Honda of America Mfg., Inc., Anna Engine Plant - Executive Summary |
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The Risk Management Plan Executive Summary The Accidental Release Prevention and Emergency Response Policies at the Honda of America Mfg., Inc.'s Anna Engine Plant: Honda of America Mfg., Inc. ("Honda") has developed and implemented two policies which directly impact and influence Honda's accident release prevention and emergency response activities. First, Honda's Safety Policy expresses Honda's commitment to: - provide a safe and healthful working environment, - conduct its operations with the highest regard for associate safety, - continually improve the safety management system, - train associates in respects to safety related to their job, and - comply with all applicable safety and health requirements and standards mandated by federal, state, and local law. Second, Honda has developed and implemented an Environmental Policy which expresses Honda's commitment to: - comply with all applicable environmental requirements mandated by federal, state, and local law, - oper ate and continually improve an environmental management system, and - implement methods to prevent pollution, conserve natural resources and reduce waste. With these policies as a foundation, Honda's Anna Engine Plant (Honda/AEP) has made a significant effort to ensure compliance and good management in all areas relating to chemical safety. Many of the Risk Management Plan (RMP) requirements are similar or identical to requirements covered by the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) program, and the two Honda processes subject to RMP regulation are already subject to PSM requirements. Moreover, even before the OSHA PSM standard was adopted as a final rule, Honda/AEP maintained a high level of protection from potential chemical exposures for all AEP associates. This was accomplished through: operational controls, systems design, mechanical integrity and associate training. Upon OSHA's final implementation of the PSM standard , existing Honda/AEP procedures were reviewed, and if needed, revised and upgraded to assure that the plant met all applicable PSM requirements. In many respects, procedures to prevent or control unwanted releases at Honda/AEP currently exceed PSM requirements relative to mechanical integrity and associate training. For example, Honda/AEP uses fixed head monitoring devices to detect leaks and/or releases, uses grade-specified components, replaces hardware prior to manufacturer-suggested replacement intervals, and has implemented comprehensive associate training. A Brief Description of the AEP Facility and the Regulated Substances Handled: Honda/AEP primarily consists of six manufacturing departments. These departments are divided into two manufacturing groups, the Engine Manufacturing Group and the Suspension Manufacturing Group. The Engine Manufacturing Group: 1. Aluminum Die Cast Department. In the Aluminum Die Cast Department, raw aluminum ingots are melted in alumin um furnaces. The molten aluminum is then injected into dies either by low-pressure casting or by high-pressure casting. Low pressure casting is used to produce engine cylinder heads. High pressure casting is used to produce engine blocks and transmission casings. 2. Aluminum Machining Department. Engine blocks and cylinder heads from the Aluminum Die Cast Department are machined into finished products for use in the Engine Assembly Department. 3. Engine Assembly Department. The Engine Assembly Department consists of three assembly lines. "0 line" assembles the Civic, Goldwing, and Valkyrie engines. "1 line" assembles four cylinder engines for the Accord and Acura models. "2 line" assembles four and six cylinder engines for the Accord and Acura models. The Suspension Manufacturing Group: 1. Ferrous Casting Department. In the Ferrous Casting Department, scrap metal is melted in a cupola and poured into sand molds to form brake disk rotors, brake drums, and cylind er sleeves. In the Quick Cast Knuckle furnace, iron is melted and poured into an alloy die to make front knuckle suspension pieces. Sulfur dioxide, a regulated substance, is used to "cure" or harden resin coated sand cores used in the "disk core" manufacturing process. Disk cores, in turn are used in the formation and molding of cast metal disk brakes. 2. Ferrous Machining Department. In the Ferrous Machining Department, the brake disk rotors, brake drums, and cylinder sleeves poured in ferrous casting are machined into finished products. In addition, inboard, inner, and outboard driveshaft parts are forged, machined, and heat-treated. Crankshafts are also machined and heat-treated. Anhydrous ammonia, a regulated substance, is used in the heat-treating (nitriding) furnace to chemically harden the surface of the crankshafts. (Note: The nitriding furnace also utilizes propane as both a fuel and chemical agent. Hower, in light of the April 27th ruling issued by U. S. Court of Appeals regarding propane, Honda/AEP does not address propane in any further detail in this submittal.) 