MG Industries - Beaumont - Executive Summary |
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MESSER - MG INDUSTRIES - BEAUMONT CARBON DIOXIDE PRODUCTION FACILITY RMP EXECUTIVE SUMMARY INTRODUCTION - MESSER AMERICA'S LOSS PREVENTION PROGRAM Loss Prevention management refers to the prevention of potential losses to Messer through an effectively designed, administered and implemented Environmental, Health, Safety and Regulatory Compliance program. Incorporating an effective loss prevention program requires developing and integrating programs that will assist in reducing losses resulting from accidents. Messer GmbH has developed Safety, Health, and Environmental guidelines. These guidelines have been further refined and developed into a comprehensive program defined as Loss Prevention Policies (LPP) and are contained in this manual. These policies are the minimal standards for Messer America's (Central, North, South America and AGS) operations. The objective of this program is to achieve an acceptable level of performance in the prevention of losses to the organization, whic h include but are not limited to; accidents, injuries, illnesses, product liabilities, regulatory non-conformities, etc. To be effective, this management system must be totally integrated in which all levels of employment are involved and held accountable. The ultimate authority for instituting an effective Loss Prevention Program rests with the senior management of each operating Group. Through their words and more importantly through their actions, senior management sets the tone for loss prevention throughout Messer Americas. While senior management sets the tone, middle management must create the uniform support and nurture the desired culture to influence the Loss Prevention program. This strong management commitment culminates with the day to day responsibility of implementing and managing the Loss Prevention program by "line management" (supervisor and lead personnel). Local management is accountable for the effective management of this program through their organization's per formance as related to loss prevention and regulatory compliance (which includes company policies). In a healthy loss prevention culture, each member of the company participates fully in the program. Loss prevention is no longer an activity that someone else is in charge of. Each manager, supervisor, driver, and line worker is personally responsible for insuring "safe working conditions, safe product for all customers and a safe environment for the citizens of the communities in which Messer operates". SIMPLIFIED PROCESS DESCRIPTION The MG Industries Beaumont facility is a carbon dioxide manufacturing plant. The ammonia portion of this plant falls within the RMP requirements. The raw carbon dioxide comes from a source via pipeline. An ammonia chiller system pre-cools the gas, which condenses the excess water. Condensed water is then removed in a water separator. The carbon dioxide is then compressed in a series of low and high stage compressors. Gaseous oxygen is injected int o the process stream before it is pre-heated for the reactor. Carbon dioxide passes into the catalytic reactor to remove hydrocarbon compounds. The carbon dioxide is then chilled and dried before being liquified in the carbon dioxide condenser. Non-condensibles are removed from the stream using a stripper/reboiler column. The liquid is sub-cooled and stored under pressure in large carbon steel storage vessels. The aforementioned cooling and liquefaction steps are accomplished using ammonia refrigeration. The ammonia exists in quantities large enough for RMP submission. The safety-related equipment/devices are described later in this summary report. WORST CASE RELEASE SCENARIO The first step in the worst-case release analysis was to determine the total amount of ammonia onsite. It was determined that there are 15,250 lbs of ammonia on-site. While there are safety devices and process controls on the equipment to prevent accidental releases, a large natural disturbance such as a tornado could rip through the facility and create a worst-case release of all of the ammonia. The determination of the affected distance to endpoint was made using the RMP*Comp software. The distance to endpoint was found to be 1.5 miles. The Landview III software package was used to determine the general environmental and community impact within this radius. There are approximately 254 people living within this radius. Other public receptors include a railroad track and fifteen businesses. There are no environmental receptors in the endpoint radius area. ALTERNATIVE RELEASE SCENARIO The best alternative scenario that could be developed that would have an offsite impact was modeling damage to the pipe threads connected to a safety relief valve resulting in ammonia gas escaping. A ten-minute time period was used for the release calculations. This is an estimate on the maximum amount of time required to close the upstream valve manually. The amount of ammonia released was c alculated at 652 pounds using the RMP*Comp software. The distance to endpoint was found to be 0.2 miles. The Landview III software package was used to determine the general environmental and community impact within this radius. There is approximately 1 person living within this radius. There is also three businesses within the radius. There are no environmental receptors in the endpoint radius area. