AlliedSignal Inc. - Delaware Plant - Executive Summary |
|
The AlliedSignal Inc. Delaware Plant is a manufacturing facility located in Claymont, Delaware. It is part of the Specialty Chemicals Business Unit of AlliedSignal Inc. Headquartered in Morris Township, New Jersey, AlliedSignal is an advanced technology and manufacturing company serving customers worldwide with aerospace and automotive products, chemicals, fibers, plastics and advanced materials. With 1998 sales of approximately $15 billion, the company ranks among the top 100 of the Fortune 500. AlliedSignal has approximately 70,500 employees at 300 facilities in 40 countries. AlliedSignal operates twelve major businesses: Aerospace Equipment Systems, Aerospace Engines, Electronic and Avionic Systems, Aerospace Marketing Sales and Services, Federal Manufacturing and Technologies, Polymers, Specialty Chemicals, Electronic Materials, Consumer Products Group, Turbocharging Systems, Truck Brake Systems and Friction Materials. More information about AlliedSignal may be found at its W eb Page: www.AlliedSignal.com. It is the world wide policy of AlliedSignal to design, manufacture and distribute its products and to handle and dispose of materials throughout their life cycle in a manner that protects the environment and safeguards employees, customers and the public from unacceptable risk. AlliedSignal's complete Health, Safety and Environmental Policy may be found at the AlliedSignal Web Page. The AlliedSignal Delaware Plant participates in the Responsible Care program of the Chemical Manufacturers Association. The Community Awareness and Emergency Response Code of Responsible Care brings chemical plants and local communities together through communications and cooperative emergency planning. The AlliedSignal Delaware Plant endeavors to accomplish this by sponsoring and regularly meeting with an established local Community Advisory Panel. The Process Safety Code of Responsible Care is designed to prevent fires, explosions, and accidental chemical releases. Th e code requires safety audits, inspection and maintenance programs, and safety training for employees and contract workers. Facilities are encouraged to listen to the concerns of the community and to consider these concerns when designing and implementing process safety systems. The AlliedSignal Delaware Plant is a specialty chemical manufacturing facility that has approximately 90 employees. The products that the facility manufactures are used in a variety of applications and end uses. One of the products, Boron trifluoride, is used to make adhesives, pharmaceuticals, synthetic lubricants, and flavors/fragrances. Boron trifluoride is one of three chemicals present at the AlliedSignal Delaware Plant that are currently subject to the RMP rule. Another product, Silanes, is used as a curing agent in the manufacture of silicone sealants. One of the ingredients used to make Silanes, methyltrichlorosilane, is the second of three chemicals present at the AlliedSignal Delaware Plant t hat are currently subject to the RMP rule. Another product, Ethoxyamine, is used as the active ingredient in the manufacture of herbicides for the agricultural industry. One of the ingredients used to make Ethoxyamine, ethyl chloride, is the third of three chemicals present at the AlliedSignal Delaware Plant that are currently subject to the RMP rule. The following seven elements describe policies, activities and information at the AlliedSignal Delaware Plant which are consistent with and support the requirements of the RMP rule. 1. Accidental Release Prevention and Emergency Response Policies It is the policy of the AlliedSignal Delaware Plant to operate a safe and environmentally sound facility by identifying and controlling health, safety, and environmental risks related to its operations; by designing its processes to protect people, property and the environment; by conducting and continually reviewing and improving programs for safety, health and environmental excellence; and by establishing processes to assure that all laws and regulations applicable to its operations and products are known and observed. The AlliedSignal Delaware Plant is committed to assuring that accidental release prevention is integrated into the design and operation of processes affected by the RMP rule. This is accomplished by checking materials compatibility requirements, proper sizing and selection of equipment, providing procedures for monitoring key process conditions, employee training, conducting equipment inspections and preventive maintenance, maintaining communications systems, and observing site security and safety rules. The AlliedSignal Delaware Plant maintains a professionally trained Emergency Response Team, and emergency response equipment and supplies. The Emergency Response Team meets regularly to review emergency response procedures and conduct drills. Several members of the Emergency Response Team are also members of the local fire department and have establi shed a means of direct radio contact with the fire department in case of emergency. The supplies of emergency response equipment are inspected regularly by designated employees to assure availability and adequacy. 