Twin Rivers Technologies, L. P. - Executive Summary |
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Twin Rivers Technologies 780 Washington Street Quincy, MA 02169 1999 Risk Management Plan Presumptive Submittal Executive Summary June 17, 1999 Overview Twin Rivers strives to not only be a high quality manufacturing facility but also to be a proactively environmental and safety oriented company. We realize that our workforce is our most important asset and that the environment around us is what provides much of the quality to our lives. In maintaining both of these assets we will thrive both in our industry and in our community Twin Rivers is a manufacturer of vegetable oils and tallow fatty acids. These products meet kosher, food-grade and non-food grade standards for secondary manufacturing users such as detergent, soap and lubrication companies. Three processes shape the Twin Rivers manufacturing organization, hydrolyzation, distillation and hydrogenation for the manufacture of whole cut and blended products and fractionation for well-defined fractionated fatty acids. Twin Rivers receives raw materials via semi-tanker, railcar and ocean tankers at its on-site rail, truck and deep-water terminals. Finished products are primarily shipped to customers over Twin Rivers rail loading and delivery system, although semi-truck tankers make some deliveries. To support these operations, Twin Rivers has a workforce of highly trained technicians and managers that conduct manufacturing operations as well as support groups of environmental, laboratory, utilities and logistics technicians continuously on duty. The Twin Rivers workforce conducts operations at the facility twenty-four hour, seven-day, year round (with the exception of maintenance shutdowns). Additional support comes from Twin Rivers security services that control site access and monitor the facility on a continuous basis. As natural oil refinery environmental and safety risks are managed in three ways. First, the manufacturing systems are designed to operate in a manner that minimizes hazardou s conditions. A system of berms, relief valves, rupture disks, interlocks, manual and automatic shutoffs, alarms, isolation walls, deluge systems as well as other safety apparatus are all used to keep any situation from becoming critical and keep technicians aware of the condition of manufacturing systems at all times. Second, Twin Rivers provides complete and appropriate training and education to its workforce to minimize human failure. This includes an (approximately) three-month apprenticeship and internal process qualification for all perspective employees prior to being released to conduct manufacturing operations. Third, Twin Rivers has a staff of environmental health and safety professionals that train, inspect and correct any conditions that could become hazardous to the workforce or the surrounding environment. This group includes the Director of Environmental Safety Systems; the Health and Safety Manager, Process Safety Inspectors and a staff of licensed and certified en vironmental technicians. The Director of ESS is responsible for regulatory compliance and reporting, administrative management of the environmental technicians (qualifications, licensing etc.), safety training, and implementing new programs to mitigate unsafe conditions or actions. The Health and Safety Manager is responsible for conducting job safety analysis, on-site inspections, hazard mitigation, safety training and safety procedure development. The Process Safety Inspectors manage the PSM program that includes pressure vessel inspections, process change and material change review. The environmental technicians are responsible for the operations of the wastewater treatment and air scrubbing systems as well as hazardous materials handling, hazardous waste handling and spill response. These technicians are also trained as emergency responders for confined space entry work and have received both first aid and CPR training. The most frequent hazard encountered at Twin Rivers is that of burns due to steam exposure. Ten-pound, 150 pound and 800 pound steam are all used for process and heating purposes. Most injuries are from contact with steam heat tracing and small steam leaks. No injuries have been attributed to 800-pound steam releases at Twin Rivers. Hazardous chemicals, such as sodium hydroxide and hydrogen peroxide, are stored on site are stored in relatively small quantities (under RMP reportable thresholds) in bermed or protected areas with controlled access. Other chemicals include fuel oils (#6 & #2) used for boilerhouse operations for steam generation. The use of gaseous hydrogen at Twin Rivers considered the most potentially serious hazard. To provide more stable and less hazardous storage media, Twin Rivers has begun construction of a liquid hydrogen storage area to replace the existing gaseous storage system. This will be located at the furthest point from the Fore River Bridge and has been inspected by the local fire department and compl ies with all safety and environmental standards. The new storage area is protected in many of the same ways that the existing system. For instance, fire walls, traffic ballards, and relief valves are all used but additional protection has been added and includes a sprinkler curtains, low pressure stops, magnetic and thermal trips, fusible links, automatic shutoffs and tank pressure and level indicators and alarms will all be utilized. This area is also located at the point of use and will minimize the risk of a transmission line leak or failure that the current system is now subject. The present storage location for gaseous hydrogen utilizes protected trailers and transmits it to process via a pipeline to its production areas. The total maximum storage at this transmission point is 1539 lbs., well under the ten thousand pound threshold outline in the RMP Guidelines. The new system will contain a maximum of 13,628 pounds of liquid hydrogen. Using the RMP Comp program the worse-ca se scenario for a hydrogen fire or vapor cloud explosion delineates an evacuation area of .05 miles of the storage area. No residential or other sensitive human receptors lie within that radius and