate of chlorine to the atmosphere would be 18,000 pounds per minute.  The distance to the toxic endpoint for this scenario was calculated at 14 miles.   
Alternative Case Scenario 
A release scenario considered by WC to be more likely to occur than the worst-case scenario would be a break in a chlorine transfer pipe.  Under this scenario, 8.8 pounds of chlorine would be released to the atmosphere per minute for a period of 20 minutes.  The di 
stance to the toxic endpoint for this scenario was calculated at 0.1 miles.  To help minimize the effects of a release, WC has installed emergency shut-down systems, an emergency scrubber, excess flow valves and a foam system. 
Phosgene Alternative Case Release Scenario 
Alternative Case Scenario 
A release scenario considered by WC to be more likely to occur would be a valve stem leak.  Under this scenario, 0.005 pounds of phosgene would be released to the atmosphere per minute for a duration of 10 minutes.  The distance to the toxic endpoint for this scenario was calculated at 0.3 miles. In addition to dikes around the largest phosgene containing tank, WC has emergency shut-down systems, an emergency scrubber and a foam system that all help to minimize the effects of a release.  It should be noted that the EPA requires release rates below 0.1 pounds per minute to be rounded up to 0.1 pounds per minute.  For this reason, the RMP submittal form shows a release rate of 0.1 pounds per mi 
nute for the alternative scenario for phosgene.  
Titanium Tetrachloride Alternative Case Release Scenario 
Alternative Case Scenario 
A release scenario considered by WC to be more likely to occur would be a pipe leak.  Under this scenario, 0.000323 pounds of titanium tetrachloride would be released to the atmosphere per minute for an evaporation period of 3100 minutes.  The distance to the toxic endpoint for this scenario was calculated at 0.1 miles.  In addition to dikes around the largest titanium tetrachloride containing tank, WC has emergency shut-down systems, an emergency scrubber, and a foam system that all help to minimize the effects of a release.  For the reason discussed above, the RMP submittal form shows a release rate of 0.1 pounds per minute for the alternative scenario for titanium tetrachloride.  
 
Ammonia Alternative Case Release Scenario 
Alternative Case Scenario 
A release scenario considered by WC to be more likely to occur would be a pipe leak.  Under this sce 
nario, 1.25 pounds of liquid ammonia would be released to the atmosphere per minute for a period of 40 minutes.  The distance to the toxic endpoint for this scenario was calculated at 0.1 miles. In addition to berms around the largest tank of ammonia, WC has emergency shut-down systems, a water curtain system, and excess emergency storage to minimize the effects of a release. 
 
4. The general accidental release prevention program and chemical-specific prevention steps. 
This facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations.  The Prevention Program consists of 12 elements which will help the facility to minimize releases of regulated substances.  A description of each of the elements is given below: 
 
Employee Participation 
The Facility has involved employees in the development and implementation of the elements of Process Safety Management and the Prevention Program.  WC encourages employees to participate with the u 
nderstanding that their participation is a key factor to the success of any program. WC is committed to maintaining a safe workplace, and as a result all employees are responsible for adhering to the PSM/RMP regulations. WC has committed to the following: 
* Including employees from the process in Process Hazard Analyses 
* Consulting employees on the development of PSM/RMP regulation elements 
* Providing employees with access to the information developed through the PSM and RMP rules. 
A description of the Employee Participation Program is provided in the Process Safety Management central files.  The PSM Coordinator is responsible for ensuring the Employee Participation program is implemented. 
 
Process Safety Information 
WC provides company personnel with the necessary information about the process equipment to conduct their jobs in a safe manner.  A complete compilation of Process Safety Information (PSI) is made available to those involved in operating and maintaining the PSM/RM 
P regulated processes.  The PSI includes the following: 
* Hazards from chemicals used or produced by the process 
* Information pertaining to the technology of the process 
* Information pertaining to the equipment in the process. 
A manual containing the PSI for each regulated process is available in the PSM Central files.  The Supervisor of each area, in conjunction with the Manager of Process Assurance, is responsible for ensuring the PSI remains up to date.  
 