3. Suspension Assembly Department. In the Suspension Assembly Department, driveshafts are assembled for the Accord and Acura models. Front and rear suspensions are assembled for the Accord, Acura, and Civic models. Worst-case and Alternative Release Scenarios: (Note: because of concerns expressed by various governmental officials regarding the public availability of hypothetical chemical release scenarios, and because of Honda's understanding that this issue has not yet been fully or finally resolved, Honda has not provided detailed descriptions of its release scenarios in this Executive Summary. The detailed descriptions, as required, are included in the RMP document itself.) Honda/AEP has only two regulated substances above currently effective threshold quantities: sulfur dioxide and anhydrous ammonia. The two substances, which are used in separate proc esses, both fall into the category of "regulated toxic substances". Consequently, Honda/AEP is submitting in its RMP a worst-case release scenario for sulfur dioxide (which has the greatest calculated distance to an endpoint) and alternative release scenarios for both sulfur dioxide and anhydrous ammonia. For both substances, an environmental consultant was hired to perform computer modeling to predict the impact areas for the release scenarios. The consultant used the "Process Hazard Analysis Software Tools (PHAST) model, version 5.11, to model both chemicals in a gas state. 1. Sulfur Dioxide: Sulfur dioxide is used in the disk core manufacturing process in the ferrous casting department. The disk cores are used in the manufacture of front brake disk rotors which will be mounted on the Accord, Civic and Acura models. In this process, two types of sands and two different resins are first mixed together. The mixed core sands and resins are then blown into a "core" box. Sulfur dioxide, which is stored as a liquid in cylinders located in the tank containment room, is pumped to the core-making machine where it passes through a vaporizer and is transformed into a gas. A plate is placed over the core box and the sulfur dioxide gas is introduced through the plate into the core box to cure the resins. The sulfur dioxide is purged from the core box by compressed air and vented to a caustic soda scrubber for neutralization. The finished cores are removed from the core box and inspected prior to their use in the disk manufacturing process. For sulfur dioxide, the hypothetical worst-case release scenario was modeled using an "F" atmospheric stability class based on a 10-minute instantaneous release from one of the sulfur dioxide storage vessels in the containment room. The alternative release scenario conducted for sulfur dioxide analyzed the hypothetical release of sulfur dioxide, as a gas, through a break in the line connecting two tanks in the containment room. The model used the "D" atmospheric stability class. 2. Anhydrous Ammonia: Liquid anhydrous ammonia (metallurgical grade) is stored in an 18,000 gallon- capacity tank. The ammonia is pumped to the nitriding furnace through a series of immersion heaters where the liquid is vaporized into a gas. Through overhead piping, the ammonia vapor travels through a shutoff header stand and a flowmeter stand prior to being introduced into the nitriding furnace. Due to the high temperature (1,110 degrees Fahrenheit) the ammonia dissociates into its components according to the following reaction: 2 Anhydrous Ammonia -> 2 Nitrogen + 3 Hydrogen The nitrogen combines with the alloying elements in the steel to form nitrides. The nitrides form at the steel surface as a hard chemical layer which will minimize wear and fatigue. The remaining component, Hydrogen, (3H2) is burned off by the afterburner. In accordance with the RMP rules and instructions, because the hypothetical worst case release scenario for anhydrous ammonia was estimated to affect a smaller number of public receptors than the hypothetical worst case release scenario for sulfur dioxide, the worst case release scenario for anhydrous ammonia is not being reported in the RMP. The alternative release scenario for anhydrous ammonia analyzed the hypothetical release of anhydrous ammonia, as a gas, through a line break during the loading of the storage tank. The model used the "D" atmospheric stability class. The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps at AEP: In addition to being subject to the RMP requirements, Honda/AEP is subject to and complies with the OSHA Process Safety Management (PSM) standard to prevent accidental chemical releases from the disk core manufacturing process and the operation of the nitriding furnace. Honda/AEP