2. Stationary Source Description and Regulated Substances Handled The AlliedSignal Delaware Plant is located on 19.3 acres (840,000 sq. ft.). Part of the site is located in Claymont, Delaware (9.1 acres) and part of the site is located in Marcus Hook, Pennsylvania (10.2 acres). The site includes several office buildings, manufacturing buildings, storage buildings, a maintenance shop, and a laboratory building. There are approximately 90 AlliedSignal employees at the site. AlliedSignal also shares the site with another industrial chemical manufacturer. The AlliedSignal Delaware Plant operates 24 hours per day and manufactures Boron trifluoride, Silanes, and products for the agricultural industry. Each of these processes is described in more detail below. Boron triflu oride is regulated by the RMP rule. It is manufactured on the Pennsylvania side of the plant. It is a non-flammable, corrosive, compressed gas. If released to the atmosphere, it forms a dense white vapor cloud. It is packaged and shipped in cylinders and tube trailers under high pressure. The boron trifluoride process areas are equipped with water spray systems and remote operated valves designed for emergency use. Boron trifluoride is used to make adhesives, pharmaceuticals, synthetic lubricants, and flavors/fragrances. The raw materials used to produce boron trifluoride are boric acid and fluosulfonic acid. Boric acid is a solid white powder that is received in rail cars. Fluosulfonic acid is a colorless, corrosive liquid with a pungent odor and is stored on site in bulk tanks. Silanes are manufactured on the Delaware side of the plant. Silanes are colorless, aromatic liquids and are packaged and shipped in drums and totes. Silanes are used to make silicone sealants. One of the raw materials used to produce Silanes is methyltrichlorosilane. Methyltrichlorosilane is regulated by the RMP rule. It is a water-white, flammable, corrosive liquid with a pungent odor. It is received in tank trucks and stored on site in a bulk tank surrounded by a diked secondary containment system. Agricultural products are made on the Delaware side of the plant in a process known as Hocal. One of the agricultural products, Ethoxyamine, is a clear, flammable, alkaline liquid with an ammonia-like odor. Ethoxyamine is packaged and shipped in totes. One of the raw materials used to produce Ethoxyamine is ethyl chloride. Ethyl chloride is regulated by the RMP rule. It is a flammable, compressed gas and is stored on site in a bulk tank under pressure. A water spray system is available at the ethyl chloride tank storage area for emergency use. 3. Worst Case Scenarios and Alternative Release Scenarios EPA's Risk Management Program requires the AlliedSignal Delaware Plant to prepare an analysis of a hypothetical worst case release of the chemicals covered by the RMP regulations. EPA defines a worst case release as the release of the largest quantity of the chemical from a vessel or process line failure. EPA also assumes that the failure takes place over 10 minutes and that all safety systems fail to operate. In addition, the release must take place during the worst possible weather conditions. For a number of reasons discussed in this submittal, it is extremely unlikely that this event would ever occur. In addition, the AlliedSignal Delaware Plant is required to analyze the impact of an alternative accidental release scenario for the chemicals covered by the RMP regulations. The AlliedSignal Delaware Plant has three chemicals which are currently subject to the RMP rule: boron trifluoride, methyltrichlorosilane, and ethyl chloride. Boron trifluoride and methyltrichlorosilane are both classified as toxics under the RMP rule. Ethyl chloride is cla ssified as a flammable under the RMP rule. For the Delaware plant, the RMP rule requires modeling the worst case scenario for one toxic (methyltrichlorosilane in this case), the worst case scenario for one flammable (ethyl chloride in this case), and one alternative release scenario for each of the three regulated chemicals at the site. 3a. Worst Case Scenarios The worst case scenario for methyltrichlorosilane would involve the failure of the methyltrichlorosilane storage tank containing 150,000 pounds of methyltrichlorosilane. The methyltrichlorosilane would spill into a diked containment area (1875 square feet with 2-foot walls), which would mitigate the release. Since this facility is located in a populated area, the toxic cloud formed by the evaporating methyltrichlorosilane would reach offsite endpoints and nearby public receptors. The worst case scenario for ethyl chloride would involve the failure of the ethyl chloride storage tank containing 40,000 pounds of ethyl chlorid e. In accordance with the modeling requirements under the RMP rule for a flammable gas, the ethyl chloride would be released instantaneously, followed by a vapor cloud explosion. Since this facility is located in a populated area, the vapor cloud explosion would reach offsite endpoints and nearby public receptors. 