the nearest receptors are located across the Fore and Town Rivers from the facility. The rivers surfaces lie 5-10 feet below grade (depending on tide) and would not likely be impacted due to hydrogen gaseous nature in ambient air. Chemical Release Prevention and Emergency Response Policies For Twin Rivers Technologies The Twin Rivers chemical storage policy requires that only qualified individuals handle hazardous chemicals and that those chemicals be stored in bermed or protected areas with controlled and limited access. Twin Rivers presently stores all its raw materials, process materials and finished products in one of two tank farms. These tank farms are bermed systems are designed to hold up to 300% of the capacity of the largest storage tank. Twin Rivers also receives raw mate rial via its deep-water ocean terminal. All other chemicals stored on site (mostly for wastewater treatment, maintenance and utilities) also are stored in either bermed or protected areas. Emergency Response policies are outlined in Twin Rivers three response plans. These plans are the Spill Prevention & Control Countermeasures Plan ("SPCC"), a Stormwater Pollution Prevention Plan ("SPPP"), and an Oil Pollution Act ("OPA 90") Plan. The SPCC outlines the actions to be taken in the event of a chemical spill from the plant, and the necessary emergency response and regulatory agencies to notify. The SPPP defines the necessary procedures and actions to take to insure that no discharge is released through the NPDES outfall that are active during rainfall events. The OPA 90 Plan addresses oil spill prevention and response for all spills that can negatively impact groundwater aquifers, navigable waterways, estuaries or any other receiving waterbody. Twin Rivers works cooperatively with tenant and cooperator of the main tank farm, Sprague Energy, to provide oil spill prevention, mitigation, and cleanup and response preparedness. Under the Twin Rivers PSM Program all new chemicals are subject to environmental health and safety review prior to being accepted into the facility. This process provides a review for the impacts that any chemical may have on the environmental controls systems, personnel health, and defines proper storage, personal protective equipment and chemical compatibility prior to receipt. Regulated Substance Handling Although only hydrogen will exceed the reportable threshold for the Risk Management Plan, Twin Rivers has several substances that are regulated under various environmental health and safety regulations. Hydrogen is presently stored in a secured location that is remote to our process operations and has various control features that insure safe handling and operations. All hydrogen deliveries are handled by the supply-company (Air Pro ducts) that uses only specially trained workers to insure safe operations. Other regulated substances stored on site include sodium hydroxide, hydrogen peroxide, ferrous sulfate, sulfuric and hydrochloric acids, methylene chloride and etc. Uses of these chemicals vary from wastewater treatment additives to laboratory reagents. Twin Rivers manages these chemicals and the resultant wastestreams in accordance with all federal, state local regulations. Release Scenarios Worst-Case Release Scenario The worst-case scenario, as defined by the RMPComp software package, anticipates a 13628-pound release of hydrogen. This release also requires a maximum evacuation area of .05 miles. However, the RMP threshold limit and the minimum evacuation zone allowed is .1 miles, this figure can be considered to be artificially large. Alternative Release Scenario No alternative release scenarios exist at Twin Rivers Five Year Accident History Twin Rivers has had a total of four coconut oil releas es since 1994. These releases were directly related to a fault in the facility's NPDES discharge line. The largest of these spills was approximately 50 gallons. The balance of this material was captured in a sea-boom however, some of this material was released into the Town River. Twin Rivers immediately dispatched its two response boats and plant response personnel for collection and control of the material. Three similar coconut oil releases of lesser quantity occurred during the same time period. During 1998, the investigation at the time revealed the NPDES discharge line fault that was immediately remediated. Since that time, no other discharges have occurred. Twin Rivers does continue to maintain the sea-boom as a precautionary measure. The former owner, Proctor and Gamble MFG Co., experienced a petroleum oil discharge that was found to be part of an underground plume that is part of an ongoing remedial effort. To stop any continued discharge, Twin River and the former o wner of the site constructed a subsurface slurry wall, a groundwater recovery system and installed a sea-boom system similar to the one at the NPDES discharge location. All reportable, lost time and worker related injuries are reported to OSHA and the appropriate state and local agencies as required. The Emergency Response Program See: Chemical Release Prevention and Emergency Response Policies For Twin Rivers Technologies (above) Planned Changes To Improve Safety Twin Rivers continually looks at itself for improvement to its current systems and procedures. In 1998 and 1999 many projects were completed including the NPDES system repairs, and the installation of a new odor control / air handling system. Current projects now in the planning stages or underway include: * Replacement of the existing hydrogen storage and delivery system; * Replacement of the existing sodium hydroxide handling systems; * Construction of new rail and truck loading platforms; * Installation of new an d modified liquid storage tank covers; * Additional internal inspection and auditing programs; and * An emergency response / training program with the Quincy City Fire Department. Twin Rivers is a proactive in its environmental and safety programs. As a company we inspect, refine and improve all of our systems to insure a clean, safe workplace. We have set goals to meet or exceed all of our environmental permits, to maintain compliance on all regulatory fronts and to achieve an injury free workplace. |