Indian Head Division, Naval Surface Warfare Center - Executive Summary |
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Executive Summary Facility Description Indian Head Division, Naval Surface Warfare Center carries out full spectrum functions for energetics research, development, manufacturing, testing, and in-service engineering. Energetics are explosives, propellants, pyrotechnics, and specialty chemicals, including their immediately related component applications such as rocket and missile propulsion units; warheads; mines; gun projectiles and propelling charges; and cartridge actuated and propellant actuated devices. The facility's scope of capabilities allow for the efficient use of specialized expertise and expensive facilities required for research and development, scale-up, manufacture, and test of energetics Covered Processes The facility has two nitration plants that produce various nitrate esters. The nitration processes conducted by the plants differ slightly from each other, but both require mixed acid. The main component of mixed acid is oleum, or fuming sulfuric acid. Oleum is listed in the Clean Air Act of 1990, Section 112(r) as a toxic substance. Both plants store oleum as a component of mixed acid in excess of the 10,000 pound threshold. There are five storage tanks in a diked area at building 781, three storage tanks in a dike at building 672, and finally two storage tanks inside building 786. Covered Process 1: Storage, Bldg. 781 Program Level: 3 Covered Chemical: Oleum, CAS 8014-95-7 Quantity: 418,535 lb Covered Process 2: Storage, Bldg. 672 Program Level: 3 Covered Chemical: Oleum, CAS 8014-95-7 Quantity: 100,426 lb Covered Process 3: Storage, Bldg. 786 Program Level: 1 Covered Chemical: Oleum, CAS 8014-95-7 Quantity: 40,974 lb Program Level 3 Worst Case Release Scenario The program level 3 worst case release scenario involves the catastrophic failure of one of the storage tanks at building 781. The process hazard analysis showed that the failure of one tank would not cause the failure of any other tanks. A single tank failure would release 139,879 pounds of oleum into a dike of 8645.5 square feet. The toxic endpoint is predicted to be 0.6 miles by the Environmental Protection Agency's (EPA) RMP*Comp software. A 0.6-mile radius circle from building 781 reaches into the Potomac River and the Mattawoman Creek, but does not affect any permanent public receptors. Program Level 3 Alternative Release Scenario The alternative release scenario involves the failure of a pump or transfer line during pumping. This scenario could occur at either building 672 or 781 and would release the oleum outside of the building dikes. Up to 441 pounds of oleum could be released during the pumping cycle of 10 minutes at building 672. At building 781, up to 385 pounds of oleum could be released during the 20 minute pumping cycle. The toxic endpoint from either scenario is predicted to be no greater than 0.1 miles using the RMP*Comp software. Program Level 1 Worst Case Release Scenario The program level 1 worst case release scenario is the catastrophic failure of one of the tanks located inside building 786. The process hazard analysis showed that the failure of one tank would not cause the failure of the other tank. A single tank failure would release 20,487 pounds of oleum into the building. The building has an area of 28,743 square feet. The toxic endpoint is predicted to be 0.2 miles by the EPA's RMP*Comp software. The toxic endpoint would not reach any offsite receptors. 5 Year Accident History The facility has had no accidents involving a covered process in the last five years. Prevention Program Overview The following paragraphs present an overview of the facility's Risk Management Program. The program is applicable to all covered processes at the facility. Process Safety Information The material safety data sheet (MSDS) supplies the required safety information. The Safety Department and the responsible office keep the MSDS. The cognizant office also has the applicable piping and co ntrol diagrams. Process Hazard Analysis The facility has a process hazard analysis (PHA) for the storage tanks. The PHA determined that it is highly unlikely that the tanks would ever suffer a catastrophic failure. The facility's safety manual requires that a hazard analysis be performed for any new or modified industrial operations. Operating Procedures Operating procedures for the processing and handling of hazardous materials explicitly describe tasks to be performed and operating conditions to be maintained. The standard operating procedures (SOPs) discuss the safety and health precautions to be taken when working with hazardous materials. The procedures must be technically accurate, include explosive safety standards, personnel qualification and certification requirements, Navy Occupational Safety and Health (NAVOSH) standards, EPA regulations and most importantly the SOP must be understandable to employees. The SOPs are revised periodically to ensure they reflect cur rent operations. SOPs are reviewed by operating personnel as well as the Safety Department to ensure job functions are carried out in a safe manner. There are also quality plans for all of the materials used by the plant. The raw materials are also bought to military specifications. Training This facility has a personnel certification process. Anyone whose duties involve explosive or hazardous materials, including the maintenance of related equipment, must be certified to perform those duties. There are three levels of operational certification and two levels of certification for observers. The operational levels are in training, operator, and lead operator. The observer levels are forbidden from performing hands on operations. Training for certification consists of on the job training, formal and informal classroom training, and sometimes independent study. Once the training is complete, the trainee is nominated for certification to the certification review board. The boa rd is comprised of the division director, branch manager, and at least one lead operator. One of the lead operators must have observed the trainee perform the duty long enough to recommend certification and is therefore typically the trainee's immediate supervisor. Personnel are trained on the standard operating procedure, workplace chemical hazards, and equipment set-up and operation in addition to on the job training. Personnel must pass an examination on the applicable operating procedure. Additionally, personnel receive a monthly hazard control briefing and an annual safety and environmental briefing. Personal certification records are kept in the division office. Mechanical Integrity This facility has a computerized preventative maintenance (PM) management system. The COMAC maintenance system issues PM requirements monthly. The computer program keeps performance records. The storage tanks' pumps and controls are covered by the PM system. Management of Change The manage ment of change is handled through the process review board (PRB), safety review committee (SRC), and the use of SOPs. See the section 'Operating Procedures' for a description