AlliedSignal, Inc. - Buffalo Research Laboratory - Executive Summary |
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RMP*Submit: Executive Summary AlliedSignal, Inc. Buffalo Research Laboratory The AlliedSignal Inc. Buffalo Research Laboratory is a research and development facility located in Buffalo, New York. 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 Web 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 Buffalo Research Laboratory 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 Process Safety Code of Responsible Care is designed to prevent fires, explosions, and accidental chemical releases. The code requires safety audits, i nspection 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 Buffalo Research Laboratory endeavors to accomplish this by our regular participation in the South Buffalo Community Forum, a local Community Advisory Panel. The AlliedSignal Buffalo Research Laboratory employs approximately130 employees including Ph.D. chemists, chemical engineers as well as industry experienced professional and hourly personnel. We serve as the primary Specialty Chemicals business unit Research and Development facility in North America. The Buffalo Research Laboratory is positioned to conduct R&D activities from bench through pilot scale. Our Pilot Plant is utilized to transfer technology from laboratory scale methods to develop commercial scale chemical processes for our manufacturing sites, as w ell as engaging in small-scale production for pre-commercialization and market acceptance testing. Historically, this site has focused on fluorine based chemistry, handling materials such as hydrofluoric acid, anhydrous hydrogen fluoride, chlorine and boron trifluoride. Recently, the site has diversified and is conducting R&D work for our pharmaceutical and agricultural business enterprises. The two chemicals on site included in the RMP Rule's list of regulated substances are boron trifluoride and ethyl ether. The AlliedSignal Buffalo Research Laboratory uses boron trifluoride and ethyl ether in a "covered process" as defined by EPA. Both chemicals are stored on-site above the Rule's specified threshold quantity and are therefore regulated under the RMP Rule. In accordance with the requirements of the RMP rule, a description of the following seven elements is provided for the AlliedSignal Buffalo Research Laboratory: 1. Accidental release prevention and emergency response policies: It is the policy of the AlliedSignal Buffalo Research Laboratory to operate a safe and environmentally sound facility by identifying and controlling health, safety, or 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 accidental release prevention and emergency response policy associated specifically with the laboratory's use of boron trifluoride and ethyl ether involves the integration of safety devices and technologies inherent in the design of the process, safe operational procedures and management practices, operator training, the preparation and testing of site emergency response plans, the maintenance of onsite emergency response equipment. We h ave a professionally trained Emergency Response Team, which coordinates our efforts and resources with local emergency response services, and the community. 2. The regulated substance handled: The AlliedSignal Buffalo Research Laboratory uses boron trifluoride and ethyl ether as the raw materials in our work on one of several boron trifluoride complexes. They are stored and handled in quantities that exceed the threshold quantity specified in the RMP Rule. Boron trifluoride is shipped in a multi-unit tube trailer, and is positioned in an area adjacent to our pilot plant, which is located in the Northwest corner of our site. The ethyl ether is shipped in a tank trailer and is positioned in a diked area adjacent to the pilot plant. Both the boron trifluoride tube trailer and ethyl ether tank truck are connected to independent distribution systems which deliver the materials to a reactor located on the second floor of the pilot plant. The ethyl ether is stored as a liquid in the tank truck. Transfer is accomplished by pressurizing the tank truck with nitrogen, moving the liquid to the reactor, which is at atmospheric pressure. Boron trifluoride is stored as a high-pressure gas in the tube trailer and transfer is accomplished by pressure difference between the reactor and the tube trailer. 3. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distance for each reported scenario: EPA's Risk Management Program requires the AlliedSignal Buffalo Research Laboratory to prepare an analysis of a hypothetical worst case release of the chemicals covered by the RMP regulation. 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 possibl e 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 Buffalo Research Laboratory is required to analyze the impact of an alternative accidental release scenario for the chemicals covered by the RMP regulations. The offsite consequence analysis for a "worst-case toxic release scenario" at the Buffalo Research Laboratory was performed for the largest single tube, containing 3,500 lbs. of boron trifluoride, on a multi-tube trailer. The tube is a horizontal, cylindrical steel tube mounted on a trailer, which is located adjacent to our pilot plant. The parameters used for the worst-case release scenario for the boron trifluoride source were those defined and pre-set by EPA in the RMP Rule for toxic gasses. In accordance with the Rule, the maximum 3,500lb. full capacity content of a single tube was assumed to be released over 10 minutes. The methodology recommended in EPA's Offsite Consequence Analysis Guidance document was used to determine the distance traveled by the boron trifluoride vapors before the concentration of the vapors decreased to an endpoint concentration of 0.028 milligrams per liter of air. Since the Buffalo Research Laboratory is located in an urban area, the vapors would reach offsite endpoints and public receptors. This endpoint concentration was selected by EPA and listed in the RMP Rule specifically for boron trifluoride. The offsite consequence analysis for an "alternate-case toxic release