surpasses the requirements of various elements of the standard, including response t raining, mechanical integrity and chemical-monitoring devices to maintain high levels of compliance and prevent accidental releases. Monitoring systems have built-in back up systems to insure fail-safe operation/detection and therefore are highly reliable. The plant also exceeds training requirements and has appropriate material/equipment to control or stabilize process leaks and releases. The AEP emergency response team conducts intensive annual training regarding chemical specific response scenarios and maintains chemical specific response equipment. As a result, no significant accidental releases have occurred over the life of the various processes regulated by the PSM standard. Five-year Accident History: In the past five years, there have been two small releases of sulfur dioxide from both the tank storage area and the process area. These releases resulted in minor injuries to associates in the area of the process but did not result in any damage to on site proper ty nor did these releases result in any damage, injury, or other known impacts offsite. In the same five-year period, there have been no releases of anhydrous ammonia. The Emergency Response Program: Honda of America Mfg., Inc., has developed a company-wide Emergency Response Plan (ERP), which explains Honda's commitment to emergency response. This plan describes the responsibility and procedures of Honda personnel and establishes a system in which the members of each plant's emergency response team work with local emergency response organizations. This company-wide plan also serves as a model upon which the Honda/AEP emergency response team has based its own AEP-specific ERP. The AEP plan outlines how the Honda/AEP emergency response team is to work closely with the Anna Fire Department, the Shelby County Hazmat Team, and the Emergency Management Agency to promptly respond to any emergency. The Honda/AEP Emergency Response Team (ERT) meets annually with the Village of Anna Fire Chief and members of its response team to review operations at the plant. This meeting also includes an in-depth tour of the plant that includes inspection of sumps, hydraulic pump pits and a thorough inspection of the roof. In addition, during last October and November, the Honda/AEP ERT took part in a joint 36 hour training session with the Village of Anna Fire Department to train new members of the respective teams. The City of Sidney Fire Department conducted the training. The Anna Engine Plant Emergency Response Team is currently made up of 12 to 15 associates on each of the three production shifts. The members are volunteers who work full-time in their respective production departments. There are 3 full-time emergency response staff members, one for each shift, with one (on a rotating basis) on call 24 hours a day, who are responsible for leadership and coordination of team members. Each emergency response team member must meet Fire Fighter Level I sta te requirements as defined in section 1001 of the National Fire Prevention Association (NFPA) manual and must attend quarterly training classes and drills. Training is taught on-site by an outside training contractor in accordance with NFPA, section 600 requirements. Additionally, 5 to 10 emergency response team members on each shift are trained to the Hazmat Technician level as defined in OSHA section 1910.120 requirements. The emergency response team members are activated by procedures identified in the AEP Emergency Response Plan. If plant security, which covers the plant switchboard 24 hours a day, receives an emergency call, they are trained to activate the alarm system and alert the emergency response pagers. The response team will be activated and respond using procedures identified in the response plan. Outside agencies are activated by plant security by dialing 911 in the event that the response team requests their assistance or if the response team is not av ailable to respond at full strength. Public notification of a release will be handled jointly by the Shelby County LEPC and Sheriff's Office. The AEP Emergency Response Plan is reviewed annually with the local Emergency Management Agency (EMA), the Village of Anna Fire Department, the Shelby County LEPC, and the Shelby County Sheriff's Office. Planned Improvements to Improve Safety: In order to greatly minimize the possibility of a worst case release from its anhydrous ammonia storage tank, Honda has placed this tank in an isolated, fenced-off area subject to restricted entry, thereby limiting the types and amounts of physical activities taking place at or near the tank. In addition, Honda/AEP is currently investigating alternative manufacturing techniques that could reduce or eliminate the use of Sulfur Dioxide. This potential process modification would