AlliedSignal - Hopewell Plant - Executive Summary
AlliedSignal Hopewell Plant |
The AlliedSignal Hopewell facility is a manufacturing plant located in Hopewell, VA. It is part of the Polymers Strategic Business Unit of AlliedSignal Inc. Headquartered in Morris Township, New Jersey, AlliedSignal is an advanced technology and manufacturing company serving customers worldwide with aerospace and automotive products, chemicals, fibers, plastics and advanced materials. With 1998 sales of approximately $15 billion, the company ranks among the top 100 of the Fortune 500. AlliedSignal has approximately 70,500 employees at 300 facilities in 40 countries. AlliedSignal operates twelve major businesses: Aerospace Equipment Systems, Aerospace Engines, Electronic and Avionic Systems, Aerospace Marketing Sales and Services, Federal Manufacturing and Technologies, Polymers, Specialty Chemicals, Electronic Materials, Consumer Products Group, Turbocharging Systems, Truck Brake Systems and Friction Materials. More inform
ation about AlliedSignal may be found at its Web Page: www.AlliedSignal.com
It is the worldwide policy of AlliedSignal to design, manufacture and distribute its products and to handle and dispose of materials throughout their life cycle in a manner that protects the environment and safeguards employees, customers and the public from unacceptable risk. AlliedSignal's complete Health, Safety and Environment Policy may be found at the AlliedSignal Web Page.
The Hopewell Plant participates in the Responsible Care program of the Chemical Manufacturers Association. The Community Awareness and Emergency Response Code of Responsible Care brings chemical plants and local communities together through communications and cooperative emergency planning. The Hopewell Plant is an active participant in the Local Emergency Planning Committee and in the Hopewell Community Industry Panel (HCIP), a community advisory panel. This organization's members come from local industry, civic leaders, governmen
tal representatives and citizens. Its mission is to promote cooperation and communication in the City of Hopewell. The Process Safety Code of Responsible Care is designed to prevent fires, explosions and accidental chemical releases. The LEPC and the HCIP both form the nucleus of the communication message for process safety to the City of Hopewell. The code requires safety audits, inspection and maintenance programs, and safety training for employees and contract workers. Facilities are encouraged to listen to the concerns of the community and to consider these concerns when designing and implementing process safety systems.
The AlliedSignal Hopewell plant has been a part of the Hopewell community for the past 70 years. During that time the company has participated in a variety of industrial organizations, local government activities and community emergency response drills. These include active membership in the Hopewell Community & Industrial Panel, and th
e Local Emergency Planning Council. The members of these organizations are government, business, industry, emergency response agencies and citizens all focusing on a common commitment to environmental and safety issues along with emergency preparedness. Annually, the AlliedSignal Hopewell plant's approximately 100 member emergency response brigade participates along with the local police, fire, rescue and other emergency services in a drill to test our plans for a variety of possible incidents.
Besides these activities, the plant cooperates with the American Heart Association and Junior Achievement along with being the largest single City of Hopewell industry contributor to the United Way. The plant has a recognized Wildlife Habitat site within the boundaries of the plant. The AlliedSignal Hopewell plant is also a member of the Hopewell and Prince George County School, Business and Industry Partnership, a cooperative endeavor between schools and businesses to improve student car
eer and educational development.
The AlliedSignal Hopewell Plant employs approximately 1,000 people and is the single largest manufacturing site of caprolactam in the world, a product used to make nylon-6 for carpets and other high-performance nylon products. Ammonium sulfate, a fertilizer high in nitrogen and sulfur content, produced as part of the caprolactam process, is sold worldwide for agricultural uses. The AlliedSignal Hopewell plant contributes approximately $4.0 million dollars to local governments in the form of various taxes.
Process Chemicals and Products:
We use three main raw materials, natural gas, sulfur and phenol, at Hopewell to produce a variety of other products in addition to caprolactam and ammonium sulfate. These include:
* Adipic acid
* Performance chemicals:
* Adicarb oxime
* Acetaldehyde oxime
* Methylethyl ketoxime
* Other oximes
These products are sold to industrial users who use them to manufacture consumer products
such as fertilizers, tennis shoes, lingerie, videotapes, paints and shellacs.
Of the many chemicals at the Hopewell plant, seven are identified on the EPA list of highly hazardous chemicals. They are:
* Anhydrous ammonia
* Methyl mercaptan
* Ammonia solution (22%)
These chemicals, along with the others manufactured or consumed, are stored in a variety of tanks and vessels specially designed for the chemicals and their varied processing steps.
