U.S. Filter Recovery Services (California), Inc. - Executive Summary |
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This Risk Management Plan (RMP) is being submitted in accordance with California Accidental Release Program (CalARP), California OSHA's Process Safety Management (PSM) regulations, and Federal RMP requirements for a new anhydrous ammonia system installed at the U.S. Filter Recovery Services facility in Los Angeles, CA. In California, the state-equivalent of the federal RMP is the CalARP. CalARP adopted the Federal RMP elements and added many substances not regulated under the Federal RMP on the hazardous substances list. Likewise, the California Occupational Safety and Health Administration (CalOSHA) is delegated to administer the PSM program promulgated by the OSHA. PSM elements are included in RMP. In addition to Federal PSM elements, CalOSHA requires preparation of an Injury and Illness Prevention Plan (IIPP). Although IIPP is not addressed in this RMP submittal form provided by EPA, U.S. Filter has prepared an IIPP as a part of its RMP/PSM Plan to comply with CalOSHA. It is t he policy of U.S. Filter to promote and provide a safe and healthful working environment for its employees so as to minimize the risk of accidents, injuries and illness at the facility. This shall be accomplished in part through the implementation of an effective Risk Management Plan (RMP), Emergency Response Program, and Injury and Illness Prevention Program (IIPP). Health and safety is an integral part of every day operations. No employee is required to perform a task or work in an area which is not safe or healthful. Management responsibilities include implementing and upgrading safety and health policies, informing and training employees, implementing and coordinating emergency procedures, investigating accidents and identifying corrective actions to prevent a similar accident from occurring. Each employee is expected and has the responsibility to use safe work practices as a condition of employment. Employees are required to immediately alert management of any health and s afety hazard and report all accidents. U.S. Filter is engaged in material treatment and recovery processes. The facility recently installed an anhydrous ammonia system consisting of a 12,000 gallon storage tank and transfer piping for conveying ammonia to process tanks for ammoniacal etchant production. The maximum quantity of anhydrous ammonia to be stored is 10,080 gallons (or 52,000 lb at 60 degree F). Anhydrous ammonia is a regulated substance by CalARP and Federal RMP and its threshold quantity to require an RMP submittal is 10,000 lb. The anhydrous ammonia storage tank is located outside and stores anhydrous ammonia liquefied under pressure at ambient temperature. The tank is a horizontal cylindrical vessel equipped with two pressure relief valves at the top. The tank has a fill line, a vapor return line, and a transfer line to the process tanks. Each line is equipped with an excess flow limit valve that closes upon break of the pipeline or sudden flow surge. The tank is situated inside concrete berms in which unexpected spill or leak from the tank can be contained up to 35% of the maximum storage volume. An offsite consequence analysis (OCA) has been performed. The purpose of OCA is to provide information to the government and the public about the potential consequences of an accidental chemical release. Both EPA's RMP Guidance for Ammonia Refrigeration and ALOHA program have been utilized in the analysis. For the worst case, a scenario involving the storage tank failure has been selected. When the tank ruptures, ammonia is expected to form a liquid pool which rapidly evaporates as vapor and fine liquid droplets. The concrete berms around the storage tank is designed to contain up to 35% of the maximum storage volume as a preliminary mitigation measure, however, the pool is likely to overflow to the ground in case a tank full of ammonia ruptures. The maximum storage quantity of 52,000 lb is assumed to be released over 10 minutes under th e worst case weather. Distance to end point is estimated at 2.7 miles. Surrounding schools, residences, hospitals, and industries may be affected. However, given the design and structure of the tank, the chance of tank rupture is highly unlikely. Extreme cases such as a severe earthquake or plane crashing into the tank can be considered as a possible cause. Two alternative cases have been selected to analyze the release events that are more likely to occur than the worst case scenario. These cases have been reported to EPA as accidental releases by other facilities that have a similar operation as U.S. Filter. Alternative case 1 involves a release scenario caused by a 1/4" hole leak in a pipe. The pipe is assumed be short and under the tank pressure. Release duration of 20 minutes is selected assuming it will take about 20 minutes for the operator to notice the leak by the ammonia odor or visual inspection and to take a preventive action (i.e. shut off the valves). Distance t o end point for 1,980 lb of ammonia at 99 lb/ min release rate is estimated to be 0.16 mile. The public receptors within this area are nearby industries. Alternative case 2 involves a release through the pressure relief valves (PRVs). The tank is equipped with two PRVs that are set to open at 265 psig. Both PRVs are assumed to be relieving at the same time. Per the