Transbas Inc. - Executive Summary |
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PURPOSE This document provides for control of the executive summary information to be included in the Risk Management Plan (RMPlan) submittal to the Environmental Protection Agency (EPA). The executive summary identifies hazards associated with operation of Transbas Inc. and describes practices in place to mitigate those hazards. This information is available to local emergency respose groups. It is also available to the public in limited form. This document also provides for control of other information required to be submitted in the Risk Management Plan. This document should be reviewed for required changes whenever the RMPlan is updated. REFERENCES Department of Labor (OSHA), 29 CFR part 1910.119, Process Safety Management of Highly Hazardous Chemicals, February 24, 1992 Environmental Protection Agency's (EPA) Risk Management Program Rule, 40 CFR part 68, Final Rule, June 20, 1996 PROCEDURE How Coverage was Determined for Transbas Dimethylamine and isopropylamine are bo th listed in the RMP rule and are stored above the threshold quantity at Transbas. EPA's lookup tables were used in modeling the worst case and alternative release scenarios. EXECUTIVE SUMMARY Stationary Source Description and Use of RMP Regulated Substances Transbas, Inc. (Transbas) is located in Section 26, Township 1 North, Range 26 East in Yellowstone County, Montana and encompasses approximately 27 acres. Transbas is a subdivision of United Agri Products (UAP), which is a subsidiary of ConAgra, Inc. Transbas operates a herbicide formulation facility which blends and reacts raw phenoxyalkanoic acid herbicides with alcohols, solvents, amines or water to produce finished products. Dimethylamine(DMA) and isopropylamine(IPA) are used to produce herbicides through the amination of phenoxy acids. The DMA amination process consists of a 60% aqueous solution of DMA along with a bulk phenoxy acid solid in a batch process creating a liquid finished herbicide. The Savage process am inates with anhydrous, DMA and produces a bulk solid herbicide. The IPA amination process uses a 50% IPA aqueous solution to aminate active ingredients and forms batches of technical material used in the production of non-RMP covered liquid herbicides. WORST-CASE SCENARIO (WCS) The worst-case scenario (WCS) associated with a flammable substance at Transbas is the complete inventory release in 10 minutes of a full 50% concentrate isopropylamine storage tank (185,520 lbs.). Although controls are in place to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures were taken into account in evaluating this scenario. The maximum distance to the worst-case flammable endpoint is 0.422 miles (2228 feet). The real life preventative measures which are not considered in the WCS evaluation, are as follows : * Engineering approved materials of construction for 50% IPA storage * Nitrogen purge preventing IPA vapor release to atmospere and eliminating static air in the tank * Safety relief device on the 50% IPA storage tank * Maintenance and inspection programs to monitor equipment integrity * In-house operating and startup procedures * Operator observation for quick response * Inventory minimization during non-IPA production periods which is the majority of the year With these practices in place, Transbas considers the complete release of a full 50% IPA storage tank to be a low probability. ALTERNATIVE RELEASE SCENARIO (ARS) The alternative release scenario (ARS) for a flammable substance at Transbas is the rupture of a gasket on the 60% DMA line from the 60% DMA tank to the plant and emptying an entire line (2465 lbs. of mixed product) in 5 minutes. The maximum distance to the flammable endpoint for the ARS is 0.072 miles (382 feet). Accident prevention measures in-place to minimize the 60% DMA release include: * Engineer approved materials of construction for 60% DMA and pressure * Maintenance and inspection programs to monitor equipment integrity * In-house operating and startup procedures * Operator and instrumentation observation Although these measures are in place and the likelyhood of this ARS happening is low, Transbas personnel selected this scenario to be the most probable to occur. GENERAL ACCIDENT PREVENTION PROGRAM STEPS The following is a summary of the general accident prevention program in place at Transbas. Processes regulated by the EPA RMP regulation are also subject to the OSHA PSM standard. This summary a ddresses the OSHA PSM elements applicable to RMP and describes the management system in place to implement the accident prevention program. The administrative procedures used for process safety management have been revised to incorporate all RMP required items and these procedures are now considered PSM/RMP administrative procedures. EMPLOYEE PARTICIPATION Transbas encourages employees to participate in plant safety. PSM/RMP elements include employee participation through writing and updating operating and maintenance procedures, compiling process safety information and participating in process hazard analysis'. Additionally, employee's have been instructed to come forward with their safety concerns. Process' that fall under RMP requirements already are subject to PSM requirements. Programs are in place that address both PSM and RMP regulations. All PSM/RMP materials are available to employees. PROCESS SAFETY INFORMATION (PSI) Transbas PSI package is a compilation of inform ation about the technology, hazards and equipment of PSM/ RMP covered processes. Transbas PSI consists of the 12 following sections: 1. The PSI administrative procedure 2. Process Description - a description of the process purpose and major processing steps. The function of all major equipment is described, along with the interactions between the equipment. 