Arizona Chemical-Pensacola, FL - Executive Summary

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Arizona Chemical is committed to operating in a manner that is safe for employees, the public, and the environment.  As part of this commitment, Arizona Chemical has established a system to help ensure safe operation of the processes at this facility.  One component of this system is a risk management program (RMP) that helps manage the risks at Arizona Chemical and that complies with the requirements of the Environmental Protection Agency's (EPA's)  regulation 40 CFR part 68, Accidental Release Prevention Requirements:  Risk Management Programs (the RMP rule).  One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at Arizona Chemical.  This document is intended to satisfy the RMPlan of the RMP rule to provide the public with a summary of the risk management program at Arizona Chemical. 
 
The risk management program at Arizona Chemical consists of three elements: 
 
1.  a hazard assessment to help understand (a) the pot 
ential offsite consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule-see topics 1.3 and 1.5, 
 
2.  a prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes) - see topic 1.4, 
 
3.  an emergency response program to help respond to accidental releases of regulated substances from covered processes - see topic 1.6. 
 
Information further describing these elements is provided in this RMPlan. 
 
Although the risk management program at Arizona Chemical helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at Arizona Chemical.  Arizona Chemical has a comprehensive safety program in place establishing many levels of safeguards against release of a hazardous substance and injuries and damage from a relea 
se of a hazardous substance. 
 
The safety program at Arizona Chemical consists of many elements, only some of which are required by the RMP rule.  This RMPlan is primarily intended to describe those parts of the safety program at Arizona that are required by the RMP rule. 
 
1.1  Accidental Release Prevention and Emergency Response Policies 
 
Arizona Chemical is committed to the safety of employees and the public,  and the preservation  of the environment, through the prevention of accidental releases of hazardous substances.  Arizona has implemented reasonable controls to prevent foreseeable releases of hazardous substance.  These controls include training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes; and programs to evaluate the hazards.  
 
In the event of an accidental release, a deluge system is available to control and minimize the release in a manner that will minimize hazards to employees and will help to  
prevent injury to the public or the environment.  Arizona Chemical provides response training to employees, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department.  Response activities have also been discussed with the LEPC. 
 
In order to effectively implement these policies, Arizona Chemical established a management system headed by a Health and Safety Specialist to oversee safety-related activities. 
 
1.2  Arizona Chemical and Boron Trifluoride 
 
Arizona Chemical manufactures Terpene-Phenolic and Polyterpene resins.  As part of this manufacturing process, Arizona Chemical handles one regulated substance in sufficient quantity to be covered by the RMP rule.  The RMP covered process at Arizona Chemical is Boron Trifluoride.  Boron Trifluoride (BF3) is used in the manufacture of Terpene-Phenolic resins.  It is received in pressurized tube trailers.  Each trailer contains eight tubes, each tube containing  
1900 lbs.  The maximum process quantity is 15,200 lbs. 
 
1.3  Offsite Consequence Analysis 
 
Arizona Chemical performed an offsite consequences analysis to estimate the potential for an accidental release of a regulated substance to affect the public or the environment.  The offsite consequence analysis consists of evaluating both worst-case release scenarios and alternative release scenarios.  Arizona Chemical does not expect a worst-case scenario to ever occur.  The alternative release scenario was selected to help the LEPC improve the community emergency response plan.  An alternative release scenario represents a release that might occur at a facility like Arizona Chemical and would result in potential offsite consequences if the release occurred. 
 
The main objective of performing the offsite consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance).  The following effects could 
occur at the endpoint distance.  At distances less than the endpoint distance the effects would be greater; at distances greater than the endpoint distance, the effects would be less. 
 
When considering the release of a toxic substance, most people at the endpoint distance would be able to walk away from the exposure without any long-term health consequences, although some-short term consequences (e.g., strong eye or throat irritation) are likely.   
 
Based on the chemicals in use at the Pensacola plant, the RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by Arizona Chemical.  These requirements are:  one worst-case release scenario for boron trifluoride, a Program 3 process, one alternative release scenario for boron trifluoride, a Program 3 process.  The following information summarizes the offsite consequence analysis performed by Arizona Chemical. 
 