3b. Alternative Release Scenarios The alternative release scenario for methyltrichlorosilane would involve a hose uncoupling during the unloading of methyltrichlorosilane into its storage tank. The methyltrichlorosilane would spill into a diked containment area (840 square feet with 1.5-foot walls), which would mitigate the release. Over the course of one hour following the spill, 2,175 pounds of methyltrichlorosilane would evaporate from the pool. Since this facility is located in a populated area, the toxic cloud formed by the evaporating methyltrichlorosilane would reach offsite endpoints and nearby public receptors. The alternative release scenario for boron trifl uoride would involve a weld failure in the high purity process piping. The high purity boron trifluoride process area is equipped with remote operated valves which would be used to isolate the leak after the release begins, thereby mitigating the release. The high purity boron trifluoride process area is also equipped with a water spray system which would be used to further mitigate the release. A total of 250 pounds of boron trifluoride would be released under pressure. Since this facility is located in a populated area, the toxic cloud formed by the boron trifluoride would reach offsite endpoints and nearby public receptors. The alternative release scenario for ethyl chloride would involve a leak from a hose during the transfer of ethyl chloride. The ethyl chloride storage area is equipped with a water spray system which would be used to mitigate the release. A total of 3,060 pounds of ethyl chloride would be released under pressure. In accordance with the modeling requiremen ts under the RMP rule for a flammable gas, the ethyl chloride release would be followed by a vapor cloud explosion. Although the vapor cloud explosion would reach offsite endpoints, the endpoint distance is relatively short and would likely not affect anyone beyond the property boundary. 4. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The general accidental release prevention program at the AlliedSignal Delaware Plant consists of 12 elements. Each of these elements is described below. Also described within each of these elements are associated chemical-specific prevention steps, where applicable. 4a. Process Safety Information Written process safety information is compiled before conducting process hazard analyses for processes involving boron trifluoride, methyltrichlorosilane, and ethyl chloride. This enables the employees involved in operating these processes to identify and understand the potential hazards associated with the processe s. The information compiled includes data on the safe use and handling of the regulated chemicals (e.g., Material Safety Data Sheets), data on the process technology (e.g., Process Flow Diagrams, process chemistry, flow rates and storage capacities, operating limits and evaluation of exceedances), and data on the equipment used in the process (e.g., Piping & Instrument Diagrams, materials compatibility, energy ratings and classification, control devices and emergency systems, ventilation systems, design basis including conformance to applicable codes and standards). The process safety information is adequate to show compliance of the process design with generally accepted good engineering practices. 4b. Process Hazard Analyses Process hazard analyses for the processes involving boron trifluoride, methyltrichlorosilane, and ethyl chloride have been completed in accordance with 29 CFR 1910.119(e) (OSHA Process Safety Management). These process hazard analyses are updated and revalid ated in accordance with 29 CFR 1910.119(e), and are retained on site for the life of the process. In general, one or more of the following methodologies are used to complete each process hazard analysis: (a) what-if evaluation; (b) checklist; (c) hazard and operability study (HAZOP); (d) failure mode and effects analysis (FMEA); (e) fault tree; (f) process mapping, and; (g) cause and effect matrix. Each process hazard analysis addresses the process hazards, process incident history, process control devices and detection systems, evaluation of failure of process control devices, equipment location, and human factors. Each process hazard analysis is performed by a team of employees having experience and knowledge of the process design and operation, and knowledge of how to complete a process hazard analysis. The Management of Change process (described below) is used to track and document process changes which occur as a result of recommendations from process hazard analyses. 4c. Ope rating Procedures Written operating procedures are prepared for each of the processes involving boron trifluoride, methyltrichlorosilane, and ethyl chloride. The operating procedures are available electronically to all plant employees via a computer program called Master Control. The Master Control program is used to meet the requirements of ISO 9000 certification for the site. The operating procedures provide clear instructions for safely conducting activities in each of the three regulated areas of the plant. The procedures are maintained up to date to reflect current operating practices, and are certified annually for accuracy. Specific information and instructions covered by the operating procedures includes startup, normal operation, emergency operation, shutdown, operating limits, operating controls, chemical-specific health and safety information, required personal protective equipment, and use of safety systems. Written procedures are also provided for specific operation s such as lockout/tagout, confined space entry, and line breaking. 