BOC Edwards - Phoenix - Executive Summary

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The BOC Gases Phoenix facility, owned and operated by The BOC Group, Incorporated is located at 1122 North 52th Street, Phoenix, AZ  85008. The management and employees of the Phoenix facility are committed to the prevention of any accidental releases of anhydrous hydrogen chloride.  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 storage and distribution of anhydrous hydrogen chloride. Hydrogen chloride is received and stored in high pressure tube trailers that contains 3,000 pounds of anhydrous hydrogen chloride in each tube.  The hydrogen chloride is then distributed into various DOT containers such as cylinders. 
 
The worst-case scenario, based on the EPA's definition for a toxic gas release, would be the rupture of  a high pressure tube that contains a maximum of 3,0 
00 lb . The results would be a maximum release of 3,000 lbs of refrigerated anhydrous hydrogen chloride over a 10 minute period. 
 
The endpoint of 0.03mg/L (EPRG-2 Level) was determined to be 2.4 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 45,953 residents and several special receptors which  the Arizona state Sanitarium, Arizona State Hospital Farm and several schools based on the 1990 US Census data obtained from "Land View III".  Many business and industries are also within the endpoint which includes Motorola Semiconductor Complex. The environmental receptors that are affected are Papago Park which contains the Phoenix Zoo, Desert Botanical Gardens and Gov. Hunt Tomb.  No passive/active mitigation or administrative controls were considered in this assessment. 
 
The alternative release, or more probable, 
scenario which was determined involved the rupturing of the fill line during filling of a 600 lb DOT container. This release would result in the maximum release of 600 lb anhydrous hydrogen chloride at a rate of 10 lb/min. 
 
The release endpoint of 0.14mg/L (EPRG-2) was determined to be 0.10 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 several public receptors and businesses based on actual observations. They would include the Motorola Semiconductor Complex, several smaller businesses. 114 residents were affect by this scenario based on the 1990 US Census data obtained from "Land View III". No passive or active mitigation systems were considered. 
 
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 line 
s, a preventive maintenance schedule for the system, safeties and testing of the DOT containers. 
 
The facility has developed a comprehensive prevention program designed to prevent accidental releases of hydrogen chloride.  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 hydrogen chloride system to enable managers, supervisors, and employees 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 hydrogen chloride.  
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 November  9, 1996 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 3/4/99 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 comm 
unication 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 to 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 March 4, 199. 
 
A contractor sc 
reening 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 February 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 recommendations 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 2/10/99. 
 
An on-going mechanical integrity program (maintenance) is used to ensure safe process operations. Equipment used to store, process, or handle hydrogen chloride 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/inspection results, and documentation of manufacturer's recommendations to prevent failure of equipment and instrumentation. This program was review on 2/8/99. 
 
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 February 1999 for both employees and contractors. 
 
Management of Change (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 per 
sonnel 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 February 9, 1999. 
 
Process incidents which result in or could reasonably have resulted in a release of hydrogen chloride 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 mistakes.  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 hydrogen chloride.  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 January 1999 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 effectiveness 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 ste 
p 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 hyd 
rogen chloride safety recommendations for implementation at this time.
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