Process Hazard Analysis 
WC provides appropriate resources to make the working environment around regulated substances safe.  To assist in assuring a safe, controlled process, hazards are identified through the Process Hazard Analyses performed on each of the areas regulated by PSM/RMP. 
WC has performed Process Hazard Analyses (PHA) on each of the regulated processes. WC will update the hazard analysis at least every five years to assure that the PHA remains applicable to any process improvements and changes.  The level of 
detail in the PHA is intended to be appropriate to the complexity of the process. A copy of each PHA is available in the PSM Central files.  The Department Manager is responsible for scheduling the PHAs and notifying the supervisor of maintenance, engineering, and operations of the area.  The supervisors are responsible for ensuring appropriate representatives participate in the PHA.  The ongoing recordkeeping requirements for process hazard analysis are: 
 
   Documentation that shows the recommendations from the PHA are resolved in a timely     manner 
   Documentation that shows what actions are to be taken as a result of the PHA; a written     schedule of when these actions are to be completed; communication of these actions to     operating, maintenance and other employees whose work assignments are in the process     and who may be affected by the recommendations or actions 
   Document that all PHA's are updated at least every five years. 
 
Standard Operating Procedures 
WC provides appropriate 
resources to insure personnel have the knowledge necessary to make the working environment at the facility safe.  To assist in assuring the safety of employees, the surrounding community, and the environment, operating procedures have been completed for each regulated process.  In conjunction with operating personnel, WC has developed and implemented written operating procedures, available in the operating manuals, which provide clear instructions for safely conducting activities involved in each of the PSM/RMP regulated processes.  Employees who work in or maintain the process utilize the procedures.  The procedures address all operational phases, and are reviewed at least annually to ensure they remain up to date.  Copies of the Standard Operating Procedures are available in the corresponding control rooms.  The Manager of Process Assurance is responsible for notifying the supervisor of the process area the date by which the SOP needs to be re-certified.  The supervisor of the proce 
ss is responsible for ensuring the manual is reviewed and certified annually.  The ongoing recordkeeping requirements for the standard operating procedures are: 
 
   Proof of certification annually that the standard operating procedures are current and     accurate. 
 
Training 
WC provides the appropriate resources to ensure adequate training of personnel involved in operating the regulated processes and to ensure that the jobs can be performed safely.  The training program includes initial training, refresher training, and training documentation. 
 
Employees currently involved in operating a regulated process and employees being transferred into a regulated process are trained in an overview of the process and in the standard operating procedures.  This initial training also includes emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. 
 
Refresher training is provided at least every  
three years to employees involved in operating a regulated process to assure that the employee understands and adheres to the current standard operating procedures of the process. 
 
WC verifies that each employee involved in operating a regulated process has received and understood the required training.  A record will be prepared that contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training. 
The training programs and documentation are available through the individual departments.  The area supervisors are responsible for ensuring employees in their area are appropriately trained.  The ongoing recordkeeping requirements for training are: 
 
   A written record that contains the identity of the employee, the date of training, type of training, and the means used to verify that the employee understood the training. 
 
Contractors 
WC periodically uses contractors to perform work in and around processes that involv 
e regulated substances.  To ensure safety, WC has developed a Contractor Program to inform and manage contract employees working in the PSM/RMP regulated systems.  The Contractor Program has been developed to establish a screening process so that WC hires and uses contractors who have a commitment to safe work practices. 
The contractor program includes all activities that have the potential for affecting process safety, including the performance of maintenance or repair, turnaround, equipment installation, renovation, demolition, or specialty work on or adjacent to the PSM/RMP regulated processes.  A facility wide Contractor Program is available in the Engineering Department. 
 
Pre-Startup Safety Review 
WC ensures a new or significantly modified facility in a regulated process is as safe as possible before starting the system.  To assist in assuring safety, a Pre-Startup Safety Review (PSSR) is performed before regulated substances are introduced to the system.  The PSSR verifies th 
e following information: 
* Training is complete 
* SOPs are complete 
* Construction/equipment is in accordance with the design specifications 
* A PHA has been complete, if it is a new facility 
Records of the PSSRs and procedures are available in the Safety Office.  The supervisor of the area/ construction project leader is responsible for ensuring a PSSR is performed.  
 