3. Process Chemistry - qualitative chemical reaction descriptions are provided. 4. Process Flow Diagrams - provides pertinent information necessary to understand process basics. Diagrams in this section indicate major process equipment, flow directions, pressures, temperatures, and instrument components. 5. Maximum Intended Inventory- identifies major pieces of equipment in the process, and qualifies the maximum normal inventories of PSM/RMP covered chemicals that can be expected within this equipment. 6. Safe Operating Limits - identifies safe upper and lower operating limits for process control variables within the PSM/RMP covered process. Control variables include pressure, flow, level, composition and temperature. This section also includes clear consequences of deviation from the safe upper and lower limits as well as the actions to prevent or correct conditions outside of the operating limits. 7. Chemical Hazard Information - lists the chemicals within the PSM/RMP covered processes, along with information pertaining to the hazards of these chemicals. 8. Inadvertent Mixing Information - outlines the consequences of inadvertently mixing chemicals utilized in the PSM/RMP covered processes. This section includes reactant names, conditions of reaction, results of reaction, likelihood of occurring, steps for handling the reaction, and safeguards to prevent the reaction. 9. Piping and Instrument Diagrams (P&ID's)- includes all equipment components , piping sizes and flow directions, valve size and type, presence of insulation and heat tracing, auxilary connections, utility connections, and instrument identification symbols. 10. Process Equipment Data - includes subsections with the following: equipment summaries, piping design schedules, relief system design, mechanical and instrument safety systems, electrical area classification, ventilation system design and fire safety systems. 11. Supporting Documentation - includes subsections with the following: engineering standard documentation, equipment drawings and relief system calculations. 12. References Additionally, complete files on PSM/RMP covered equipment are located in mechanical integrity documentation. PROCESS HAZARD ANALYSIS (PHA) Transbas has a comprehensive program to help ensure that hazards associated with the various units within our process are identified and controlled. Within this program, each unit is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The techniques Transbas uses in its PHAs are the "What-if Checklist" and hazard and operability study (HAZOP) analysis for specific nodes. The HAZOP technique is one of the most systematic and thorough hazard evaluation techniques available. All PHAs are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process and makes recommendations for additional prevention and safety measures or design changes when the team believes such actions are necessary. Local management reviews the PHA Team recommendations, and employees are assigned accountability to resolve all recommendations that have been made by the PHA team and accepted by local management. Implementation of recommendations in response to PHA findings is based on a relative risk ranking assigned by the PHA Team. This ranking helps ensure that potential accident scenarios are assigned the highest risk ranking and thus receive immediate attention. All approved recommendations being implemented in response to PHA Team findings are tracked until they are complete. The final resolution of each finding is documented and retained. Upon competion of all recommendations for a specific PHA, a final report is issued that all affected employees can access, thus having knowledge that all the recommendations for the PHA have been resolved. To insure process safety at Tra nsbas, each process is required to have a PHA revalidation every five years. Additional details, including management responsibilities, can be found in the refinery Process Hazard Anaysis, (PSM-ADM-04) procedure. OPERATING PROCEDURES Transbas maintains written operating procedures for normal operations and emergency procedures. Startup and shutdown procedures are included in the normal operating procedures since we produce in batches. Emergency procedures include the assignment of responsibility of shutdown and startup procedures. Included in the operating procedures is guidance on how to respond to upper or lower limit exceedances for specific process steps or equipment parameter deviations. These procedures are used by operators and are used in the training of new operators. All procedures are reviewed at least annually by the area supervisor. Whenever a change is required the management of change procedure is initiated. Operating procedures are readily available to the ope rators in the process unit and for other personnel to use as necessary to safely perform their tasks. Additional information, including management responsibilities can be found in PSM-ADM-05 of the PSM administrative procedure. TRAINING To complement the written procedures for process operations, Transbas has implemented a comprehensive