Ferro Polymer Additives Division-Fort Worth - Executive Summary |
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FERRO CORPORATION POLYMER ADDITIVES DIVISION 510 East Central Avenue, Fort Worth, Texas 76106 RISK MANAGEMENT PLAN JANUARY 1999 PREPARED BY: Earl E. Wheeler Ferro Polymer Additives (817) 625-2894 TABLE OF CONTENTS Section Page No. 1.0 FERRO POLYMER ADDITIVES-FORT WORTH RISK MANAGEMENT PLAN: EXECUTIVE SUMMARY 1 1.1 Accidental Release Prevention and Response Policies 1 1.2 Description of the Stationary Source and Regulated Substances 1 1.3 Off-Site Consequence Analysis Results 2 1.3.1 Worst-Case Releases 2 1.3.2 Alternative Releases 3 1.4 General Accidental Release Prevention Program 4 1.4.1 Employee Participation 4 1.4.2 Process Safety Information 5 1.4.3 Process Hazard Analysis (PHA) 5 1.4.4 Operating Procedures 6 1.4.5 Training 7 1.4.6 Contractors 7 1.4.7 Pre-startup Safety Reviews (PSSRs) 7 1.4.8 Mechanical Integrity 8 1.4.9 Safe Work Practices 8 1.4.10 Management of Change 9 1.4.11 Incident Investigation 9 1.4.12 Compliance Audits 9 1.5 Chemical-Specific Prevention Steps 10 1.5.1 Universal Prevention Activities 10 1.5.2 Specialized Safety Features 10 1.6 Five-year Accident History 11 1.7 Emergency Response Program Information 11 1.8 Planned Changes to Improve Safety 11 Section 1.0 Ferro Polymer Additives-Forth Worth Risk Management Plan: Executive Summary 1.1 Accidental Release Prevention and Response Policies The Ferro Corporation, Polymer Additives Division-Fort Worth (PAD-FW) has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as the training of personnel and consideration of safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of substances. If, in spite of all precautions, a release does occur, trained personnel will respond to control and contain the release. 1.2 Description of the Stationary Sour ce and Regulated Substances FERRO PAD-FW is a chemical manufacturing facility located at 510 East Central Avenue in Fort Worth, Texas. This plant is situated on approximately 12 acres in north Fort Worth. The immediate area surrounding this plant is open undeveloped land to the north, industrial development including Witco Chemical to the east, and mixed industrial/residential zoned areas to the south and to the west. Chemical manufacturing has been conducted at this location since the late 1940s. This site makes a variety of specialty organic chemicals that are sold to the plastic and rubber industries. The plant is operated 24 hours per day, seven days per week. Plant manufacturing activity can be broken down into three major product lines employing a total of 88 people. Except during Holiday shutdowns, the plant will be manned by one salaried production supervisor and 14 hourly plant operators. During the Holiday Shutdown one alaried supervisor and at least one hourly op erator are present. One of the three major product lines operated at this facility is the fatty amide line which has been in operation since 1981. Here, oleic acid is reacted with anhydrous ammonia to form fatty amide. Fatty amides are used in the manufacturing of plastic films. Actual reacting of the fatty acid is done under pressure in one of two process reactors. Excess ammonia is vented from the reactor to the scrubber while in the venting mode at the end of the semi-continuous process. Anhydrous Ammonia is supplied from a 12,000 gallon ammonia tank. . Ferro PAD-FW was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, the regulated substances and quantities kept on site were determined. The facility uses one regulated substances in one process. The chemical, process unit, largest quantity on site, and its threshold quantities are presented in Table 1. TABLE 1 Largest Quantity of Regul ated Substances Regulated Substances or Mixtures Containing Regulated Substances Process Unit Largest Quantity On Site (lbs) Threshold Quantity (lbs) Ammonia, Anhydrous Amide unit 59,280 10,000 Ammonia, Aqueous Amide unit 48,840 10,000 Based on worst-case analyses, the distances to endpoints [i.e., Emergency Response Planning Guideline level 2 (ERPG-2) for ammonia and IDLH for ammonia exceed the distances to public receptors (i.e., off-site residences, institutions, industrial and commercial office buildings, parks, or recreational areas inhabited or occupied by the public). In addition, Ferro PAD-FW is subject to Occupational Safety & Health Administration (OSHA) Process Safety Management (PSM) and is classified under a listed SIC Code (2869). Therefore, Ferro PAD-FW process is classified as Program 3 process under the Accidental Release Prevention (ARP) Program. 