How We Prevent Incidents:
Chemical risk management is the way people operating a business that uses chemicals ensure safe handling of each chemical. At AlliedSignal's Hopewell plant, the chemical safety and risk management program involves the nearly 1000 men and women committed to operating a safe workplace for the community and their coworkers through numerous activities including but not limited to:
* Eliminating or reducing chemical hazards through safe plant design and con
stant equipment modernization
* Preventing accidents through continuous worker training and on-going plant maintenance
* Preparing for possible incidents through drills and community emergency planning
* Preventing incidents with modern computer controlled alarm and shutdown systems and quick employee response
* Responding promptly to emergencies with a well-trained plant emergency brigade and community fire and police support
Emergency Response Program:
The Hopewell plant emergency response plan is designed to:
* Enable the plant to effectively cope with a plant emergency or potential emergency
* Reduce the hazards of injury to plant personnel and hold to a minimum damage to plant property and equipment
* Form an organization capable of dealing with immediate needs during and after a emergency
* Minimize the impact of the disaster on the environment and surrounding area
The plan is designed to alert employees by an audible alarm system and as the situation warrants, notify the com
munity through the local police and fire departments. Evacuation procedures are included in the emergency response plan. Each functional department head is charged to focus on the safety of the employees and local citizenry. Communication is provided through a specialized radio service, where the plant site can review the situation and coordinate directly with other emergency response agencies. Direct 2-way radio links are in place to quickly notify local school systems and media sources.
The plant has its own emergency response brigade made up of approximately 100 trained, qualified, certified emergency response individuals. These responders receive additional training in chemical plant emergency response and many have been trained at nationally known emergency response schools in Texas and Nevada. These plans and responses to incidents are tested annually through drills involving the brigade and local police, fire, rescue and other emergency service personnel. The brigade re
ceives periodic training e.g., tabletop drills and hands on exercises, throughout the year.
EPA Defined Scenarios:
EPA's Risk Management Program requires the Hopewell plant to prepare an analysis of a hypothetical worst case release of the chemicals covered by the RMP regulation. EPA defines a worst case release as the release of the largest quantity of the chemical from a vessel or process line failure. EPA also assumes that the failure takes place over 10 minutes and that all safety systems fail to operate. In addition, the release must take place during the worst possible weather conditions. For a number of reasons discussed in this submittal, it is extremely unlikely that this event would ever occur.
In addition, the Hopewell plant is required to analyze the impact of an alternative accidental release scenario for each covered chemical.
Worst Case -- Toxic
Our worst-case toxic scenario is the failure of a pressurized ammonia storage tank, resulting in the release of the e
ntire contents of the tank in 10 minutes. Since the AlliedSignal Hopewell plant is located within the City of Hopewell, any gas cloud formed by the evaporating ammonia could reach public areas. The effects offsite of a worst-case scenario would be in a downwind direction both within the plant and beyond the plant boundary.
Alternative Release -- Toxic
a) Anhydrous Ammonia
A plausible alternative release scenario for ammonia is a pipe flange or gasket leak from a transfer hose. This release of ammonia over a 10-minute period would have a minimal downwind impact. The effect offsite would be minimal due to low vapor concentration and the sparse residential population just outside the immediate plant boundaries.
A plausible alternative release scenario for chlorine is the failure of the relief device on the cylinder. In this case, the entire contents of the chlorine cylinder are released. Based on the plant location and proximity of the cylinders to the fence line, offs
ite consequences are minimal and limited to adjacent industrial sites.
c) Methyl Mercaptan
A plausible alternative case scenario for methyl mercaptan is the failure of a flange gasket in a section of piping. The ensuing gas cloud will have a minor off site consequence to adjacent industrial sites.
A plausible alternative case scenario for methyl trichlorosilane is the failure of a pump seal. In this situation, the liquid is contained within a dike and evaporates slowly. The gas can be carried off site into the community immediately adjacent to the plant where it will dissipate.
A plausible alternative case scenario for oleum involves a transfer line leak within the dike area surrounding the storage tanks. The dike contains the liquid and the vapors released dissipate before they reach the community immediately adjacent to the plant.
f) Ammonia Solution (22%)
A plausible alternative release scenario for 22% ammonia solution is a failure of the d
rain valve on the bottom of the storage tank. The release involves a significant volume of liquid ammonia solution. Due to process drains near the tank, the release of ammonia from the solution would not have any offsite consequences.
Worst Case -- Flammable
The RMP rule requires us to evaluate the impact of our worst-case flammable scenario. This was done for acetaldehyde. In this case, the impact of a vapor cloud explosion has been evaluated. There would be a minimal offsite impact to an adjacent industrial site from a worst case release of acetaldehyde.
Alternative Release - Flammable
A plausible alternative case scenario for acetaldehyde is the failure of a transfer line gasket causing a gas leak. If this gas finds an ignition source an explosion will occur. The impact of the explosion extends beyond the plant boundaries to impact an adjacent industrial site.
