BLOUNT, INC. - CCI OPERATION - Executive Summary |
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Blount, Inc. - CCI Operation is committed to operating in a manner that is safe for Company employees, the public, and the environment. As part of this commitment, the Company in Lewiston, Idaho, has established a system to help ensure safe operation of the processes at its facility. One component of this system is a risk management program (RMP) that helps manage the risks at the CCI Operation and that complies with the requirements of the Environmental Protection Agencys (EPAs) 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 Blount Inc.s CCI Operation. The risk management plan is intended to satisfy the RMPlan requirement of the RMP rule and to provide the public with a description of the risk management program at the Lewiston Operation. The risk management plan Supplement #1 provide sspecific details and addresses the requirements of the rule. The risk management program at the CCI Operation consists of three elements: 1. a hazard assessment to help understand (a) the potential 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 (regulated substances) - 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 the RMPlan. Although the risk management program at the CCI Operation helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of th e safety program. In fact, the Company has a comprehensive safety program in place establishing many levels of safeguards against release of a hazardous substance and injuries and damage from a release of a hazardous substance. The Company strives to prevent releases of the hazardous substances used at the facility. When a hazardous substance is used at the plant, the equipment is carefully designed, built, and operated to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, and operation of the equipment. The CCI Operation limits damage from a release, if such a release occurs by training workers to respond to an accidental release, reducing the consequences of a release if it occurs. In addition, the Company works with the City of Lewiston fire department, with the Lewiston-Nez Perce Country Office of Emergency Management, and the Region II Hazardous Materials Response Team to help ensure that inju ries and environmental damage will be minimized if a release does occur. The Companies safety program consists of a number of elements, only some of which are required by the RMP rule. This RMPlan is primarily intended to describe those parts of the safety program that are required by the RMP rule. 1.1 Accidental Release Prevention and Emergency Response Policies Blount, Inc. 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. The Company implements reasonable controls to prevent foreseeable releases of hazardous substances. These controls include training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes at the plant; and programs to evaluate the hazards. In the event of an accidental release, the facility controls and /or contains the release in a manner that will be safe for employees and w ill help prevent injury to the public or environment. The facility provides training to its employees, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local response organizations. The company has 3 employees with 40 Hour Haz Mat (2 which serve on Region II Haz Mat Team), 2 employees with 24 Hour Haz Mat training, and 6 employees with 8 Hour Haz Mat training. Blount, Inc., is provided emergency response services by the Lewiston Fire Department which has formed mutual aid agreements with the Port of Wilma Fire Department, City of Clarkston, Asotin County Fire Protection District No. 1, City of Asotin, and Washington State University. Response activities have also been discussed with the Lewiston-Nez Perce County Office of Emergency Management. In order to effectively implement these policies, the Blount, Inc. Lewiston Operation has established a management system headed by the Environmental Manager to oversee RM P-related activities. 1.2 Facility Information and Regulated Substances The Blount Inc., Lewiston Operation consists of three production locations - CCI, Speer, and Southport. Only the CCI operation uses chemicals in quantities included within RMP regulations. Approximately 569 full-time workers work at the CCI operation. The location produces small arms ammunition for the shooting sport industry, police and military markets. As part of this manufacturing process, Blount, Inc. handles one regulated substance in sufficient quantity to be covered by the RMP rule, as shown below: Process ProgramLevel Regulated Substance ProcessQuantity Chlorine Unloading and Transfer 3 Chlorine 12,000 lb. The chlorine is used in the wastewater treatment plant to de-toxify cyanide from the facilitys copper plating operation. The process is sub ject to OSHAs PSM standard under Federal OSHA programs and is subject to Program 3. 