4d. Training Employees currently engaged in operating processes involving boron trifluoride, methyltrichlorosilane, and ethyl chloride have received training to ensure they have the required knowledge, skills, and abilities to safely carry out the requirements specified in the written operating procedures. Refresher training is provided every three years at a minimum, or sooner if warranted by changes to operating conditions, equipment, or procedures. If refresher training is required more frequently than every three years, it would be triggered through the Management of Change process (described below). Training records are maintained for each employee to show the date training was conducted and the material covered by the training. 4e. Mechanical Integrity The AlliedSignal Delaware Plant maintains the mechanical integrity of equipment used to process and handle boron trifluoride, methyltrichlorosilane, and ethy l chloride. Such equipment includes pressurized vessels, storage tanks, piping systems, pressure relief and vent systems, emergency control devices, pumps, and valves. Written procedures are established to define the scope and requirements of the mechanical integrity program. Maintenance employees engaged in carrying out the mechanical integrity program are trained to complete the required tasks in a safe manner. One component of the mechanical integrity program includes inspection and testing of covered equipment. Equipment inspection and testing is conducted in accordance with manufacturer's recommendations and generally accepted good engineering practices. Records of inspections and testing are maintained to show the date, equipment identification, inspector, type of test or inspection performed, and test results or observations. If deficiencies are noted during equipment inspection and testing, corrective actions are taken in a timely manner to assure safe operation of the p rocess. In some cases, equipment inspections are driven by permit requirements as well as the mechanical integrity program. For example, pumps used to process methyltrichlorosilanes are inspected visually on a weekly basis, and quantitatively for leaks on a quarterly basis, in accordance with specific air permit requirements. 4f. Management of Change One component of the site's ISO 9000 certification program is a written procedure for the Management of Change. Except for "replacements in kind", any change to a process involving boron trifluoride, methyltrichlorosilane, or ethyl chloride requires completion and approval of a Request For Change prior to making the change. Such changes include new process chemicals, new technologies, new or modified equipment, new or modified operating conditions, and new or modified procedures. The Request For Change must be reviewed and approved by a team of employees having experience and knowledge of the process, knowledge of the proposed chang es, and knowledge of applicable regulatory requirements. The Request For Change must describe the proposed change and its impact on employee health and safety, the purposes and benefits of the change, the target date for the change to take effect, and whether the change is temporary or permanent. The Request For Change must also indicate whether any of the following items are required as a result of the change, and if so, who is responsible for completing these items and when they must be completed: (a) process hazard analysis; (b) new product review; (c) Piping & Instrument Diagram update; (d) operating procedure update; (e) employee training, and; (f) process safety information. Records of Requests For Change are maintained to track the status and progress of planned changes. 4g. Pre-startup Review Prior to startup of a new process involving boron trifluoride, methyltrichlorosilane, or ethyl chloride, a pre-startup safety review is conducted to ensure that the equipment and inst allation meets design specifications, a process hazard analysis has been completed, employee training has been completed, and safety, operating, maintenance, and emergency procedures are in place. A pre-startup safety review is also conducted for process changes where the approved Request For Change indicates a change in the process safety information is required. The pre-startup safety review is conducted by a team of employees having knowledge of the process, equipment, operating conditions, procedures, and safety requirements. All items on the pre-startup review checklist must be satisfied prior to commencing startup. 4h. Compliance Audits Self-assessed compliance audits for processes involving boron trifluoride, methyltrichlorosilane, and ethyl chloride are conducted every three years at a minimum to ensure that the elements of the general accidental release prevention program are up to date and are being implemented. The compliance audits are conducted by a team of employees having experience and knowledge of the covered processes, and knowledge of the program requirements. Records of the compliance audit reports are maintained to document the results of the audits and corrective actions taken, if necessary. 