Process Safety Accident Prevention Program:
The employees at the AlliedSignal Hopewell plant are committed to t
he safe and reliable operation of the plant in a manner that safeguards life, health, property and the environment. The process safety and risk management initiatives are implemented as proactive approaches to minimize the potential for accidental releases. Policies and procedures have been implemented to guide the plant to meet the requirements of the federal mandates.
Each of the seven chemicals on the EPA list at the AlliedSignal Hopewell plant has been evaluated based on the EPA's guidelines. Specific information related to each chemical is supplied in our risk management plan, available from the EPA. In all of these cases, there are numerous safety devices to prevent and/or reduce the chance of a release occurring. Examples of these devices include:
* Remote operated shutoff valves
* Remote detectors
* Continuous monitoring
* Containment dikes
The responsiveness of the Emergency Brigade has proven in the past that in addition to safety systems, in the unlikely event tha
t a chemical release occurs, emergency response has been successful in preventing the releases from getting outside the plant boundaries.
Process Safety Information
The Hopewell plant has established specific guidelines and procedures for compiling and maintaining written information for the chemical processes we operate. Specific responsibilities for maintaining this process safety information have been identified and assigned to qualified individuals. The plant's hazard communication program communicates the health and environmental effects of chemicals to our employees. We also maintain comprehensive evaluations of the process chemistry and operating conditions of all processes.
Process Hazard Analysis (PHA)
We analyze each chemical process utilizing a method designed to evaluate the process for hazards such as fire, chemical release, process control and explosions. The utilization of proven hazard analysis techniques has been applied at the Hopewell plant for many years, pr
ior to being mandated by the federal government in 1992. The process safety analysis approach is applied to major modifications and also to minor operating changes. Each process change or process modification undergoes rigorous technical evaluation using the highest standards of personal and community safety as the focal point. We review the process hazard analyses on a continuing 5-year cycle so that we maintain a high degree of integrity in the safety of our processes. Each PHA uses the appropriate methodology to analyze potential hazards, their affects and provides for timely resolution of recommendations. Recent hazard analyses have shown the need for additional redundant environmental control systems for those rare occasions when the primary control system requires preventative maintenance. As a result, we have added these controls.
Written operating procedures are structured to cover all aspects of plant operation including startup, shutdown, normal op
erations, upset conditions and emergency response. Each operating area of the plant has specific operating procedures developed by those people most knowledgeable in the plant operation, operators and area supervisors. Other process operators and supervisors review these procedures for accuracy and consistency. After review, the department manager who verifies that they are accurate and up-to-date annually certifies the operating procedures. Operators work closely with process engineers as process modifications take place to make sure the operating procedures include information relating to the process changes.
Besides standard operating procedures, the Hopewell plant has developed extensive training materials to support the development of individuals into highly trained and qualified process operators. These training manuals have been developed by the operators themselves and cover their expansive knowledge from years of on-the-job service. The training program is su
pported with computer based training modules and extensive hands-on training by qualified area trainers. Operators are trained on computers that simulate real-life plant situations before they can qualify to work in the operating areas of the plant. The Hopewell plant operators are required to complete a three-year training program before becoming fully qualified. To assist in documenting and tracking employee training, we have installed a software program, which involves self-directed learning, online information databases and integrated procedures and training manuals.
Mechanical integrity of plant equipment is another way we reduce the probability and consequences of catastrophic releases. We assure that equipment is fit for its intended service. Extensive on-going inspection programs are key to maintaining the process equipment. Guidelines and procedures have been developed and are followed by people performing the inspections. They are trained and qual
ified to analyze data and provide operations with timely information for continued safe equipment operation. Quality assurance of new equipment, processes and spare parts provide additional confidence that the equipment containing the process chemicals will perform as designed. For example, process vessels holding chemicals are inspected/evaluated on a preset timetable using visual and ultrasonic thickness testing methods. Based on the results of these tests, appropriate actions are taken to assure that the vessels are deemed fit-for-service. Specifically, the large ammonia storage vessels considered in the worst case scenario description are taken out of service on a scheduled basis for comprehensive integrity evaluations.
Management of Change
Managing change is one of the most important activities associated with process safety and risk management. Detailed procedural steps have been developed to provide guidance for operations personnel in making necessary process and mecha
nical changes to maintain a safe plant and achieve a high level of performance. Multi-departmental approvals are required before proceeding with the requested change. This management of change process incorporates:
* Process hazard analysis
* Operating procedure updates
* Mechanical integrity review
* Pre-startup safety reviews
* Audits to ensure that any process or mechanical change maintains our high level of safe performance
We perform safety checks using management of change to provide documentation that all process safety precautions have been taken prior to starting up a new process or modification to an existing process. These checklists serve as a reminder and give guidance for support groups as they evaluate the requested changes. The support groups provide written documentation to the owning departments verifying that the requested change has been thoroughly reviewed and will be implemented in a safe manner.
