Ozark Mahoning Company - Executive Summary |
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Executive Summary Introduction A Risk Management Program has been implemented at Ozark Mahoning's Tulsa, Oklahoma plant for the reduction of accidental releases of hazardous materials. The Risk Management Plan summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The plan summary is organized to correspond with specific EPA RMP definitions and requirements, including: Introduction; Ozark Mahoning policies to protect health, environment, and safety; Facility identification and regulated substances covered processes; Hazard Assessment; Prevention Program; Five-Year Accident History; Emergency Response Plan; and Planned changes to improve safety. Ozark Mahonings Policies for Health, Environment, and Safety Risk management and safety have been important concerns at Ozark Mahoning for many years; this RMP formalizes and documents these activities. Ozark Mahoning is committed to conducting its operations in a safe, responsible manner and to reducing risks to health and the environment. This commitment to health, environment, and safety (HES) starts with the CEO. Senior management of Ozark Mahoning and its parent company Elf Atochem routinely dedicate time to a review of HES matters, including safety. This emphasis on safety is carried through to the facility level, where the Plant Manager and the Safety Committee regularly review safety performance, take corrective actions, and strive for continuous improvement to safety by employees and contractors. Ozark Mahoning's HES programs include policies, procedures, standards, and guidance materials designed to fulfill Ozark Mahoning's commitment to health, environment, and safety. These materials include Risk Management Program guidance to help our facilities prevent and/or reduce the risk of accidents. Facility Identification and Regulated Substances in Covered Processes The Ozark Mahoning Tulsa facility is located at 5101 West 21st Street, Tulsa, Oklahoma. The facility manufactures chemicals that are mainly used in dental care products. Anhydrous Hydrofluoric Acid, which is used within the facility, is registered under 40 CFR Part 68, the EPA Risk Management Program (RMP) Rule. This substance is present above the minimum threshold for RMP applicability. The maximum simultaneous capacity for Anhydrous Hydrofluoric Acid at the facility is 80,000lbs. Anhydrous Hydrofluoric Acid is the foundation for the plant's major products. Ozark Mahoning knows that this and other chemicals which are handled and used are hazardous and/or flammable. These chemicals are handled with a great deal of care and respect. Hazard Assessment -- Worst Case Scenario Ozark Mahoning strives to protect its employees, contractors, the community, and the environment. Ozark Mahoning was already addressing with most of the EPA's requirements of RMP through our Process Safety Management (PSM) Program. For the worst case scenario, assume the bulk storage tank is completely full of Hydrofluoric Acid, breaks open, and spills all of its contents in 10 minutes. Also, assume all plant safety systems completely fail. In this case, for Anhydrous Hydrofluoric Acid, the maximum distance where there is concern for the public being at risk of significant injury is at least 25 miles. Neither the EPA nor Ozark Mahoning believes the worst case scenarios are realistic cases. The Risk Management Plan includes information on mitigation and prevention measures implemented by Ozark Mahoning to reduce the risk of a worst case scenario event. Hazard Assessment -- Alternate Release Scenario RMP requires each site to analyze an Alternate Release Scenario that could potentially impact the public. For Anhydrous Hydrofluoric Acid a two inch rupture disk release was used as the alternate scenario. In this scenario, 36,420 lbs would be released and would travel an estimated 4,530 ft in the summertime a nd 2,950 ft in the winter months before dispersing enough to no longer pose a hazard to the public. This alternate release scenario is somewhat more likely than the Worst Case Scenario, but is still a very unlikely event. The Risk Management Plan includes information on mitigation and prevention measures implemented by Ozark Mahoning to reduce the risk of this type of event. Prevention Programs The risk of releases are significantly reduced by designing for safety. Some of the ways which the facility designs for safety include conducting hazard studies to identify potential release scenarios and assess safeguards, completing hazard studies for design changes, designing the plant to be built to industry and national engineering codes, maximizing employee participation in design work, designing components with multiple automatic safety shutdowns, building emergency shutoff valves into the process and transfer systems, and ensuring that emergency escape routes from the units are ma intained. The plant maintains safety by operating a preventive maintenance program for tanks, equipment and piping, operating a leak detection and repair program to identify and repair equipment and piping leaks early, conducting routine mechanical integrity testing to ensure that metal thickness is adequate over the life of the equipment, routinely testing emergency shutdown devices and safety systems, checking sensors, and using mandatory checklists to ensure that equipment is opened for repair without creating releases. More importantly, routine audits are conducted to assure that safe practices are being followed. Five Year Accident History There have been no RMP accidents or releases for the last five years at the facility. Emergency Response Plan A written emergency response plan is maintained at the facility. The emergency response measures to be taken for RMP scenarios have been incorporated into the facility emergency response plan. The facility actively part icipates with Tulsa County Local Emergency Planning Committee (LEPC) to coordinate emergency response training and drills at the plant site. Selected elements of the plan will be incorporated into the Tulsa County Emergency Action Plan, which is maintained by the LEPC. The Tulsa plant is prepared to respond to accidental releases. The facility prepares by having employees participate in drills and training for emergency response/mutual aid, having fire/spill response equipment ready, having an emergency response team, providing employees with medical/first responder and rescue training. Supervisors and key employees also receive incident command and spill response training. |