AlliedSignal, Inc., El Segundo Works - Executive Summary |
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RMP*Submit Executive Summary El Segundo Site The AlliedSignal Inc. El Segundo site is a manufacturing facility located in El Segundo, California. It is part of the Specialty Chemicals Business Unit of AlliedSignal, Inc. Headquartered in Morristown, New Jersey, AlliedSignal is an advanced technology and manufacturing company, serving customers worldwide with aerospace, automotive products, chemicals, fibers, plastics and advanced materials. With sales of about $15 billion, the company ranks among the top 100 of the Fortune 500. AlliedSignal operates twelve major businesses: Specialty Chemicals, Aerospace Equipment Systems, Aerospace Engines, Aerospace Marketing Sales and Services, Electronics and Avionics System, Polymers, Electronic Materials, Consumer Product Group, Turbocharging Systems, Truck Brake Systems and Friction Materials. It is the worldwide policy of AlliedSignal to design, manufacture and distribute its products and to handle and dispose of materials throughout thei r 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 El Segundo site participates in the Responsible Care program of the Chemical Manufacturers Association. The Community Awareness and Emergency Response (CAER) code of Responsible Care brings chemical plants and local communities together though communication and cooperative emergency planning. The El Segundo site is a member of the Beach Cities CAER group. This is a coalition of local industry and business, which produce or use hazardous chemicals, with fire departments, police, schools and public service organizations concerned with emergency response. The El Segundo site sponsors and regularly meets with an established Community Advisory Panel that consists of local governmental agencies and citizens from the surrounding communities of El Segu ndo, Manhattan Beach, and Hawthorne. The El Segundo site through the Beach Cities CAER group and its Community Advisory Panel listens to the concerns of the community and considers their concerns when designing and implementing process safety systems. The Process Safety Code of Responsible Care is designed to prevent fires, explosions and accidental chemical releases. The code requires safety audits, inspection and maintenance programs and safety training for employees and contract workers. The El Segundo site is a hydrochlorofluorocarbon producing facility that has approximately 60 employees. The products that the facility produces are used as foam blowing agents and solvents. The facility's process involves reacting 1,1,1-trichloroethane with anhydrous hydrogen fluoride (HF). Chlorine is also used as a process chemical. HF and chlorine are on the RMP Rule's list of regulated substances. At the El Segundo site, HF and chlorine are present in quantities exceeding the RMP regulat ion's threshold quantities. The El Segundo site has devoted considerable amounts of manpower and capital to bring its computer systems to Year 2000 compliance. As an additional assurance of safe operation, the process will be shutdown on December 31, 1999 and re-started on January 1, 2000. All employees critical to the operation will be on-site during the shutdown and startup of the process. In accordance with the requirements of the RMP Rule, a description of the following seven elements is provided for the El Segundo site. 1) Accidental release prevention and emergency response policies It is the policy of the El Segundo site to operate a safe and environmentally sound facility by identifying and controlling health, safety and environmental risks related to its operation. We accomplish this goal by designing the processes to protect people, property and the environment by: ( Professional engineering and design ( Hazard assessments of critical processes (HAZOP) ( Employee tra ining ( Detailed process safety information ( Written operating procedures ( Quality maintenance and reliability practices ( State-of-the-art detection, monitoring, emergency response and mitigation systems ( Internal and external auditing practices ( Continuous improvement ( Observing all laws and regulations applicable to the operation The accidental release prevention and emergency response policy associated specifically with the facility's use of anhydrous hydrogen fluoride and chlorine involves the integration of safety devices and technologies inherent in the design of the process. This includes the use of safe operational procedures and management practices, operator training and testing of the site emergency response plan, the maintenance of onsite emergency response equipment and a professionally trained Emergency Response Team. Our efforts and resources are coordinated with local emergency response agencies. We have an ongoing effort to communicate these programs with the community. 2) Stationary source and regulated substance handled The El Segundo site uses HF as a raw material in the production of dichlorofluoroethane, chlorodifluoroethane, and hydrochloric acid. HF is stored and handled in quantities above the threshold quantity specified in the RMP Rule. The Site's stationary source of HF consists of one bulk storage tank and process distribution equipment located within the south side of the process area. HF is delivered to the site via tankcar. The tankcar's contents are unloaded by the site's specially trained serviceman into a refrigerated, above the ground, horizontal bulk storage tank identified as V-123. HF is pumped from the storage tank to reactors. The El Segundo site uses chlorine as a process chemical in the production of dichlorofluoroethane and chlorodifluoroethane. It is stored and handled in quantities above the threshold quantity specified in the RMP Rule. Chlorine is purchased from an outside vendor and delivered to the facility in one ton cylinders by truck trailers. 