Mechanical Integrity 
WC provides appropriate resources to ensure that the equipment used to process, store, or handle highly regulated substances is designed, constructed, installed, and maintained to minimize the risk of releases of the regulated substances into the workplace or community.  To accomplish this goal, a Mechanical Integrity Program is in place to ensure the continued integrity of the processes.  The Mechanical Integrity Program is implemented for the systems that could potentially result in the release of a hazardous chemical.  The program utilizes increased maintenance training, and preventive mai 
ntenance in conjunction with regular inspections and tests, to ensure equipment is in satisfactory condition.  A summary of the Mechanical Integrity Program is found in the PSM Central Files with more details located in the maintenance shop.  The ongoing recordkeeping requirements for the mechanical integrity testing program are: 
 
   Documentation showing each inspection and test that has been performed on process     equipment.  The documentation shall identify the date of the inspection or test, the name     of the person who performed the inspection or test, the serial number or other identifier of     the equipment on which the inspection or test was performed, a description of the     inspection or test performed, and the results of the inspection or test. 
 
Hot Work/ Safe Work 
The objective of the WC Hot Work Permit is to consistently control hot work conducted in the process areas.  The Hot Work Permit System is specifically concerned with the permitting of hot work operations associated  
with welding and cutting on or near PSM/RMP regulated process areas.  The permits document compliance with the fire prevention and protection requirements. 
Additional safe work practices such as lockout/tagout, confined space entry, and control over entrance are also implemented to increase facility safety. 
 
The ongoing recordkeeping requirements for the hot work/safe work programs are: 
 
   Copies of the hot work permit showing: that the fire prevention and protection requirements in 29 CFR 1910.252(a) are in place prior to beginning the hot work operations; the date(s) authorized for hot work; and the object on which hot work is to be performed.  The permit is kept on file until completion of the hot work operations. 
 
Management of Change 
WC manages all changes to processes regulated by PSM or RMP to ensure the processes are operated and maintained as safely as possible.  To assist in accomplishing this goal, a Management of Change Program is in place.  Management of Change exam 
ines any type of change that is planned for the process, and the basis of the change. 
The Management of Change Program is designed to evaluate, approve and administer changes to PSM/RMP regulated processes to assure any changes implemented enhance the operation and safety of the system.  A description and procedures for the Management of Change Program can be found in the PSM Central Files.  The Area Manager is responsible for ensuring all MOC forms are complete.  The ongoing recordkeeping requirements for management of change are: 
 
   Copy of the written procedures to manage changes (except for "replacements in kind") to     process chemicals, technology, equipment, and procedures; and, changes to stationary     sources that affect a covered process 
 
   Best Management Practice Documents: process control change documents. 
 
Incident Investigation 
It is the policy of WC to investigate any incident that occurs in a process regulated by PSM or RMP, which could have or did result in a catast 
rophic release of a hazardous chemical in the workplace.  The Incident Investigation policy, procedures, and records of the Incident Investigations are available in the Safety Office. 
 
Compliance Audits 
Compliance audits are utilized to evaluate the effectiveness of the PSM/RMP programs that are implemented at WC's Facility.  The compliance audit is intended to identify any deficiencies or weaknesses in WC's policies, programs, or procedures, and take action to correct the deficiencies.  A compliance audit is performed at least every three years to verify that the systems required by the PSM and RMP Regulations are in place and have been implemented.  The regulations require that the previous two compliance audits be kept on file.  This documentation and the Compliance Audit procedures are available in the Manager of Process Assurance's Files.  The ongoing recordkeeping requirements for compliance audits are: 
 
   Certification that compliance with the provisions of the prevention pr 
ogram has been evaluated at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed 
 
   Internal audit files. 
 
Summary of Recordkeeping Requirements for the Prevention Program 
The following is a summary of the ongoing recordkeeping requirements for the prevention program.  
 
Process Hazard Analysis 
 
   Documentation that shows the recommendations from the PHA are resolved in a timely     manner. 
   Documentation that shows what actions are to be taken as a result of the PHA; a written     schedule of when these actions are to be completed; communication of these actions to     operating maintenance and other employees whose work assignments are in the process     and who may be affected by the recommendations or actions. 
   Document that all PHA's are updated at least every five years. 
 
 
Standard Operating Procedures 
 
   Proof of certification annually that the standard operating procedures are current and     accurate. 
 
 
Training 
 
   A written record that contains the identity of the employee, the date of training, types of training and the means used to verify that the employee understood the training. 
 
Mechanical Integrity 
 
   Documentation showing each inspection and test that has been performed on process     equipment.  The documentation shall identify the date of the inspection or test, the name     of the person who performed the inspection or test, the serial number or other identifier of     the equipment on which the inspection or test was performed, a description of the     inspection or test performed, and the results of the inspection or test. 
 