eliminate one of two AEP processes that are currently regulated by the PSM standard. The Risk Management Plan Executiv e Summary The Accidental Release Prevention and Emergency Response Policies at AEP: Honda of America Mfg., Inc. (Honda) has developed and implemented two policies which directly impact and influence Hondas accident release prevention and emergency response activities. First, Hondas Safety Policy expresses Hondas commitment to: ? provide a safe and healthful working environment, ? conduct its operations with the highest regard for associate safety, ? continually improve the safety management system, ? train associates in respects to safety related to their job, and ? comply with all applicable safety and health requirements and standards mandated by federal, state, and local law. Second, Honda has developed and implemented an Environmental Policy which expresses Hondas commitment to: ? comply with all applicable environmental requirements mandated by federal, state, and local law, ? operate and continually improve an environmental management system, and ? implement methods to prevent pollution, conserve natural resources and reduce waste. With these policies as a foundation, Hondas Anna Engine Plant (Honda/AEP) has made a significant effort to ensure compliance and good management in all areas relating to chemical safety. Many of the Risk Management Plan (RMP) requirements are similar or identical to requirements covered by the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) program, and the two Honda processes subject to RMP regulation are already subject to PSM requirements. Moreover, even before the OSHA PSM standard was adopted as a final rule, Honda/AEP maintained a high level of protection from potential chemical exposures for all AEP associates. This was accomplished through: operational controls, systems design, mechanical integrity, implementing specified components and associate training. Upon OSHAs final implementation of the PSM standard, existing Honda/AEP procedures were reviewe d, and if needed, revised and upgraded to assure that the plant met all applicable PSM requirements. In many respects, procedures to prevent or control unwanted releases at Honda/AEP currently exceed PSM requirements relative to mechanical integrity and associate training. For example, Honda/AEP uses fixed head monitoring devices to detect leaks and/or releases, uses grade-specified components, replaces hardware prior to manufacturer-suggested replacement intervals, and has implemented comprehensive associate training. A Brief Description of the AEP Facility and the Regulated Substances Handled: Honda/AEP primarily consists of six manufacturing departments. These departments are divided into two manufacturing groups, the Engine Manufacturing Group and the Suspension Manufacturing Group. The Engine Manufacturing Group: 1. Aluminum Die Cast Department. In the aluminum die cast department, raw aluminum ingots are melted in aluminum furnaces. The molten aluminum is the n injected into dies either by low-pressure casting or by high-pressure casting. Low pressure casting is used to produce engine cylinder heads. High pressure casting is used to produce engine blocks and transmission casings. 2. Aluminum Machining Department. Engine blocks and cylinder heads from the aluminum die cast department are machined into finished products for use in the engine assembly department. 3. Engine Assembly Department. The engine assembly department consists of three assembly lines. 0 line assembles the Civic, Goldwing, and Valkyrie engines. 1 line assembles four cylinder engines for the Accord and Acura models. 2 line assembles four and six cylinder engines for the Accord and Acura models. The Suspension Manufacturing Group: 1. Ferrous Casting Department. In the ferrous casting department, scrap metal is melted in a cupola and poured into sand molds to form brake disk rotors, brake drums, and cylinder sleeves. In the Quick Cast Knuckle f urnace, iron is melted and poured into an alloy die to make front knuckle suspension pieces. Sulfur dioxide (SO2), a regulated substance, is used to cure or harden sand molds used in the disk core making process. 2. Ferrous Machining Department. In the ferrous machining department, the brake disk rotors, brake drums, and cylinder sleeves poured in ferrous casting are machined into finished products. In addition, inboard, inner, and outboard driveshaft parts are forged, machined, and heat-treated. Crankshafts are also machined and heat-treated. Anhydrous ammonia, a regulated substance, is used in the heat-treating (nitriding) furnace to chemically harden the surface of the crankshafts and to provide fuel to the heating process. 