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS - LOSS PREVENTION WRITTEN POLICY SUMMARY The objective of the Messer Loss Prevention Program is to achieve an acceptable level of performance in the prevention of losses to the organization. The paramount importance of our Loss Prevention Program is assuring safe working conditions for our employees, safe product for our customers, and a safe environment for the citizens of the communities in which we operate. This program is integrated with a series of Loss Prevention Policies that are the corn erstone of Messer Loss Prevention efforts. These policies form our Loss Prevention Policies Manuals. These manuals are maintained by local management and are available for review by any employee upon request during normal business hours. In addition, compliance with local and federal regulations such as OSHA, DOT, EPA are required. AUTHORITY AND RESPONSIBILITY FOR PROGRAM IMPLEMENTATION Plant Manager has the overall site authority for implementation of the Loss Prevention Program. He or she is responsible for the day to day management of the Loss Prevention Policies as they directly relate to all operational activities. Terminal Manager is responsible for the day to day management of the Loss Prevention Policies as they directly related to distribution activities. Site Safety Advisor is responsible for conducting periodic inspections, serving as the facility spokesperson (on Loss Prevention issues) and participation on the Safety Committee. Regional Manager oversees the Loss Prev ention activities of their region, conducts audits, introduces new and/or revised Loss Prevention Policies, participates in "Group" accident/incident investigations and assures that hazards are abated in a timely manner. SYSTEM FOR IDENTIFYING, EVALUATING, AND PREVENTING OCCUPATIONAL SAFETY AND HEALTH HAZARDS HAS BEEN DEFINED THROUGHOUT THE LOSS PREVENTION MANUAL WHICH INCLUDE, BUT ARE NOT LIMITED TO: () Review of applicable standards to the industry. () Review and availability of Material Safety Data Sheets. () Assure the proper labeling of potentially hazardous materials. () Safety work permitting systems. () Investigation of accidents/ incidents. () Periodic and scheduled inspections of the general work areas. EMPLOYEE COMMUNICATIONS AND TRAINING ARE ALSO DEFINED THROUGHOUT THE LOSS PREVENTION MANUAL WHICH INCLUDE, BUT ARE NOT LIMITED TO: () Monthly poster program service by the National Safety Counsel on a variety of safety and health topics. () Site specific Safety Bulletin Board for the posting of all environmental, health and safety related information i.e. Loss Prevention Policy, Injury/Illness Logs, safety posters, etc. () Site specific Safety Committee made up of representative functional positions within the operation. () Monthly Safety Meetings are held on various environmental, health, and safety related topics. () Safety Orientation for all new hires and personnel transferred into new positions. () Regulation Compliance training as it may apply to specific operations and/ or exposures i.e. Hearing Conservation, HAZCOM, Respiratory Protection, Fire Extinguishers, etc. RECORDKEEPING Loss Prevention records are maintained in the facilities Loss Prevention and Regulatory files. Access to these files is controlled by the respective manager. Distribution of these records requires authorization. PROCESS SAFETY FEATURES The MG Beaumont Carbon Dioxide facility has a Loss Prevention Program at both the local and corporate levels. There are two pr ocess areas that are affected by RMP: the pre-cooler unit and the main production facility. Although the facility is manned 8 hours per day, it is operated 24-hours per day and is monitored both locally and remotely. The facility is routinely inspected at least once per day. The ammonia refrigeration vessels are equipped with safety relief devices that are piped into a common header that leads to a sparge system (which neutralizes the ammonia). Critical process variables in the ammonia refrigeration system are monitored to alarm in the event of a process upset. The process building and the facility perimeter are both equipped with ammonia sensing devices. These devices are set to alarm at 45 ppm in the event of high ammonia concentrations in air. The entire process is equipped with emergency E-stops located throughout the entire facility. FIVE-YEAR ACCIDENT HISTORY There have been no accidental releases in the past five years. EMERGENCY RESPONSE PROGRAM MG Industries is loc ated in the industrial area on Gulf States Road in southeast Beaumont. Fire brigade support is available through mutual aid agreements between existing chemical companies operating in the region. No specific community fire department responds to this area. MG has developed a mutual aid system with Equistar who is the raw gas supplier to the MG plant. Equistar plays a critical role in MG's emergency plan by providing control and mitigation of an incident while MG provides the technical expertise with respect to the equipment and product. A comprehensive Loss Control Program exists at the facility that is managed both locally and at the MG corporate level. PLANNED CHANGES TO IMPROVE SAFETY Opportunities are continually reviewed to improve the safety and reliability of the facility. |