3) Worse case release scenario and the alternative release scenarios, including administrative controls and mitigation measures to limit the distance for each reported scenario EPA's RMP Rule requires the El Segundo site 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 El Segundo site is required to analyze the impact of an alternative accidental release scenario for the chemicals covered by the RMP regulations. Modeling P rocedures and Assumptions for Worst Case Release Scenario The offsite consequence analysis for the "worst-case release scenario" at the El Segundo site was performed for a 20,000 gallon liquid HF tankcar at ambient conditions. Utilizing EPA's RMP Offsite Consequence Analysis Guidance, the worse-case scenario releases of the contents of the tankcar showed that a hypothetical release from the tankcar would have an impact beyond the boundaries of the plant site. The assumptions used for the worst-case scenario for the anhydrous hydrogen fluoride from the tankcar were those defined and pre-set by EPA in the RMP Rule for toxic liquids. In accordance with the RMP Rule, the maximum capacity of the tankcar was assumed to be released as a gas. The assumptions followed in the modeling analysis were: ( Stability Class "F", 1.5 meters per second wind speed, an ambient temperature of 77 F and 50% relative humidity; ( El Segundo was assumed to have an "urban" dispersion environment; ( Followin g EPA Guidance the entire contents of liquid anhydrous hydrogen fluoride in the tankcar stored under ambient conditions were assumed to be released as a gas over a period of ten (10) minutes; ( An endpoint concentration of 0.016 milligram per liter of air was used for determination of offsite impact. This endpoint concentration was selected by EPA and listed in the RMP Rule specifically for anhydrous hydrogen fluoride. Modeling Procedures and Assumptions for Alternative Release Scenarios The HGSYSTEM dispersion model was used to calculate the distances to toxic endpoint for HF. The evaporation rate for the spill in the Alternate Scenario was calculated by the use of the PAVE pool evaporation model. Other assumptions used in the modeling of "Alternate" releases are given below: Neutral atmospheric stability (Class "D"); Wind speed of 3 meters per second at 10-meter height above ground; An ambient temperature of 77 F; Relative humidity at 50%; Surface roughness of 1 meter based upon EPA Guidance for "urban" dispersion Alternative Release Scenario for anhydrous Hydrogen Fluoride (HF) Under the alternative release scenario required by the RMP Rule, HF would be hypothetically released at a pressure of 25 psig and a temperature of 60 F through a flange leak that develops in a liquid outlet nozzle of the HF storage tank. The effective diameter of the flange leak is 0.25 inches. Since the HF liquid is below its boiling point, it is assumed that all the liquid reaches the ground in the form of an evaporating liquid pool. Within seconds of the release, HF atmospheric sensors stationed around the plant would automatically alert AlliedSignal operating personnel, the El Segundo Fire Department, and the South Coast Air Quality Management District of the leak. Remote controlled shutoff valves on both ends of the HF piping would be closed, thereby minimizing the quantity of HF released to the environment. Remote controlled water spray systems would be activated promptly, further reducing the impact of the release. The site emergency response team would take actions necessary to repair the leak. This release would have an offsite impact. Alternative release scenario for chlorine Under the alternative release scenario required by the RMP Rule, chlorine would be hypothetically released as a mixture of liquid and gaseous chlorine from a broken 3/8-inch line leading from a 1-ton chlorine cylinder having its contents at a temperature of 77 F. The chlorine is released at a rate of 93.8 lb./min until the cylinder is empty. Within seconds of the release, a chlorine atmospheric sensor adjacent to the chlorine cylinder would automatically alert AlliedSignal operating personnel. The HF atmospheric sensors surrounding the plant are also sensitive to chlorine, and would therefore also alert the El Segundo Fire Department and the South Coast Air Quality Management District. Remote controlled shutoff valves on the chlorine piping would be closed, thereby minimizin g the quantity of chlorine released to the environment. Remote controlled water spray systems would be activated promptly, reducing the impact of the release. The site emergency response team would take actions necessary to repair the leak. This release would have an offsite impact. 4) General accidental release prevention program and chemical specific prevention steps. The general accidental release prevention program at the El Segundo site for HF and chlorine include the following: a) Development of a Risk Management and Prevention Program (RMPP) pursuant to the State of California Health and Safety Code, Division 20, Chapter 6.95, Article 2; the RMPP Guidance document of the State of California Governor's Office of Emergency Services; the Los Angeles County Fire Department Guidelines for the Preparation of a RMPP and Seismic Assessment RMPP b) Established Process Safety Management System for the oversight of the hydrogen fluoride and chlorine processes. c) Written procedures fo r safe operation and maintenance of the system d) An on-going proactive mechanical integrity program e) Performance of process hazard analyses with prompt implementation of recommendations