The worst-case release scenario for a Program 3, toxic substance is r 
upture of a single tube containing 1,900 lbs. of boron trifluoride.  The gas is released over a ten minute time period.  The area inside a circle   with a radius distance to the toxic endpoint includes several public receptors.  No environmental receptors are within this distance.  This information is provided to the Local Emergency Planning Council. 
 
The alternate release scenario for BF3 is the failure of the 3/8" tubing connected from the process piping to the tube trailer.  The scenario assumes that workers require 30 minutes to detect the leak and activate the deluge system and close upstream valves.  The material is released as a gas.  The water deluge system is expected to knock down 80 percent of the BF3 vapor.  The area inside a circle with a radius distance includes several public receptors.  No environmental receptors are within this distance.  This information is provided to the Local Emergency Planning Council. 
 
1.4  Accidental Release Prevention Program 
 
Arizona Chemical  
has used a prevention program to help prevent accidental releases of hazardous substances for several years.  Beginning in 1992, Arizona Chemical formalized this prevention program for the Boron Trifluoride Storage and Handling processes to comply with the 14 elements of the OSHA process safety management (PSM) prevention program.  In 1996, the EPA RMP rule established  prevention program requirements similar to PSM, except that the program also focuses on protecting the public and the environment. 
 
The following paragraphs briefly describe the elements of Arizona Chemical's prevention program that address the EPA RMP rule prevention program requirements. 
 
1.4.1  Process Safety Information.  Arizona Chemical maintains a variety of technical documents that are used to help ensure safe operation of the covered processes.  These documents address (1) physical properties of hazardous substances handled at Arizona Chemical, (2) operating parameters of the equipment, and (3) design basis and 
configuration of the equipment.  Arizona Chemical ensures that this process safety information is available to all employees, the LEPC and the fire department. 
 
1.4.2  Process Hazard Analysis.  Arizona Chemical performs and periodically updates process hazard analyses (PHAs) of the covered processes to help identify process hazards and generate recommendations that might improve the safe operation of the process.  A team composed of personnel with engineering and process operating experience and a leader with process hazard analyses experience is assembled to analyze the hazards of the process.  Arizona Chemical primarily uses the hazard and operability (HAZOP) technique, supplemented with checklists, to perform the analysis.  The PHA team prepares a written report describing the results of the analysis, including a list of recommendations.  Responsibility to resolve the recommendations is assigned to unit personnel and, when appropriate, changes to enhance the safety of the process a 
re implemented.  Approved recommendations are tracked to completion. 
 
1.4.3  Operating Procedures. Arizona Chemical process engineers, operators, and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed.  The operating procedures are used to train employees and serve as a reference guides for appropriate actions to take during both normal operations and process upsets.  Operating procedures include: steps for safely conducting activities; applicable process safety information, such as safe operating limits and consequences of deviation; and safety and health considerations, such as chemical hazards and personal protective equipment requirements. 
 
Arizona Chemical operating procedures cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a maintenance outage or emergency shutdown, and temporary operations. 
 
1.4.4  T 
raining.  Arizona Chemical trains workers to safely and effectively perform their assigned tasks.  The training program includes both initial and refresher training that covers a general overview of the process, the properties and hazards of the substances in the process, and a detailed review of the process SOP's and safe work practices.   
 
1.4.5  Mechanical Integrity.  Arizona Chemical maintains the mechanical integrity of process equipment to help prevent equipment failures that could indanger workers, the public, or the environment.  The mechanical integrity program includes an inspection and testing program to help identify equipment deterioration and damage before equipment fails and a quality assurance program to ensure that new and replacement equipment meet the design standards required for services in plant processes.  The mechanical integrity program includes:  specifications for inspection and testing of process equipment; specifications for replacement parts and equipment; 
procedures for inspecting, testing, and maintaining process equipment; procedures for safe work practices such as lockout/tagout, hot work, confined space entry, PPE, and linebreaking; training of maintenance personnel and documentation of maintenance activities. 
 
1.4.6  Management of Change.  The Arizona Chemical management of change program (MOC) evaluates and approves all proposed changes to chemicals, equipment, and procedures for a covered process to help ensure that the change does not negatively affect safe operations.  Process changes that are determined to be replacement in kind are excluded from the MOC process.  All other changes must be confirmed through the full MOC process to ensure that inadvertant consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the change. 
 