1.3 Off-Site Consequence Analysis Results 1.3.1 Worst-Case Releases . Toxic Substances Endpoints for tox ic substances are based on the ERPG-2. Toxic endpoints are listed in Appendix A to 40 CFR Part 68 (Table of Toxic Endpoints). The conditions at Ferro PAD-FW was reviewed to determine the substance with the distance to an endpoint. Table 2 shows the calculation parameter and distance to the toxic endpoint of 3.9 miles for Aerial Locations of Hazardous Atmospheres (ALOHA) model,which is greater than the 3.6 miles for a worst-case release of anhydrous ammonia based on the EPA lookup tables. Anhydrous ammonia is contained as a liquefied gas. Under the ARP Program ['68.25(c)(1)], gases liquefied by pressure alone (i.e., without refrigeration) are released as a gas over 10 minutes for worst-case purposes. Figure 2 shows the distance to the endpoint for anhydrous ammonia on a USGS map. Table 2 Distances to Endpoints for Toxic Worst-Case Scenarios Chemical Name Amount Released (gals) Liquid Density Weight (lbs) Distance to Toxic Endpoints (miles) anhydrous ammonia 12,000 4.94 59,280 2.71 aqueos ammonia 6,600 7.4 48,840 0.11 1.3.2 Alternative Releases Alternative release scenarios are those that are more likely to occur than the worst-case release scenario. Alternative release scenarios for toxic substances should be those that lead to concentrations above the endpoint beyond the facility's fenceline. The following conditions are considered for alternative release scenarios: @@ Release rate dependent upon scenario; @@ Use of typical meteorological conditions at the stationary source; @@ Actual release height; and @@ Consideration of active and passive mitigation systems. Flammable Substances A single alternative release scenario for all flammable substances is provided in response to the General Duty Clause under the ARP Program. A hypothetical release scenario has been identified for hydrogen as follows. A rupture disk on the hydrogen tank fails, allowing release of the contents into the atmosphere. For the alternativ e release a review of the consequences resulting from a vapor cloud release revealed that the distance to the lower flammability limit (LFL) for the hydrogen vapor cloud was greaterthan the overpressure endpoint in the model. Therefore, the distance to the LFL was chosen as the altenative release scenario - exceedint the the distance-to-endpoint of one psi overpressure based on an explosion hazard. Table 3 shows the distances to the endpoint for the for the alternative-case release of hydrogen predicted using the ARCHIE model beause the minimum value from the EPA lookup tables list is 10,000 pounds. This is almost twice the quantity of hydrogen stored in our tank. The alternative-case release of hydrogen resulted in a distance to the 1 psi overpressure endpoint of less than 0.08 miles. TABLE 3 Distance to Endpoint for Flammable Alternative-Case Scenario Chemical Name Amount Released (gals) Density grams/liter Weight (lbs) Distance to LFL From lookup tables (miles) Di stance to LFL From ARCHIE model (miles) hydrogen 9,000 70.8 5,317 0.8 0.04 Toxic Substances One alternative release scenario for each toxic substance is required under the ARP program. A hypothetical release scenario has been identified for the anhydrous ammonia at Ferro PAD-FW to determine the distance to an endpoint. The scenario is a l 1/4 inch relief valve fails open allowing a release of 5,200 pounds of anhydrous ammonia into the atmosphere over a two-hour period. Active mitigation exists and was considered in calculating air emissions for the alternative release scenario. Table 5 shows the calculation parameters and distances to toxic endpoints for the three toxic substances based on the EPA lookup tables. TABLE 4 Distances to Endpoints for Toxic Alternative-Case Scenario Chemical Name Amount Released (gals) Liquid Density (lbs/gal) Weight (lbs) Distance to Toxic Endpoints (miles) anhydrous ammonia 1,052.6 4.94 5,200 0.06 aqueous ammonia 2,432.4 7.4 18,000 0.20 1.4 General Accidental Release Prevention Program The following is a summary of the accident prevention program in place at Ferro PAD-FW. Because the process at the plant that is regulated by the EPA's risk management program (RMP) regulation are also subject to the OSHA's PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. 1.4.1 Employee Participation Ferro PAD-FW encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of Ferro PAD-FW accident prevention program. Specific ways that employees are involved in the accident prevention program include but are not limited to particpation in th e safety commitee, root cause analysis of incidents and near incidents in the plant, management of change decisions, and process hazard analysis of plant processes. 1.4.2 Process Safety Information Ferro PAD-FW keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information. Chemical-specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific covered p rocess areas, Ferro PAD-FW has documented safety-related limits for specific process parameters (e.g., temperatures, pressures). The plant ensures that the process is maintained within these limits using state-of-the-art process controls and monitoring instruments, emergency relief systems with a fog spray system and venting to a scrubber, highly trained personnel, and protective instrument systems (e.g., emergency shutdown systems). The plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. 1.4. 3 Process Hazard Analysis (PHA) Ferro PAD-FW has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each new and alterred process is systematically examined to identify hazards and ensure the adequate controls are in place to manage these hazards. Ferro PAD-FW primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses 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 as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local and corpo rate management for resolution. Implementation of mitigation options 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 assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, Ferro PAD-FW periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and 3 years for covered processes and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for considerati on, and the final resolution of the findings is documented and retained. 