3. Suspension Assembly Department. In the suspension assembly department, driveshafts are assembled for the Accord and Acura models. Front and rear suspensions are assembled for the Accord, Acura, and Civic models. Worst-case and Alterna tive Release Scenarios: (Note: because of concerns expressed by various governmental officials regarding the public availability of hypothetical chemical release scenarios, and because of Hondas understanding that this issue has not yet been fully or finally resolved, Honda has not provided detailed descriptions of its release scenarios in this Executive Summary. The detailed descriptions, as required, are included in the RMP document itself.) Honda/AEP has only two regulated substances above currently effective threshold quantities: sulfur dioxide and anhydrous ammonia. The two substances, which are used in separate processes, both fall into the category of regulated toxic substances. Consequently, Honda/AEP is submitting in its RMP a worst-case release scenario for sulfur dioxide (which has the greatest calculated distance to an endpoint) and alternative release scenarios for both sulfur dioxide and anhydrous ammonia. For both substances, an environmental consultan t was hired to perform computer modeling to predict the impact areas for the release scenarios. The consultant used the Process Hazard Analysis Software Tools (PHAST) model, version 5.11, to model both chemicals in a gas state. 1. Sulfur Dioxide: Sulfur dioxide is used in the disk core making process in the ferrous casting department. The disk cores are used in the manufacture of front brake disk rotors which will be mounted on the Accord, Civic and Acura models. In this process, two types of sands and two different resins are first mixed together. The mixed core sands and resins are then poured into a cold core box. Sulfur dioxide, which is stored as a liquid in cylinders located in the tank containment room, is pumped to the core-making machine where it passes through a vaporizer and is transformed into a gas. A plate is placed over the core box and the sulfur dioxide gas is introduced through the plate into the box to cure the resins. The sulfur dioxide is p urged from the core box by compressed air and vented to a caustic soda scrubber for neutralization. The finished cores are removed from the core box and inspected prior to their use in the disk manufacturing process. For sulfur dioxide, the hypothetical worst-case release scenario was modeled using an F atmospheric stability class based on a 10-minute instantaneous release from one of the sulfur dioxide storage vessels in the containment room. The alternative release scenario conducted for sulfur dioxide analyzed the hypothetical release of sulfur dioxide, as a gas, through a break in the line connecting two tanks in the containment room. The model used the D atmospheric stability class. 2. Anhydrous Ammonia: Liquid anhydrous ammonia (metallurgical grade) is stored in an 18,000 gallon- capacity tank. The ammonia is pumped to the nitriding furnace through a series of immersion heaters where the liquid is vaporized into a gas. Through overhead piping, the a mmonia vapor travels through a shutoff header stand and a flowmeter stand prior to being introduced into the nitriding furnace. Due to the high temperature (1,110 degrees Fahrenheit) the ammonia dissociates into its components according to the following reaction: 2 Anhydrous Ammonia ? 2 Nitrogen + 3 Hydrogen The nitrogen combines with the alloying elements in the steel to form nitrides. The nitrides form at the steel surface as a hard chemical layer which will minimize wear and fatigue. The remaining component, Hydrogen, (3H2) is burned off by the afterburner. In accordance with the RMP rules and instructions, because the hypothetical worst case release scenario for anhydrous ammonia was estimated to affect a smaller number of public receptors than the hypothetical worst case release scenario for sulfur dioxide, the worst case release scenario for anhydrous ammonia is not being reported in the RMP. The alternative release scenario for anhydrous ammonia analyzed the h ypothetical release of anhydrous ammonia, as a gas, through a line break during the loading of the storage tank. The model used the D atmospheric stability class. The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps at AEP: In addition to being subject to the RMP requirements, Honda/AEP is subject to and complies with the OSHA Process Safety Management (PSM) standard to prevent accidental chemical releases from the disc core making process and the operation of the nitriding furnace. Honda/AEP surpasses the requirements of various elements of the standard, including response training, mechanical integrity and chemical-monitoring devices to maintain high levels of compliance and prevent accidental releases. Monitoring systems have built-in back up systems to insure fail-safe operation/detection and therefore are highly reliable. The plant also exceeds training requirements and has appropriate