1.3 Offsite Consequence Analysis Blount, Inc. performed an offsite consequence 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. Blount, Inc. does not expect a worst-case release scenario to ever occur. The alternative release scenarios were selected to help the Lewiston-Nez Perce County Office of Emergency Management improve the community emergency response plan. An alternative release scenario represents a release that (1) might occur at a facility and (2) the result in the greatest potential offsite consequences if this release occurred. The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by the CCI operation. These requirements are: 7 one worst-case release scenario for chlorine, and 7 one alternative release scenario for chlorine. The following information summarizes the offsite consequence analysis performed by Blount, Inc.: 1.3.1 Chlorine Releases Worst Case The worst case release scenario for toxic substances is the simultaneous failure of the fusible pressure release plugs from the six 2,000 lb. chlorine cylinders releasing the entire 12,000 pounds in 10 minutes (1/1,200#/min.) from an accident such as a fire. The maximum distance to the toxic endpoint concentration of 8.7 mg/m3 is 2.44 miles. The U.S. Census indicates that 31,245 people live within this distance from the facility. There are numerous public receptors located within the Worst Case and Alternative Scenario endpoint circles for chlorine. These receptors include: schools, public building, hospitals, parks and recreational areas. There are also environmental receptors such as Hells Gate State Park located within the toxic endpoint ci rcles as shown in Section 1.3.2 - Determination of Exposed Populations. Alternative Case The alternative release scenario is the rupture of a single 5/16 inch tank feed line. This scenario based on a calculated release rate of 15 pounds/minute. The maximum distance to the toxic endpoint is 0.69 miles. The U.S. Census indicates that 1,288 people live within this distance. Several Lewiston neighborhoods, public receptors and one environmental receptor are located within this distance as shown below: 1.4 Accidental Release Prevention Program and the Chemical-specific Prevention Steps The facility has formalized the prevention program for connecting the chlorine cylinders and maintaining related equipment. In 1996, the EPA RMP rule established requirements for Program 3 processes. The following sections briefly describe the elements of the Operations Program 3 prevention program and addresses the EPA RMP rule prevention program requirements. 1. Process Safety Information. Blount, Inc. maintains a variety of technical documents that are used to help ensure safe operation. These documents address (1) physical properties of hazardous substances, (2) operating parameters of the equipment, and (3) design basis and configuration of the equipment. The Operation ensures that this process safety information is available to all employees, the Lewiston-Nez Perce County Office of Emergency Management, and the Lewiston Fire Department. Material safety data sheets (MSDSs) document the physical properties of hazardous substances handled at the site, including regulated substances in RMP-covered processes. MSDSs for hazardous substances in work areas are handled for each process and are available to operators for ready reference. In addition, a list of chemicals on-site and quantities are provided to the Lewiston-Nez Perce County Office of Emergency Management and the Lewiston Fire Department for use in helping formulate emergency response plans. The engineerin g design documents include the operating parameters and the design basis and configuration of the equipment in the covered process. The available information includes: 7 operating parameters 7 simplified process flow diagrams 7 process chemistry 7 maximum intended inventories 7 safe upper and lower limits for parameters such as temperature, pressure or flow 7 consequences of deviation from established operating limits 7 design basis and configuration of equipment 7 piping and instrument diagrams, including materials of construction 7 electrical classification 7 safety systems 7 applicable design codes and standards 7 design basis for relief and ventilation systems Many of the operating parameters are included in the operating procedures to help with the safe operation of the process. These documents are used (1) to train employees, (2) to perform process hazard analyses, and (3) to help maintain the equipment. 2. Process Hazard Analysis. The Operation performs and periodically up dates process hazard analyses (PHAs) of the covered processes to help identity 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 analysis experience is assembled to analyze the hazards of the process. The CCI Operation primarily uses the hazard and operability (HAZOP) technique to perform this 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 the department manager and, when appropriate, changes to enhance the safety of the process are implemented. 3. Operating Procedures. Blount, Inc. 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 (1 ) are used to train employees, and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Employees develop and maintain operating procedures that cover all phases of operations, including changing of cylinders , normal operations, normal shutdown, emergency shutdown, and temporary operations. 4. Training. Blount, Inc. trains workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process, and (3) a detailed review of the process operating procedures and safe work practices. Employees who work closely with hazardous materials receive specialized training. Demonstrations and employee observations are used to verify that an employee understands the training material before the employee can resume work in the process. 5. Mechanical Integrity. T he facility maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. The mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meet the design standards required for service. The mechanical integrity program includes: 7 specifications for replacement parts and equipment 7 procedures for inspection, testing, and maintaining process equipment 7 procedures for safe work practices such as fork lift and respirator training 7 training of maintenance personnel 7 documentation of maintenance activities 6. Management of Change. The management of change program evaluates and approves all proposed changes to chemicals, equipment, and procedures for a covered process to help ensure that the change does not negative ly affect safe operations. Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be approved by the department managers to help ensure that inadvertent 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 changes. 7. Pre-startup Review. The operation performs a safety 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: 7 construction and equipment are in accordance with design specifications 7 adequate safety, operating, maintenance, and emergency procedures are in place 7 employee training has been completed 7 for a covered process, a start up review has been perfor med if the process is new or management of change requirements have been completed if an existing process has been modified 8. Compliance Inspections/Audits The Lewiston Operation inspected covered processes to be certain that the prevention program is effectively addressing the safety issues of operations. The operation assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 9. Incident Investigation. The facility 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. The company trains em ployees 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 the appropriate process enhancements are implemented. 10. Employee Participation. The company has developed a written employee communication action plan for covered processes to help ensure that the safety concerns of the Lewiston operation employees are addressed. The Operation encourages active participation of personnel in the prevention program activities of all processes at the facility. Employees are consulted on and informed about all aspects of the RMP rule prevention program, including process hazard analysis, employee training, and operating procedures. 11. Hot Work Permits. The facility 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 plant. Blount reviewed OSHAs fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The safety manager reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the operations safety program. 12. Contractors. The operation has established a program to help ensure that contractor activities at the site 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. The operation periodically reviews contractors training documents and work performance to help ensure that safe work practices are followed. 1.5 Chemical-specific Prevention Steps In addition to the required prevention program elements, Blount, I nc. has implemented safety features specific to the hazardous substances used at the Lewiston Operation. Chlorine. Chlorine is supplied in Department of Transportation (DOT) approved 1 ton cylinders. Chlorine is unloaded outside an enclosed building which vents to a caustic scrubber to reduce the severity, if a release were to occur. Chlorine detectors and alarms are provided in areas containing chlorine. 1.6 Five-Year Accident History The Lewiston Operation has had no accidents during the last five years while handling chlorine. Blount is proud of the excellent safety record of its employees. The excellent five-year accident record is indicative of the effectiveness of the prevention program that has been implemented. 1.7 Emergency Response Program The Lewiston facility has established a written emergency response program to help safely respond to accidental releases of hazardous substances. The emergency response plan includes procedures for: 7 Informing the Lewiston Fire Department and the public about accidental releases that could reasonably result in offsite consequences 7 Providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances 7 Controlling and containing accidental releases of hazardous substances, including the use of emergency response equipment 7 Inspecting and maintaining emergency response equipment 7 Reviewing and updating the emergency response plan Blount operates with trained personnel to assist off-site emergency responders during emergencies. All employees are training in evacuation procedures. The Safety department periodically conducts emergency response drills. A functional response exercise has been conducted with the Lewiston-Nez Perce County Office of Emergency Management. (see Blount Chlorine Functional Exercise 3/25/94 on file in the Environmental Managers office.) The written emergency response plan complies with other federal contingency plan regulatio ns (e.g., 29 CFR 1910.38(a), 29 CFR 1910.120(a)) and has been communicated to the Lewiston-Nez Perce County Office of Emergency Management and the Lewiston Fire Department. The Blount Environmental Manager maintains a regular dialogue with the local municipal fir departments emergency planning agencies and serves as the Chairman of the Nez Perce County Local Emergency Planning Committee. 1.8 Planned Changes to Improve Safety The Blount organization constantly strives to improve the safety of the processes through both the incident investigation program and a program review. The following changes to improve safety are planned or have recently been completed. 7 The CCI operation plans to upgrade its employee training program for chlorine processes. 7 Install an onsite weather station to gain real time climatology data in the event of an incident 7 Install purchased computer air emission modeling capabilities 7 Purchase additional chlorine monitoring equipment 7 Formalize the prev entive maintenance activities |