training program for employees involved in operating a process. New employees receive basic training in operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. When new operators can demonstrate through tests or skills demonstration that they have the knowledge necessary to perform the duties and tasks in a safe manner, they may be qualified for a job position and allowed to work independently. In addition, all operators are updated when ever a process change occurs and are periodically given refresher training on the operating procedures. Additional information, including management responsibilities can be found in PSM-ADM-06 of the PSM administrative procedure and Transbas Written Safety Plan. CONTRACTORS Transbas uses contractors to supplement its workforce for peak production periods and for specialty work. Procedures are in place to ensure contractors perform their work in a safe manner, have the appropriate knowledge and skills, are aware of the hazards in their workplace, understand what they should do in the event of an emergency, and understand and follow site safety rules. Contractors are orientated on site safety and health hazards, task safety and health hazards, emergency response and evacuation information, safe work practices for the site and their duties, a process overview and a site overview. Part of Transbas' contractor program is a safety performance review of a contractor prior to hiring a contractor and monitoring the performance of the contractor while working at Transbas to ensure safe work practices a re being observed. If a contractor is not fulfilling his/her safety obligations, Transbas will request the contractor come into compliance or dismiss the contractor. Additional information, including management responsibilities, may be found in PSM-ADM-07 of the PSM administrative procedure. PRE-STARTUP SAFETY REVIEWS (PSSRs) Transbas conducts a PSSR for any new process or a process modification. The purpose of the PSSR is a final check to ensure safety features, procedures, personnel, and equipment has been preparred for the change. The PSSR checklist verifies all aspects of readiness and serves a quality assurance function. Additional information, including management responsibilities, may be found in PSM-ADM- 08 of the PSM administrative procedure. MECHANICAL INTEGRITY (MI) Mechanical integrity systems are maintained and documented at Transbas for all PSM covered Pressure vessels, exchangers, columns and tanks Piping and piping com ponents Relief devices Pumps Instrumentation/controls Emergency systems The MI program includes training, mechanical activity procedures, inspections and tests, correcting identified deficiencies and quality assurance measures. Aspects of the mechanical integrity program were designed to comply with all government and manufacturer requirements. Maintenance training includes process overviews, safety and health hazards, applicable maintenance procedures, emergency response plans and safe work practices. In the case of an equipment deficiency, employees will correct the deficiency prior to placing the equipment back into service or a team will review the equipment use and determine what actions are necessary to ensure safe operation of the equipment. Equipment that cannot be safely operated will be kept out of service until the deficiency is corrected. Quality assurance measures are incorporated in equipme nt purchases and repairs to make certain new equipment is suitable for its intended use and proper materials/parts are used when repairs are made. Additional MI information, including management responsibilities, may be found in PSM-ADM-09 of the PSM administrative procedure and our mechanical integrity manual. SAFE WORK PRACTICES (SWP) Transbas safe work practices include but are not limited to: Hot work authorization, permitting and training Lockout/Tagout authorization, permitting and training Incident reporting and reviews with employees Air monitoring and reviews with employees Contractor orientation Confined Space authorization, permitting and training Personal Protective Equipment reviews and training HazCom programs and training Housekeeping training Emergency evacuation training These procedures and other safety procedures may be found in Transbas Written Safety Plan. MANA GEMENT OF CHANGE (MOC) Transbas MOC program requires changes to process equipment, chemicals, technology, operating procedures and other process changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure adequate controls are in place to manage any new hazards, verify existing controls have not been compromised, and identify changes that need to be made for safe process operations. Once any identified changes are made, Transbas' PSM is updated and employees involved in or near the process are provided training on the change. Additional information, including management responsibilities may be found in PSM-ADM-11of Transbas PSM administrative procedure. INCIDENT INVESTIGATION Transbas investigates all incidents that activates Transbas emergency response system or could potentially of resulted in a fire/explosion, major property damage, environmental loss or personal injury. The incident investigation is conducted by a team that reviews the event, documents its findings, develops corrective actions to prevent a repeat incident. Once the investigation is complete, employees and contractors are made aware of the incident findings and the actions that will be taken