Compliance audits are
a self-check to verify that the process safety and risk management programs are functioning as per the federal mandates. These audits are performed at least every three years on the entire process safety management standard. In reality, portions of these audits are performed on a more frequent basis to maintain an on going level of process safety. Management of change, for example, is audited on a quarterly basis focusing on documentation and timely closure of any action items. The AlliedSignal corporate audit team provides an additional level of evaluation for enhanced compliance.
Being prepared for unforeseen events is an additional measure of readiness. This is how the Hopewell plant sees incident investigation. The plant has specific guidelines for addressing unplanned events within the facility. These guidelines include a detailed incident investigation for major, minor and near miss incidents. The team approach is used to investigate the situatio
n and include appropriate personnel including hourly employees. Analysis techniques include structured root cause analysis and a system to track recommendations to resolution.
The Hopewell plant has several teams and committees from the plant leader level to the wage roll employees structured to focus on safety and process safety activities throughout the plant. Many examples have been identified in the elements of process safety being discussed in this section of the executive summary. One key component is the Plant Safety and Environmental Committee. This committee is comprised of plant management and hourly leaders to develop and implement safety and environmental goals.
Hot Work Permits
The purpose of the hot work permit at the Hopewell plant is to regulate the use of equipment capable of igniting flammable or combustible material. Due to the variety of flammables used in the plant, it is mandatory that any hot work is reviewed and strict adherence
to the hot work procedure is followed. A permit system with specific check requirements has been used for achieving our goal of safe hot work within the plant.
The Hopewell plant's contractor safety program encompasses contractor screening for suitability to perform to AlliedSignal standards. Contractors working on-site meet the strict safety requirements including:
* A comprehensive safety orientation
* Detailed qualification and training documentation
* Hazard communication program
* Formal audit system
* An accident-investigation procedure
The AlliedSignal Hopewell plant is controlled by a modern computer based distributed control system (DCS). The DCS system has both a primary control system and a backup system in case the primary one fails. Fail-safe shutdown systems are tested both on and off line. Our ammonia storage tank, for example, has an electronic pressure monitoring interlock, which upon sensing a high pressure sends an alarm to the
control room console. The interlocks also trip a valve, which diverts the ammonia vapor to a secondary absorption system there by preventing a release of ammonia to the atmosphere.
Five-Year Accident History:
The AlliedSignal Hopewell plant has experienced three releases based on definitions of releases provided by the EPA during the past five years. In all three cases, the facility identified very effective actions to prevent similar incidents from occurring again.
* In 1994 the plant experienced a total power failure due to a problem with the power company. Due to this loss of power, and ensuing process upset, a process relief valve lifted, allowing ammonia to escape to the atmosphere. The vapors drifted off site before dissipating to minimally detectable levels. A local business employee reported some minor discomfort from the low ammonia concentrations. To correct the situation of power failures, the AlliedSignal Hopewell plant has worked extensively with the power company
. Together we have achieved a very high degree of power stability, i.e., no total plant power failures in the last 3 years.
* In 1996, during the startup of our ammonia plant, a relief valve lifted due to a process upset and ammonia vapors again drifted off-site. The plant evaluated other ammonia facilities and determined that a change in startup operating procedures could eliminate future occurrences. We changed our procedure and have been operating since that time without any ammonia releases during startup or shutdown of the ammonia plant.
* In 1997, a pump seal failed on a methyltrichlorosilane pump allowing methyltrichlorosilane to escape and caused discomfort to an individual at a nearby facility. The process was examined and it was determined that the pump was not required and the pump was removed from the process. We have operated since then with no additional releases.
Thus, we implemented very effective actions to prevent these releases from recurring.
The AlliedSignal Hopewell plant continually strives to improve process safety at the site. Anytime new equipment is installed, it receives several reviews in our ongoing effort to maintain proven quality equipment. Also, with each new piece of equipment, we track its performance to ensure that it operates in a manner that helps us toward our plant goals of zero environmental and safety incidents. The plant receives audits, both internal and federally mandated, which help improve the level of safety performance.
Also, the plant benchmarks neighboring companies looking for ways to continually achieve a higher level of safety. Although not considered a benchmark opportunity, we found that a comprehensive incident investigation program would enhance our ability to avoid recurrence of past incidents. As one part of the investigation tool, we trained about 180 salaried and hourly employees in root cause analysis techniques. This investigative system is a methodol
ogy that drives towards removing and correcting the causes of equipment and procedural failures. It is widely used to help improve our level of safety and environmental performance.
We continually evaluate the use of highly hazardous chemicals. Recently we determined that tank car quantities of chlorine were not necessary for treating incoming river water. The tank car was replaced by smaller quantities of chlorine in 1-ton cylinders.
The AlliedSignal Hopewell plant employees continue our efforts to enhance safety and reduce risks through equipment modernization and hazard analysis for the chemicals used at the site.