manufacturer's standard, PRVs are assumed to release over a 3 minute period. Distance to end point for 1,860 lb of ammonia at 620 lb/min release rate is estimated to be 0.42 mile. Public receptors within the distance are mainly industries. In an effort to prevent accidental releases of anhydrous ammonia and to minimize the consequences of such releases, U.S. Filter has prepared a release prevention plan in accordance with CalARP's RMP and CalOSHA's PSM rules. Prevention Program Level 3 has been applied in preparation of the RMP. Several key preventive practices have been identified during the Process Hazard Analysi s. These practices include: 1) Verify that the chemical supplier is trained and equipped with personal protective equipment. The supplier is responsible in transferring ammonia to the storage tank. U.S. Filter personnel with protective equipment is required to stand by and observe the loading/unloading procedure. 2) Maintain mechanical integrity of the system and inspect safety systems including pressure relief valves and excess flow limit valves. 3) Train the operators to follow the operating procedures established for the anhydrous ammonia system. There has been no accidental release from the anhydrous ammonia system at the U.S. Filter facility through the date of the summary, 6/18/99. It is the policy of U.S. Filter to investigate all accidental releases of regulated substances. The investigation is conducted by a team from management and operating staff. The investigation focuses on the root causes of the release and leads to recommendations for changes (if deemed neces sary) to plant operations, systems or management practices to minimize the likelihood of reoccurrence of the release in the future. Comprehensive emergency response program, when combined with emergency response training, can effectively minimize the impact of an accidental release by ensuring proper and quick facility response. U.S. Filter's emergency response program includes procedures to safely handle anhydrous ammonia and to respond to accidents such as fire, explosion, toxic releases, and earthquake. The program also addresses procedures to train personnel and to coordinate with public or local agencies in case of emergencies. U.S. Filter is an RCRA permitted facility and its majority of employees are trained in 40-hour HAZOP for emergency responses. U.S. Filter is also trained to coordinate with the City of Vernon Fire Department HAZMAT response team. Under the emergency response program, individual employees are required to immediately report all emergencies to the Area S upervisor. If the emergency is life threatening or requires immediate evacuation, the employee and/or the Area Supervisor is required to notify all employees via radio or public address system. The Emergency Coordinator is responsible for contacting the appropriate emergency response agencies. Local emergency responders include the City of Vernon Fire Department, Police Department, and Health Department. White Memorial Hospital and Los Angeles County USC Hospital are to be contacted for medical assistance. U.S. Filter's emergency program is distributed to the local and public emergency agencies as an effort to effectively coordinate emergency response actions. U.S. Filter has implemented training programs to ensure that personnel working in the facility are adequately trained and understand the process hazards and appropriate response actions. In accordance with Title 29 CFR 1910.120, training programs for the anhydrous ammonia system include initial training, refresher trainin g, hazardous materials training, maintenance training, and emergency awareness training. Majority of employees are required to attend 40-hour HAZOP training. In addition, U.S. Filter annually conducts emergency response drills. The Emergency Coordinator conducts and review the outcome of the drill. The Coordinator uses different scenarios in each drill to assure that all aspects of possible emergencies are exercised and tested. As a result of the Process Hazard Analysis as required by RMP, a list of corrective actions was generated to improve safety. The corrective action list include: 1) implementing comprehensive operating and maintenance procedures; 2) verifying safety systems such as pressure relief valves, excess flow limit valves, and scrubber; 3) placing equipment identification markings; 4) evaluating installation of gas sensors to activate ventilation fans; 4) evaluating PRV discharge pipe routing to a quench tank; and 5) evaluating installation of an interlock between the T-314 level transmitter and the ammonia flow control valve. Since the anhydrous ammonia system is still new, there are some mechanical parts that need to be replaced or installed as a result of start-up and troubleshooting. The operational procedures are expected to be revised as a result of Process Hazard Analysis. Therefore, some of the RMP elements may not have all the information required at this stage of plant development. The main elements that need to be completed are Operational Procedures and Mechanical Integrity. The changes are not likely to affect other RMP elements including offsite consequence analysis in this submittal. U.S. Filter plans to complete the necessary RMP sections and re-submit the corrected submittal (or addendum) by August 27, 1999. Management of change procedures will be followed when evaluating the impact of theses updates. |