material/equipment to control or stabili ze process leaks and releases. The AEP emergency response team conducts intensive annual training regarding chemical specific response scenarios and maintains chemical specific response equipment. As a result, no significant accidental releases have occurred over the life of the various processes regulated by the PSM standard. Five-year Accident History: In the past five years, there have been two small releases of sulfur dioxide from both the tank storage area and the process area. These releases resulted in minor injuries to associates in the area of the process but did not result in any damage to on site property nor did these releases result in any damage, injury, or other known impacts offsite. In the same five-year period, there have been no releases of anhydrous ammonia. The Emergency Response Program: Honda of America Mfg., Inc., has developed a company wide Emergency Response Plan (ERP), which explains Hondas commitment to emergency response. This plan descri bes the responsibility and procedures of Hondas personnel and a system in which all members of each plants emergency response team will work with local emergency response organizations. This company wide plan acts as a guideline for the Honda/AEP emergency response team to develop a plant specific ERP. This plan in turn outlines how the Honda/AEP emergency response team is to work closely with the Anna Fire Department, the Shelby County Hazmat Team, and the Emergency Management Agency to execute a smooth stop to any emergency. The Honda/AEP Emergency Response Team (ERT) meets annually with the Village of Anna Fire Chief and members of its response team to review operations at the plant. This meeting also includes an in-depth tour of the plant that includes inspection of sumps, hydraulic pump pits and a thorough inspection of the roof. In addition, during last October and November, the Honda/AEP ERT took part in a joint 36 hour training session with the Village of Anna Fire Department to train new members of the respective teams. The City of Sidney Fire Department conducted the training. The Anna Engine Plant Emergency Response Team is currently made up of 12 to 15 associates on each of the three production shifts. The members are volunteers who work full-time in their respective production departments. There are 3 full-time emergency response staff members, one for each shift, with one (on a rotating basis) on call 24 hours a day, who are responsible for leadership and coordination of team members. Each emergency response team member must meet Fire Fighter Level I state requirements as defined in section 1001 of the National Fire Prevention Association (NFPA) manual and must attend quarterly training classes and drills. Training is taught on-site by an outside training contractor in accordance with NFPA, section 600 requirements. Additionally, 5 to 10 emergency response team members on each shift are trained to the Hazmat Technicia n level as defined in OSHA section 1910.120 requirements. The emergency response team members are activated by procedures identified in the AEP Emergency Response Plan. If plant security, which covers the plant switchboard 24 hours a day, receives an emergency call, they are trained to activate the alarm system and alert the emergency response pagers. The response team will be activated and respond using procedures identified in the response plan. Outside agencies are activated by plant security by dialing 911 in the event that the response team requests their assistance or if the response team is not available to respond at full strength. Public notification of a release will be handled jointly by the Shelby County LEPC and Sheriffs Office. The AEP Emergency Response Plan is reviewed annually with the local Emergency Management Agency (EMA), the Village of Anna Fire Department, the Shelby County LEPC, and the Shelby County Sheriffs Office. Planned Improvements to Imp rove Safety: In order to greatly minimize the possibility of a worst case release from its anhydrous ammonia storage tank, Honda has placed this tank in an isolated fencedoff area subject to restricted entry, thereby limiting the types and amounts of physical activities taking place at or near the tank. In addition to the preventive steps listed above, Honda/AEP is currently investigating alternative manufacturing techniques that could reduce or eliminate within the next two years the use of Sulfur Dioxide. This potential process modification would eliminate one of two AEP processes that are currently regulated by the PSM standard. Honda/AEP notes that the nitriding furnace also utilizes propane as both a fuel and chemical agent. However, in light of the April 27th ruling issued by U. S. Court of Appeals regarding propane, Honda/AEP does not address propane in any further detail in this submittal. 2 1 |