4i. Incident Investigation All incidents which resulted in, or could have resulted in, a release of boron trifluoride, methyltrichlorosilane, or ethyl chloride are investigated promptly. The incident investigation starts with the completion of an Incident Investigation Report prepared by the supervisor on duty at the time of the incident, and is distributed to the incident investigation team. The incident investigation team is made up of employees having experience and knowledge of the processes affected by the incident, and knowledge of completing incident investigations. Following the incident investigation, a report is prepared to include the following information: (a) date, time, and location of the incident; (b) employees involved in the in cident, and their roles; (c) date of the incident investigation; (d) names of employees on the incident investigation team; (e) description of the incident, including a chronology of events; (f) root causes and contributing causes, including conditions at the time of the incident, and; (g) recommendations to prevent a recurrence. Follow-up actions which are taken as a result of the recommendations in the incident investigation report are documented, and records of the reports and follow-up actions are maintained for a minimum of 5 years for future reference. 4j. Employee Participation All employees at the AlliedSignal Delaware Plant have opportunities to access and participate in the sharing of information related to process safety for the processes involving boron trifluoride, methyltrichlorosilane, and ethyl chloride. Each employee has computer access to operating procedures located in the Master Control program (see Operating Procedures above), including a procedure for suggesti ng changes. A safety audit card program is established to allow any employee to note observations, either positive or negative, and submit the card to the health, safety and environmental department to reinforce positive observations or to require corrective actions to mitigate negative observations. Employees in the maintenance and operating areas attend monthly safety meetings to review incidents, learn about new or modified processes, and discuss specific safety awareness topics. A special committee named the Delaware Safety Council, made up of employees from each of the functional areas of the plant, meets monthly to review the status of in-progress safety action items, review safety policies and procedures for the plant, and recommend changes if necessary. Employees routinely have opportunities to participate in other safety processes under the prevention program such as process hazard analyses, management of change, employee training, and incident investigations. 4k. Hot Wor k Permits The AlliedSignal Delaware Plant has established a hot work permit system. The hot work permit system applies to processes involving boron trifluoride, methyltrichlorosilane, and ethyl chloride. Under the system, a hot work permit must be issued prior to commencing hot work operations. Hot work operations may include burning, welding, or torch cutting. The hot work permit indicates the type and method of hot work to be conducted, the equipment the hot work will be performed on, the date, time, and location authorized for the hot work, the presence of fire prevention and protection systems meeting the requirements of 29 CFR 1910.252(a), and signatures of the supervisory employees authorizing the hot work. A separate hot work permit must be issued for each hot work operation, and a separate hot work permit must be issued for each day. A copy of the hot work permit must be displayed at the job location while hot work is in progress, and the permit is maintained on file aft er the completion of the hot work. 4l. Contractors Prior to retaining contractor services for work in the process areas involving boron trifluoride, methyltrichlorosilane, and ethyl chloride, the contractor's safety performance and program is evaluated. This includes a 3 year review of the contractor's Total Case Incident Rate (TCIR), review of OSHA recordable injuries and illnesses and corrective actions, review of Lost Work Day Cases Away (LWDCA) and corrective actions, review of the contractor's safety program including safety policies, training, and medical monitoring, and review of any applicable site-specific health and safety plan (HASP) prepared by the contractor. The information supplied by the contractor is retained on site while the contractor is engaged in work activities. Prior to commencing work on site, each contractor employee receives a safety orientation provided by AlliedSignal. The safety orientation covers information on the hazards associated with the proces s areas where the work will be performed, safety procedures and systems to be used, overview of the site emergency response program including specific procedures to be followed in case of emergency, and a review of site safety rules and applicable operating procedures. A record of each contractor employee's sign-off on the safety orientation is maintained on file at the site, including the date the training was completed. Once the safety orientation is complete, the contractor is responsible to ensure that each contractor employee performs the assigned work in a manner consistent with the information provided during the safety orientation. If the contractor assigns new employees to the job after work has commenced, the contractor must also ensure that each new employee receives a safety orientation prior to starting work on site. Failure of the contractor or any contractor employee to abide by these requirements is grounds for immediate dismissal from the site. 5. Five-Year Accide nt History In the past 5 years, there have been no accidental releases of boron trifluoride, methyltrichlorosilane, or ethyl chloride from the AlliedSignal Delaware Plant which