of SOPs. See the section 'Pre-Start Up Review' for a description of the PRB and SRC. All active SOPs must be reviewed annually and re-approved every 4 years. Pre-Start Up Review All new explosive processes, facilities, and equipment and processes that have changed significantly must be validated as acceptable. A process review board (PRB) or a safety review committee (SRC) are the mechanisms by which to receive validation. The SRC evaluates safety, health, and environmental issues while the PRB evaluates technical, security, and quality issues in addition to those previously mentioned. A PRB is required if: new processes are scaled-up over certain limits, new ingredients are added to an existing formulation, appreciable changes are made to an existing formulation, new facilities or equipment are used, e xisting facilities or equipment are modified, a process is restarted after an explosive incident or near-miss, a process is restarted after 2 or more years, and if there is any indication that a process presents a hazard not previously encountered. The Safety Department has final say on whether a PRB or SRC is needed and can request a PRB. The PRB is comprised of the Safety and Ordnance Department heads, the Quality and Industrial Operations directors, the cognizant department head, environmental representatives, and any other personnel with specialized knowledge. The PRB is to review the following information: process description, material flow, hazardous materials, hazard analysis, scale-up justification, facilities, equipment, standard operating procedures, personnel training and certification plan, hazard control briefing, and quality assurance plans. The PRB recommendations are presented to the captain for final approval. The SRC reviews processes or changes that are deemed to not require a PRB. The SRC typically consists of a safety representative and the cognizant project engineer, though other personnel are requested to participate when needed. The SRC will review the following information: process or change description, rationale for review at the SRC level, and the hazard analysis. The SRC recommendations are presented to the cognizant division director and the Safety Department head. . Incident Investigation Two chapters of the facility's safety manual present the requirements and procedures for mishap investigations. One outlines the procedures for investigating explosive incidents and another outlines the procedures for investigating personnel injuries and illnesses. The facility investigates and reports mishaps per Operation Navy Instructions (OPNAVINST) 5100.23 and 5102.1. Explosive incidents include inadvertent detonations, arming, and launches, malfunctions, material and equipment defects, calibration failures, and near-miss inci dents. Mishaps involving explosive support equipment are covered by the same investigation procedures. The Safety Department performs an immediate investigation to assess the nature and degree of the mishap. Within 24 hours of the incident, the cognizant division director performs an investigation report for the Safety Department. The Commander appoints an investigation board to perform an informal Judge Advocate General (JAG) investigation when personnel injury is involved or the damage exceeds $10,000. The cognizant department head appoints an engineering investigation board when no injuries are involved and the damage is less than $10,000. The cognizant department head must address the findings of the investigations. The Commander approves process restart after the informal JAG investigation; the Safety Department approves restart after the engineering investigation. The Safety Department and the supervisor of the personnel involved investigate occupational fatalities, i njuries, illnesses, and near-miss incidents. The division director and department head shall review the report and recommend any corrective actions. The investigation discussed in the safety manual is independent of any investigations required by the Navy JAG. Employee Participation There is a written plan of action to incorporate employees into the risk management program. Employees are already involved in most of the risk management program elements. For example, knowledgeable area personnel required to be part of incident investigation teams and personnel attend monthly hazard control briefings where safety and environmental concerns are discussed. The most recent process hazard analysis was conducted with the assistance of employees involved with the process. The risk management plan will be supplied to the affected office for employees to review. Hot Work Permits The facility's work permit program is outlined in a separate chapter of the facility's safety manual. All work is done in compliance with 29 CFR 1910 and OPNAV 5100.23. Operating personnel must decontaminate any equipment or buildings prior to any repairs or maintenance. The supervisor of the repair or maintenance crew must obtain a work permit from the Safety Department prior to beginning any work. The crew leader or supervisor, the building supervisor and a safety inspector must inspect the work area and the work to be performed. All three parties must sign the work permit. Contractors The facility's contractor safety program is set forth in a separate chapter of the facility safety manual. All solicitations for contracts include a copy of the facility safety requirements. Contracting officers are required to have contractors acknowledge receipt of the requirements and that they understand them. The contracting officer is to maintain a safety performance plan for the duration of any contract. The safety plan is a contract submittal requirement. Pre-performance meetings ar e held to discuss safety and security concerns of both the contractor and facility. Meeting attendance by representatives of fire protection, security, occupational safety and health, and the work area are required. The Safety Department must approve all contract work through the issuance of a work permit. The safety officer that signed the work permit will periodically check the work site for safety issues. The Safety Department also performs monthly inspections of contractor work sites. Emergency Response Program The facility's Fire Department has an emergency management plan that complies with the National Response Team's Integrated Contingency Plan Guidance. Facility sites where there is potential for damage to the environment from the spill of oil or a hazardous substance are required to have spill plans. Hazardous waste accumulation sites are also required to have spill plans. These site specific spill plans are kept in the environmental office, with the Fire Department, and the cognizant office. Important sections of the plan are kept at the site. The plans are reviewed annually and resubmitted every four years regardless of any changes. The local emergency agencies have a copy of our contingency plan with our Part B permit. There are procedures to notify the public and a list of media to contact in case of an emergency. The facility has an on scene operation team (OSOT) to respond to hazardous material situations. |