f) Use of safety shutdown, relief and vent system, interlocks, control instruments and process monitoring for early warning and detection g) Implementation of procedures to review and manage changes to the process h) Performance of incident investigation, process safety compliance audits and pre-startup and shutdown safety reviews i) A thorough area-specific training program for process operators and maintenance personnel The chemical specific prevention steps include: a) Developing an understanding amongst operators for hazardous properties of HF and chlorine, process chemistry and safe operational parameters such temperature, pressure and flow b) Training plant personnel about the consequences and avoidance of unsafe chemical handling, process deviation and the inadvertent mixing of incompatible chemicals c) Having knowledge of the requirements, capabilities and limitations of personal protective equipment and emergency response equipment d) Maintaining easily accessible inventories of personal protective equipment and emergency response equipment e) Designing the process technology and equipment based on a thorough understanding of the hazardous properties of HF and chlorine f) Providing operators and maintenance personnel with specialized HF and chlorine training regarding its hazards and proper handling. g) Seismic enhancements and retrofits of the foundations and steel structures that support and surround the processing equipment that handles HF and chlorine. h) Emergency holding tanks that are always kept empty, ready to receive the contents of the HF storage tanks and processing equipment. i) Automated process control systems that continuously monitor and control safety critical operations and equipment containing HF and chlorine. j) Automatic emergency power generatio n equipment and battery backup systems that will assure continuous operation of safety critical process control systems. k) Tanks and piping that contain hazardous chemicals are protected by automatic pressure relief valves that discharge into "scrubber systems" that neutralize HF and chlorine l) Automatic atmospheric sensors surround the HF and chlorine containing equipment areas. If HF or chlorine is present in the air, these sensors will immediately alert AlliedSignal operating personnel, the El Segundo Fire Department, and the South Coast Air Quality Management District. m) Remote controlled water spray systems surrounding the plant, capable of delivering up to 2500 gallons per minute of water, reducing the consequences of HF or chlorine incidents 5) Five year history During the past five years, there have been no accidental releases of HF which have had an on-site or off-site impact. . There has been one chlorine incident, which did not have an off-site impact: Date Descript ion of Event Amount Released January 24, 1996 Piping mechanic was disassembling chlorine piping, exposed to chlorine odors. Examined by Physician and released for immediate return to work. Less than 0.5 pounds 6) Emergency response program The El Segundo site has an emergency preparedness plan and response program designed to deal with accidental releases and other unplanned events involving HF and chlorine. The El Segundo site's written Emergency Action Plan and procedures provide: ( Necessary detailed emergency response instructions and training have been provided to all employees in advance of a possible disaster or emergency ( A means for the immediate notification and warning to all employees in the event of a disaster or an emergency ( Plans and instructions for immediate evacuation of employees and complete or partial shutdown of the facility if that becomes necessary ( Detailed information for responding to an emergency ( An identification of and joint training w ith local emergency response agencies The plan provides for both internal site and external community emergency notification and response. The plan addresses emergency health care, sheltering in place, evacuation, emergency responsibilities, response and control procedures. It covers emergency situations such as airplane crash, bomb threat, building collapse, civil disturbances, earthquake, explosion, fire, flood, hazardous material release, sabotage, tornadoes and utility failure. The plan provides for the implementation of an Incident Command System to direct and coordinate AlliedSignal employees and response personnel, El Segundo Fire Department personnel, and other response agencies during the site's emergency response activities. The site has provided the Emergency Action Plan to local governmental agencies and hospitals. The site maintains its own professionally trained Emergency Response Team (ERT) which is knowledgeable and prepared to respond, mitigate, and stop incident s involving accidental releases of anhydrous hydrogen fluoride and chlorine. The ERT holds quarterly plant emergency response drills. The Emergency Action Plan is continuously improved and revised. 7) Planned changes to improve safety The process hazards analysis (PHA) is updated and validated at least every five years. These PHA's were most recently completed in September of 1997. A team consisting of plant personnel and management conducted a detailed safety review of the operation. As a result, action items were identified and implemented to improve on the existing safeguards to further reduce the potential of an accidental release. Future safety improvements will be identified and implemented through risk management program audits, monthly safety audit conducted by front line supervision and site management, and continuous safety system analysis and improvement suggestions by plant operators, maintenance personnel, engineering staff, and site leadership. |