to prevent future like incidents. Incident investigation reports are retained at least 5 years and are included in Transbas PHAs. Additional information about Transbas incident investigation process may be found in PSM-ADM-12 of Transbas PSM administrative procedure. COMPLIANCE AUDITS Transbas PSM audit includes field verification of actions, policies, and required documents to ensure actual practice and compliance with the PSM Compliance Plan. The PSM Audit Team will verify whether materials needed to support each audit element are in place and up-to-date. Upon completion of the audit, the PSM Audit Team and management reviews the findings and any items requiring follow-up will be assigned to appropriate personnel and a completion date will be assigne d. The audit and followup actions will be maintained in Transbas PSM compliance files. Additional information, including management responsibility, may be found in PSM-ADM-14 of Transbas administrative procedure. TRADE SECRETS Although confidentiality agreements may be required at Transbas, trade secrets will never be allowed to interfere with the dissemination of information required for ensuring the safety of employees, contractors, customers and members of the public. All process information needed by employees or contractors to safely perform their job assignments shall be made available without regard to possible trade secret status. Additional information on trade secrets, including management responsibility, may be found in PSM-ADM-15 of Transbas administrative procedure. FIVE-YEAR ACCIDENT HISTORY No incidents have occurred at Transbas that have resulted in offsite impact and no onsite accidental releases have occurred that require reporting in our accident history. EMERGENCY RESPONSE PROGRAM INFORMATION Transbas maintains a contingency plan in compliance with 40 CFR Parts 264 and 265, Subpart D. Related emergency planning requirements covered are 29 CFR Part 1910.38(a), Employee Emergency Plans 29 CFR Part 1910.119, Process Safety Management of Highly Hazardous Chemicals 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response 40 CFR, Part 68, Risk Management Program Rule 40 CFR, Part 112, Oil Spill Prevention Control and Countermeasures Transbas' Contingency Plan along with Transbas' Preparedness and Prevention Plan are designed to minimize emergencies which could threaten human health or the environment. The provisions of the Contingency Plan are immediately implemented whenever there is a fire, explosion, or release of hazardous material or hazardous waste which could harm personnel on the Transbas site, endanger the neighboring community o r cause damage to the environment. Arrangements have been made with Lockwood Rural Fire District #8 to take the lead if an emergency occurred. Other organizations that have agreed to respond in the event of an emergency are Yellowstone County Sheriff Department, Saint Vincent's Hospital and Health Center, Deaconess Medical Center of Billings, Montana Department of Environmental Quality, Montana State Disaster and Emergency Services Division, U.S. EPA (Region VIII, Montana Office), City of Billings Fire Department, Unifield Engineering and Great Northern Equipment. Each of these services are notified and provided updated emergency plans whenever a modification occurs. The contingency plan and preparedness and prevention plan are accessible to all employees. Every employee and contractor is familiarized with the plant alarm system, evacuation procedures and how to perform any assigned responsibility or duty. Periodic evacuation drills are conducted to refresh workers on alarms and evacuation procedures. Whenever a change is made to either emergency response document, Transbas employees and contractors are notified and trained(if necessary) on the change. In the event an incident threatens to go beyond Transbas' boundaries, neighboring facilities would be contacted and if needed the community warning siren system would be activated. The Yellowstone County Local Emergency Planning Committee (YC-LEPC) has coordinated programs along with industry to address public notification, emergency response procedures and emergency medical procedures in the event an incident threatens the community. PLANNED CHANGES OR CHANGES MADE TO IMPROVE SAFETY Management plans for improving plant safety include: 1. Attaining ISO 9002 certification to improve the quality of operations. Transbas includes environmental and safety compliance in its ISO program. The process safety management program and risk management plan are specifically listed in the ISO program. 2. Drilling w ith Lockwood Fire on Transbas' alternative risk scenario. 3. Upgrading the current DMA dillution system to improve its efficiency. Due to process safety management program the following facility improvements were made: 1. A formal system to maintain and coordinate operating, maintenance, training and safety systems to enhance communication, quality and safety of the DMA amination, IPA amination and savage processes. 2. Installation of a nitrogen purge system on the isopropylamine storage tank to prevent IPA vapor release to the atmosphere and eliminating static air in the tank. 3. Adding slam valves to the DMA anhydrous tank to reduce potential loss of containment of DMA in the event of a piping failure. There are other miscellaneous changes made in the process due to Transbas PHAs but the above items were the highlights resulting from the PSM program. |