Hot Work/ Safe Work 
 
   Copies of the hot work permit showing: that the fire prevention and protection requirements in 29 CFR 1910.252(a) are in place prior to beginning the hot work operations; the date(s) authorized for hot work; and the object on which hot work is to be performed.  The permit is kept on file until completion of the hot work operation 
s. 
 
Management of Change 
 
   Copy of the written procedures to manage changes (except for "replacements in kind") to     process chemicals, technology, equipment, and procedures; and, changes to stationary     sources that affect a covered process 
 
   Best Management Practice Documents: process control change documents. 
 
Compliance Audits 
 
   Certification that compliance with the provisions of the prevention program are evaluated at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed 
 
   Internal audit files. 
5. The five-year accident history 
During the past five years, the WC Facility has had only one reportable accident.  WC emphasizes safety in the work place and takes pride in their safety record.  WC was the first OSHA Star facility west of the Mississippi River, however, the State of Oregon has since discontinued this program. The reportable accident is described below. 
The accident occurred in Dec 
ember of 1995.  A process vaporizer developed a leak due to the corrosion of wet chlorine.  Under normal conditions the chlorine used in this process is dry.  Approximately 400 pounds of chlorine were released.  A worker in a nearby work station was exposed to the chlorine and had to be taken to the local hospital for evaluation.  Approximately $50,000 dollars in property damage was sustained as a result of this accident.  The equipment has since been upgraded and improved and the process has been changed to prevent a similar situation from occurring in the future. 
6. The emergency response program 
WC has developed and implemented an emergency response program for the purpose of protecting public health and the environment.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
 
To ensure proper  
functioning, the emergency response equipment is regularly inspected and serviced.  In addition, the plan is promptly updated to reflect any pertinent changes taking place within the covered processes that would require a modified emergency response. 
 
A 24 hour a day Senior Emergency Response Official is assigned to respond to any accidental release, should one occur.   
 
The emergency response plan, which is maintained at the facility, contains the following elements: 
 
   Procedures for informing the public and local emergency response agencies about     accidental releases. 
   Documentation of proper first-aid and emergency medical treatment necessary to treat     accidental human exposures. 
   Procedures and measures for emergency response after an accidental release of a     regulated substance. 
   Procedures for the use of emergency response equipment and for its inspection, testing,     and maintenance. 
   Training for all employees in relevant procedures. 
 
   Procedures to review and update, 
as appropriate, the emergency response plan to reflect     changes at the stationary source and ensure that employees are informed of changes. 
   A written plan that complies with OSHA and EPA Planning, Preparedness, Response and training requirements. 
   The emergency response plan is coordinated with the community emergency response plan.  Upon request of the local emergency planning committee or emergency response officials, promptly provide to the local emergency response officials information necessary for developing and implementing the community emergency response plan. 
    Training with local emergency response agencies and local emergency care providers. 
 
7. Planned changes to improve safety 
Several developments and findings have resulted from the implementation of the various elements of PSM and RMP.   Noted below are some of the major steps we want to take to improve safety at the facility.  These changes are under consideration. 
 
* A study of ways to minimize or eliminate p 
hosgene in crude silicon tetrachloride storage tanks.  
* Courtyard scrubber at Sand Chlorination 
* Improved scrubber at Pure Chlorination   
 
Several changes have been made to processes as a result of PSM and RMP program reviews: 
 
* Deleted anhydrous ammonia and replaced with 28% ammonia. 
* Deleted sulfur dioxide and replaced with first 50% hydrogen peroxide and then replaced 50% hydrogen peroxide with sodium sulfite. 
* Replaced existing chlorine railcar unloading station and vaporizers with a new chlorine railcar unloading station with vaporizer/super-heater, such that the chlorine in pipes is largely limited to gaseous chlorine, not liquefied chlorine as in the past.  
* Eliminated use of one-ton Cl2 tank in water treatment system 
* Eliminated use of 70% hydrofluoric acid  
 
8. Certification Statement 
 
 
 
 
Re-Submission Certification Statement 
EPA Facility Identifier - 1000 0010 2925 
                
To the best of my knowledge, information, and belief formed after reasonable inq 
uiry, the information contained in this plan is true, accurate, and complete. 
 
            
Signature        Printed Name 
 
            
Title        Date 
 
 
 
 
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