1.4.4 Operating Procedures Ferro PAD-FW maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures are used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and certified as current and accurate as part of the review of the Process Safety Management review every 3 years. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. These procedures are readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. 1.4.5 Training To complement the written procedures for process operations, Ferro PAD-FW has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least annually in the case of ammonia hazards. All of this training is documented for each operator, including the means used to verify that the operator understood the training. 1.4.6 Contractors Ferro PAD-FW uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, Ferro PAD-FW evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that con tractors are fulfilling their safety obligations. 1.4.7 Pre-startup Safety Reviews (PSSRs) Ferro PAD-FW conducts a PSSR for any facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. 1.4.8 Mechanical Integrity Ferro PAD-FW has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for p ressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. Ferro PAD-FW incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. 1.4.9 Safe Work Practices Ferro PAD-FW has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous s ubstances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space, and (6) a pre-start-up safety review on each unit. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 1.4.10 Management of Change Ferro PAD-FW has a comprehensive system to manage changes to all processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affect ed chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. 1.4.11 Incident Investigation Ferro PAD-FW promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is docum ented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. 1.4.12 Compliance Audits To help ensure that the accident prevention program is functioning properly, Grant Chemical periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. 1.5 Chemical-Specific Preventio n Steps The processes at Ferro PAD-FW have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. 1.5.1 Universal Prevention Activities The accident prevention program summarized previously is applied to all RMP-covered processes at Ferro PAD-FW. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. 1.5.2 Specialized Safety Features Ferro PAD-FW has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes: Release Detection 1. Ammonia detectors with alarms. Release Containment/Control 1. Process relief valves that discharge to a vent ho od directed to a scrubber to capture episodic releases 2. Valves to permit isolation of the process (manual or automated) 3. Automated fog spray system to minimize ammonia cloud formation 4. Free flow restrictors on the tank outlet valves Release Mitigation 1. Fire extinguishers 2. Deluge system for ammonia tank 3. Use of offsite emergency response personnel located within 10 minutes of the site. 4. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus) 1.6 Five-Year Accident History Ferro PAD-FW has not had any accidental releases during the past five years which meet the criteria for an accidental release per 40 CFR 68.42. 1.7 Emergency Response Program Information Ferro PAD-FW maintains a written incident response plan, which is in place to protect worker and public safety as well as the environment during an emergency. The plan consists of procedures for responding to a release of anhydrous ammonia, including the possibi lity of a fire or explosion or tornado. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The incident response plan is updated when necessary based on modifications made to plant processes. The overall emergency response program for Ferro PAD-FW is coordinated with the Fort Worth Fire Department. This coordination includes periodic meetings of Ferro PAD-FW personnel and Fire fighting personne l to discuss needs and concerns in the event of an incident at the plant. Ferro PAD-FW has around-the-clock communications capability with the Fort Worth Fire Department who have the ability to communicate to all state, federal and county agencies as to needed equipment (i.e., firefighting equipment, manpower, ambulances, hospitals, law enforcement, and HAZMAT operations). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. Ferro PAD-FW participates as requested in periodic emergency drills that involve the Fort Worth Fire Department and emergency response organizations. 1.8 Planned Changes to Improve Safety Ferro PAD-FW has several elements of the management system of the accident prevention program in place to improve safety throughout the facility. These elements are part of an overall ongoing safety improvement process. The following elements of the management system are present to improve safe ty. Process Hazard Analysis (See Page 6) Management of Change (See Page 9) Compliance Audits (See Page 10) |