1.4.7  Pre-startup Safety Review.  Arizona Chemical performs a safe 
ty review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely.  This review confirms that construction and equipment are in accordance with design specifications; adequate safety, operating,  maintenance, and emergency procedures are in place; employee training has been completed; and a PHA has been performed if the process is new or MOC requirements have been completed if an existing process has been modified. 
 
1.4.8  Compliance Audit.  The parent company of Arizona Chemical, International Paper audits covered processes to be certain that the prevention progam is effectively addressing the safety issues of Arizona operations.  International Paper has a corporate audit group that assembles audit teams that include personnel knowledgeable in the RMP/PSM rules and in the process.  The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention progr 
am are implemented. 
 
1.4.9  Incident Investigation.  Arizona Chemical investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented.  Arizona Chemical relies on trained employees to identify and report any incident requiring investigation.  An investigation team is assembled, and the investigation is initiated within 48 hours of the incident.  The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. 
 
1.4.10  Employee Participation.  Arizona Chemical developed a written employee participation program for covered processes to help ensure that the safety concerns of employees are addressed.  Arizona Chemical encourages active participation of personnel in the prevention program activities of all processes at the facility. 
 
1.4.11  Hot Work Permits.  Arizona Chemical established a hot work permit program to  
control spark or flame producing activities that could result in fires or explosions in covered processes at the facility.  Arizona Chemical reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit to comply with these requirements.  
 
1.4.12  Contractors.  Arizona Chemical established a program to help ensure that contractor activities at the facility are performed in a safe manner.  The program reviews the safety record of all contractors to help ensure that only contractors who can safely perform the desired job tasks are hired.   
 
1.4.13  Chemical-specific Prevention Steps 
 
In addition to the required prevention program elements, Arizona Chemical has implemented safety features specific to the boron trifluoride system.  The following paragraph describes some of these safety features. 
 
Boron trifluoride.  Industry standards are followed at Arizona Chemical to help ensure safe handling of boron trifluoride.  The manufacturer suppl 
ies BF3 via Department of Transportation (DOT) approved tube trailers and follows DOT standards for maintenance and inspection of the tube trailer.    The BF3 manufacturer annually inspects the Arizona Chemical storage and unloading system and provides feedback on safe work practices.  The BF3 manufacturer has conducted safe handling training for production and maintenance employees.  The local fire department also has attended the training sessions. 
 
1.5  Five-Year Accident History 
 
There have been no accidents of consequence related to BF3 causing off-site impact or major monetary damage since Arizona Chemical acquired the facility in 1989. 
 
1.6  Emergency Response Programs 
 
Arizona Chemical has established a written emergency response program to help safely respond to accidental releases of hazardous substances.  The emergency response plan includes procedures for:  informing the local fire department and the public about accidental releases that could reasonably result in offsite c 
onsequences;  providing proper first aid and emergency medical treatment to treat accidental human exposure to substances at Arizona Chemical; operation of engineering controls such as activation of the deluge system to contain accidental releases of hazardous substances,  and reviewing and updating the emergency response plan. 
 
Arizona Chemical provides awareness level training to employees in these emergency response procedures.  All personnel are trained in emergency evacuation procedures. 
 
The written emergency response plan complies with other federal contingency plan regulations (e.g., the OSHA regulation 29 CFR 1910.38(a)) and has been communicated to local emergency response officials through the local fire department.  Arizona Chemical maintains a regular dialogue with the local fire chief, and provides appropriate information to the fire chief. 
 
1.7  Planned Changes to Improve Safety 
 
Arizona Chemical constantly strives to improve the safety of the processes at the plant thro 
ugh the incident investigation program, process hazard analysis, and by soliciting safety suggestions from the employees.  Over the last five years several changes have been made to the process.  Examples of changes include installing a high speed deluge over the BF3 trailer to knock down any potential vapor leaks, installing fixed cameras that are monitored by the control room operator to visually detect leaks from the BF3 trailer or process piping and installing a new scrubber tank for overpressure relief. 
 
The plant reviewed alternate raw materials in 1998, however, an acceptable alternative to BF3 that did not introduce a new set of hazards is currently unavailable.  Arizona Chemical will continue to monitor available technology and raw materials to identify opportunities to improve the safety of the process. 
 
Currently there are no significant changes planned for the BF3 system.
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