Rogers Metal Services, Inc. - Executive Summary |
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Risk Management Plan Rogers Metal Services; Skokie Illinois. Executive Summary: Approach to Chemical Safety and Accident Prevention: Rogers Metal Services is a specialized metal brazing facility located in Skokie, Illinois. The facility has been operating for over 39 years at this location. The company management is totally committed to employee safety and adherence to regulations ensuring the safety of the surrounding community. The facility is staffed with a well-trained and experienced work force. This is evidenced by the fact that the average employee has been with the company for more than seven years. A strong message is given to all employees that "Safety comes first and, if you cannot do something safely, do not do it". Safety procedures and policies are also strictly followed by all contract employees working on the site. The Company backs up its commitment to safety by developing and implementing operating procedures for all critical operations and communicating hazards of the processes and chemicals used through Hazard Communication Programs. The company has ongoing safety programs implemented with the help of specialized consultants. Over the past several years, the Company has critically evaluated raw materials used in the process and successfully eliminated several hazardous chemicals by substituting with safer and more environmentally friendly materials. Safety programs are implemented under the direct supervision of the facility owner and operator. Facility Description: Rogers Metal Services, located at 7330 N. Monticello Avenue in Skokie, Illinois, is a specialized metal brazing facility. The facility treats similar and dissimilar parts with braze material like copper or silver alloys and fuses them together. Brazing material is applied to the parts and they are passed through one of the several furnaces. It is required to maintain a protective atmosphere inside the furnace to prevent oxidation and finishing defects of brazed parts. The protective atmosphere is provided by introducing dissociated anhydrous ammonia gas into the furnace. Anhydrous ammonia at high temperature and in the presence of catalyst breaks down to 75% Hydrogen and 25% Nitrogen gas, which provides a proper protective atmosphere for this type of application. Heat treating of metals in an atmosphere of dissociated ammonia is a well established technology and has been common practice for many years. Hazards that may be associated with this process involves storage and handling of Anhydrous Ammonia and the generation of hydrogen gas, which under adverse conditions, can be explosive and flammable. Rogers Metal purchases and stores Anhydrous Ammonia in bulk quantities. The maximum inventory of Anhydrous Ammonia stored at this site is approximately 17,000 lbs. Anhydrous Ammonia is received in bulk trucks twice monthly, and always on week days and during normal business hours only. Most people have encountered ammonia in common house hold cleaners or as a smelling salt and can recognize its strong, pungent odor. Ammonia occurs naturally and is very important to animal and human life. Though eighty percent of all man-made (manufactured) ammonia is used as a fertilizer, most of the ammonia in the environment comes from natural breakdown of manure , dead plants and animals. Ammonia is also extensively used as a refrigerant in the industry since the 1880's. Ammonia is potentially hazardous chemical and it must be treated with respect. The most likely way to get exposed to ammonia would be to breathe the fumes from spilled ammonia. For example, if you spilled a bottle of concentrated ammonia in your house and had to breathe the fumes while cleaning up, you might experience the symptoms of coughing and burning, watery eyes because of irritation. Exposure to high concentration of ammonia could cause burns to the skin, eyes, throat and lungs. At worst, these burns could be serious enough to be life threatening. Usually the odor of ammonia will alert people to its presence before a concentration resulting in serious injury could be reached. During routine operations, the amount of dissociated ammonia (consisting of 75 % Hydrogen Gas and 25 % Nitrogen Gas) is not present in large enough quantities so as to have off site impact in case of fire or explosion. The Worst- Case Release Scenario and the Alternative Release Scenario: The worst case release scenario would occur with the accidental release of the maximum stored inventory (i.e. the entire tank) of anhydrous ammonia. Anhydrous ammonia at Rogers Metal is stored in a bulk tank outside at the back of the facility. The tank is located next to an alley where there is very little vehicular traffic. For the extremely unlikely event that an accident can occur, it would be if a vehicle backs into the tank causing a rupture and release of the liquified ammonia stored inside the tank in a matter of minutes. The tank is barricaded and steel b ump posts are installed around it. The tank is clearly labelled, prominently displaying the description of the contents of the tank, and indicating that it is hazardous. In the event of a tank rupture, there will be offside impact of the toxic chemical release. The released ammonia fumes will travel primarily in the direction of the wind. The distance of travel depends on the weather conditions. Ammonia concentration may be significant so as to warrant a evacuation of population located in the direction of the wind. Release modelling is done based on EPA's RMP *Comp software. In a less severe but most likely situation referee to as a alternative scenario, a release can occur from a leak in the pipe or fitting supplying ammonia to the process or from the tank itself. Any release of this nature will be handled by directing a water spray from a spray nozzle located on top of the tank.. Attempt will also be made where feasible to isolate and shut the source of the leak. A releas e of this nature can go on for a longer duration and may impact immediate surrounding population and appropriate measures for evacuation will have to be taken if deemed necessary. General Accidental Release Prevention Program This facility is subject to OSHA Process Safety Management rules as stipulated in 40 CFR Section 1910.119. In compliance with these regulations, Rogers Metal has implemented all aspects of PSM regulations. Written information is available to employees involved in operating the process to identify and understand the key hazards posed by ammonia storage and use, and the use if the dissociated byproduct gases. The information includes items describing the hazards of ammonia, the technology used in the design and construction of ammonia systems and specific equipment. Process Hazard Analysis is performed with the involvement of key employees to systematically study and identify the hazards associated with ammonia storage and use. Written operating procedures are available to operate equipment safely. Training programs are in place to ensure all employees are adequately trained in safe operating, maintenance, and shutdown procedures. All contractors working on the site must go through a Contractor Safety Orientation Program and Reviewing the Safety Rules and Regulations applicable to this facility. The other key elements of the PSM that have been implemented involves Pre-Start Up Reviews, Mechanical Integrity Inspections, Hot Work Permitting, Management of Change, Incident Investigation, Emergency Planning and Response and Compliance Audits. Five Year Accident History The facility had no lost time accidents in the past five years. The safety record of the facility is excellent, with no injury or accidental release involving ammonia gas. Emergency Response Program The Facility has updated its emergency response plan to include response procedures in the event of accidental release of ammonia. As required, various scenarios have been analyzed. A survey of the surrounding community has been performed and a list of address and contact numbers have been generated. In the event of a release having offside impact, the facility will work with the HAZMAT team of the Skokie Fire Department to control the emergency and protect the surrounding community. Notification will be done through the local police and fire department in case evacuation becomes necessary. The Facility has identified public receptors in the area of potential impact and the information will be included in the emergency response plan. A copy of the emergency response plan will be available with the local fire department. Plant Emergency Organization structure has been summarized and Emergency Coordinators who have received training in implementing the emergency response plan are identified and listed. Planned Changes to Improve Safety Rogers Metal is been working constantly to improve safety. After meeting with HAZMAT team of Skokie Fire Department in May, 1999, the Company has agreed to provide them with an Ammonia Detector and Freeze Protection Gloves to better equip them to respond to emergency situations. An updated Emergency Response Plan including copy of the MSDS will be available in the NOX box to facilitate easy access at all times. The company co-hosted an emergency exchange information meeting with neighboring industries. The objective was to inform all interested parties of the potential hazards associated with the operations at Rogers Metal and to identify a joint approach to emergency response. Officials from the Skokie and Lincolnwood fire departments attended the meeting. It is planned to continue this type of meetings in the future. |