Mine Safety Appliances - Evans City Operations - Executive Summary |
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EXECUTIVE SUMMARY RMPSUBMIT Mine Safety Appliances Company Evans City, PA 16033 June 14, 1999 General Mine Safety Appliances Company (MSA) is committed to protection of human health and the environment. This commitment is supported by its Code of Ethical Conduct and policies on Business Ethics, Workplace Health and Safety, and Environmental Law Compliance and Management. All divisions of MSA actively support these policies, including the two divisions at the Evans City Operations - the Callery Chemical Company Division (Callery) and the Safety Products Division (Safety Products). Callery provides and coordinates all facility-wide environmental, health and safety policies, practices and procedures, while each division is responsible for environmental, safety, and health compliance programs that only apply to the division. The Evans City Operations is located in Butler County at 1420 Mars-Evans City Road between Mars and Evans City, Pennsylvania. A small portion of the facility l ies within the Borough of Callery; the majority is within Forward Township. MSA owns approximately 100 acres but only 30 acres have been developed for commercial use. EPA's Chemical Accident Prevention Provisions, 40 CFR Part 68, also known as the Risk Management Program, were created to reduce the probability and severity of accidental releases and to stimulate dialogue between industry and the public to improve accident prevention and emergency response. In an effort to better educate the community, MSA has presented a summary of the Evans City Operations Risk Management Program to the Local Emergency Planning Committee (LEPC), local firefighters, MSA Community Awareness and Emergency Response (CAER) Committee, and its own employees. This written summary should also help other members of the community understand MSA's Risk Management Program. Additional information is available by calling the CAER Committee Infoline, (724) 538-8944. Regulated Substances MSA manufactures a va riety of products at the facility. Safety Products manufactures and assembles rubber products, such as facepieces for self-contained breathing apparatus (SCBA) used by firefighters. They also manufacture chemical oxygen generating devices which are used in an emergency by miners and military personnel. This Division does not use any chemicals in sufficient quantity to be subject to the Risk Management Program. Callery manufactures a range of chemicals based on alkali metal chemistry and boron hydride chemistry. Its products are used in the pharmaceutical and electronics industries. Boron trifluoride (BF3), Chemical Abstract Services Registry Number 7637-07-2, is the only substance used at the Evans City Operations in quantities above the Risk Management Program regulated threshold quantity. That regulatory threshold is 5,000 pounds for BF3. Callery receives BF3 in specially constructed, Department of Transportation-certified, tube trailers with six or more individual high press ure tubes permanently mounted to a truck trailer. Up to 22,000 pounds of BF3 may be onsite at one time. The BF3 is directly piped to Callery's process from the tube trailer which is standard industry practice. BF3 is commonly used throughout the world to manufacture synthetic motor oils, adhesives, pharmaceuticals, and flavors and fragrances. Callery uses it to manufacture diborane, which is a basic boron chemical. Other materials listed by EPA in 40 CFR Part 68 are purchased, stored and consumed in quantities below their threshold quantities. Callery has a procedure to limit the amount of these materials purchased and stored onsite such that they will not exceed these thresholds. Release Scenario EPA's Chemical Accident Prevention Provisions require the preparation of a worst case and an alternate (or more likely) case scenario for the release of the regulated substances. These release scenarios were prepared in 1996 for MSA by JBF ASSOCIATES, INC. (now ABS Group Inc., Risk & Reliability Division), a professional firm that provides modeling services. The model used for the scenarios was the SLAB dense gas dispersion model. The SLAB model is capable of modeling dispersions of high pressure releases of heavier than air gases, such as BF3. The worst case scenario involves the catastrophic failure of one of the high pressure tubes on the BF3 trailer, resulting in a release of 3700 pounds of BF3 gas over a 10 minute period. The alternative scenario involves the failure of the one quarter inch diameter unloading line from the tube trailer to the first pressure regulator in the facility's BF3 system. The result would be a release of 2340 pounds of BF3 over a 30 minute time period. It is assumed that it would take Callery personnel 30 minutes to detect the release and close the remote shutoff valve on the tube trailer. By procedure, BF3 is never transferred or used without supervision by a trained operator. Emergency Response Program The facility maintain s a detailed Emergency Preparedness Plan. The Plan is reviewed and updated at least annually. It details responsibilities and actions to be taken by facility personnel as well as outside response organizations. The facility has its own Emergency Response Team. They, along with community firefighters, emergency medical services, HazMat teams, and the LEPC have been trained to handle and to respond to a release of BF3 by the manufacturer of BF3. In addition, they have held their own practice drills. MSA works closely with the LEPC and other community responders to prepare and preplan for proper response. The proper response to a release of BF3, which is a corrosive gas and will produce a white cloud, is to hit it with water spray in order to prevent its offsite migration by knocking down the cloud. If the BF3 cannot be controlled this way, it will eventually react with moisture in the atmosphere or be diluted enough in the air so that it is no longer a hazard. MSA installed a Community Alert System (siren and community education program) in 1998. For a release of BF3 with offsite consequences, the proper community response is to shelter in place to prevent exposure to the material. If needed, the siren would be used to alert the community to shelter in place and take proper precautions. An all clear signal will let the community know that the emergency is over. Information on the alert system has been distributed to those in the community within the audible range of the siren. Drills are conducted twice a year. The alert system may also be activated for weather emergencies at the request of the Butler County EMA Director. If the Community Alert System is activated, MSA will also call 911 to activate the offsite response plan developed by MSA and the LEPC. The LEPC has developed a plan in conjunction with local industry to address road closures, etc, if they were ever to become necessary. Release Prevention The facility uses a number of programs t o design, operate and maintain a safe facility and prevent releases. These programs include but are not limited to the following: 7 The OSHA Process Safety Management (PSM) standard. 7 Conducting Process Hazard Analysis studies. 7 Writing and implementing a series of Environmental, Safety and Health procedures. 7 Preparing and implementing a site Emergency Preparedness Plan. 7 Extensive use of computer control and monitoring of chemical processes. 7 Installation and use of on-site fire and leak detection systems. 7 Maintenance of on-site fire detection and suppression systems. 7 Continuous training of operations personnel utilizing Standard Operating Procedures (SOPs). 7 Implementation of a Contractor Safety Program. 7 Implementation on an Incident Investigation procedure. 7 The use of a computerized maintenance management system to implement a preventive maintenance program. 7 Equipment lockout, tagout (Control of Hazardous Energy) procedures, Hotwork (Flame and heat producing activ ities), and line breaking procedures. Five Year Accident History All incidents for the past 5 years were reviewed for actual or potential off-site consequences. No incidents during the past 5 years were found to have actual or potential off-site consequences. Planned Changes to Improve Safety The facility reviews its manufacturing processes on a regular basis in order to improve the processes, related procedures, and plans. The BF3 system was revised for improved reliability in the first quarter of 1999 after a complete Process Hazard Analysis. No further changes to the system are planned. MSA's Commitment MSA's Evans City Operations is committed to making continual efforts to improve its processes, procedures, and plans. Preventing accidents is an important part of our efforts. Preplanning and practicing response with both MSA's Emergency Response Team, the community's firefighters, and the LEPC is an important part of our emergency planning. |