meet the reporting requirements described in the RMP rule. 6. Emergency Response Program The AlliedSignal Delaware Plant has an emergency response program for the purpose of protecting public health and the environment. The program includes a written Emergency Response Plan, employee training in emergency response procedures, procedures to review and update the plan, and procedures for the use, inspection, testing, and maintenance of emergency response equipment. The Emergency Response Plan includes procedures for emergency response after an accidental release of boron trifluoride, methyltrichlorosilane, or ethyl chloride at the site. The Emergency Response Plan also includes procedures for administering first aid and emergency medical care as required in case of exposure following a release. The Emergenc y Response Plan includes notification procedures for informing the public and outside agencies in case an accidental release occurs. Outside agencies such as fire departments, local emergency planning committees, and state environmental agencies are notified according to regulatory reporting requirements at a minimum, and as necessary to provide or assist with emergency response. In addition, representatives of the AlliedSignal Delaware Plant meet regularly with an established local Community Advisory Panel to inform the public about relevant activities at the plant, including accidental releases. The Emergency Response Plan is coordinated with the local emergency planning committees, and information in the plan is readily available to the local emergency response officials for the purpose of developing and implementing the community emergency response plans. Offsite community response activities are implemented in accordance with the community emergency response plans as developed by the local emergency planning committees. Representatives from the AlliedSignal Delaware Plant meet regularly with the local emergency planning committees to review procedures, training requirements, equipment needs, and to conduct emergency response exercises. As part of the site emergency response program, the AlliedSignal Delaware Plant maintains a professionally trained Emergency Response Team and emergency response equipment. The Emergency Response Team conducts drills and training exercises on a regular basis to reinforce emergency response procedures and the use of emergency response equipment. Several members of the Emergency Response Team are also members of the local fire department and have established a means of direct radio contact with the fire department in case of emergency. The emergency response equipment, including spill supplies, fire protection equipment, personal protective equipment, and alarm systems, is inspected and tested regularly to ensure that it o perates properly and is being maintained. 7. Planned Changes to Improve Safety When changes at the AlliedSignal Delaware Plant are planned to improve safety for the Boron trifluoride process, Silanes process, or Hocal process, the first step in implementing the changes is to obtain approval through the management of change process. The tool we use at this site under the management of change process is the Request For Change form. A description of the most recent change to improve safety for each of the covered processes approved via the Request For Change form is provided below. The most recent Request For Change to improve safety for the Boron trifluoride process was approved on April 19, 1999. The Request For Change was approved only as a temporary condition in order to test the change for the design effectiveness. If the change is shown to meet the design effectiveness, a separate Request For Change will be prepared and approved to make the change permanent. The change invol ves the boron trifluoride high purity column control configuration. Pressure controls, level controls, and alarm setpoints will be modified to improve process safety. The most recent Request For Change to improve safety for the Silanes process was approved on March 4, 1999. The change involves upgrading the P-49 pump. The existing P-49 pump is an air operated double diaphragm pump and is prone to leakage. The pump will be replaced with a sealess vertical magnetically driven in-line pump to reduce the potential for leakage and improve process safety. The most recent Request For Change to improve safety for the Hocal process was approved on May 4, 1999. The change affects the oximation process, and is based on the results of a Process Hazard Analysis. The change includes: (1) Provide additional information in the oximation procedure about potential hazards. (2) Make pH adjustments with a different chemical to improve safety. (3) Retain process data to verify acetone levels for ea ch batch. (4) Add limits for the maximum addition of one of the chemical ingredients to two process vessels. (5) Modify the process to change the controls for the step where alkylation bottoms are added to one process vessel. (6) Reduce the alkylation bottoms high level limit in two process vessels. (7) Remove the manual mode operation for the addition of one of the chemical ingredients. (8) Add a control instrument to require the process operator to verify acetone levels prior to adding steam. (9) Install a flow indicator to verify cooling water flow to two process vessels prior to adding raw materials. |