scenario" at the Buffalo Research Laboratory was performed based on an operational review of the process, which identified a leak in a process line. The failure results in the release of 420 lbs. of boron trifluoride, stored at ambient temperature and 1,600 psi. Active mitigation systems in the form of a water deluge system and an emergency shutdown system were considered in this scenario. Since the Buffalo Research Laboratory is located in an urban area, the vapors would reach offsite endpoints and public receptors. The endpoint concentration of 0.028 milligrams and the parameters used for the alternate-case release scenario for the boron trifluoride source were those defined and pre-set by EPA in the RMP Rule for toxic gas. The offsite consequence for a "worst-case flammable release scenario" at the Buffalo Research Laboratory was performed for the entire contents of the ethyl ether tank trailer, which is 40,000 lbs. The tank trailer is located on a concrete dike in an area adjacent to the pilot plant. The parameters used for the worst-case release scenario for an ethyl ether source were those defined and pre-set by EPA in the RMP Rule for flammable liquids. In accordance with the Rule, the maximum 40,000lb. capacity contents of the tank are assumed to be released, forming a liquid pool in the dike. The vapor cloud which forms over a ten minute period is assumed to ignite and explode. The methodology recommend ed in EPA's Offsite Consequence Analysis Guidance document was used to determine the distance at which an over pressurization of 1psi would be experienced as a result of a vapor cloud explosion. Since this site is located in an urban area, the effects of an over pressurization above 1 psi would be experienced at offsite endpoints and by public receptors. This endpoint effect was selected by EPA and listed in the RMP Rule specifically for flammable liquids. The offsite consequence for an "alternate-case flammable release scenario" at the Buffalo Research Laboratory was performed based on an operational review of the process, which identified a valve seal failure in a process line. As a result of the valve seal failure, ethyl ether is released into the "V" shaped dike and confined to a 64 ft2 area, which ignites. Modeling analysis indicates that the flammable vapors would be confined to an area relatively close to the spill so that over-pressurization associated with the ignition wou ld be minimal. Therefore, the only impact considered was thermal radiation from the pool fire. Modeling analysis indicates the effects of the 5000 watt/m2 endpoint would not reach over the property line and therefore no offsite endpoints or public receptors would be effected. The parameters used for the alternate-case release scenario for ethyl ether source were those defined and pre-set by EPA in the RMP Rule for flammable liquids. 4. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The general accidental release prevention program at the AlliedSignal Buffalo Research Laboratory consists of 12 elements. Each of these elements is described below. 4a. Process Safety Information Written process safety information is compiled before conducting process hazard analyses for processes involving boron trifluoride and ethyl ether. This enables the employees involved in operating these processes to identify and understand the potential hazards asso ciated with the processes. 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 or ethyl ether have been completed in accordance with 29 CFR 1910.119(e) (OSHA Process Safety Management). These process hazard analyses are updated and revalidated 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. 4c. Operating Procedures Written operating procedures are prepared for the boron trifluoride complex project, which uses both boron trifluoride and ethyl ether. The operating proc edures provide clear instructions for safely conducting activities in the pilot 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. 4d. Training Employees currently engaged in operating the boron trifluoride process in the pilot plant 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 year at a minimum, or sooner if warranted by changes to operating conditions, equipment, or procedures. If refresher training is required more frequently than every year, it wo uld 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 Buffalo Research Laboratory maintains the mechanical integrity of equipment used in the boron trifluoride complex project. Such equipment includes pressure vessels, 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 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 process. 4f. Management of Change One component of the site's Temporary Operating Permit (TOP) program is a written procedure for the Management of Change. Except for "replacements in kind", any change to a process involving boron trifluoride or ethyl ether requires completion and approval of a Management of Change (MOC) form prior to making the change. Such changes include new process chemicals, new equipment or facility changes, new assignments of personnel or new procedures. The Management of Change forms are submitted to the Project Permit Administrator and are maintained in files with the original Temporary Operating Permit documentation 4g. Pre-startup Review Prior to startup of a new process involving boron trifluoride or ethyl ether, a pre-startup safety review is conducted to ensure that the equipment and installation 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. 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 or ethyl ether are conducted 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 that resulted in, or could have resulted in, a release of boron trifluoride or ethyl ether are investigated promptly. The incident investigation starts with the completion of an electronic Incident Investigation Report prepared by the employee(s) involved and the supervisor on duty at the time of the incident, and is distributed electronically to the site leadership, department management and the union management safety committee. The incident investigation team is made up of employees having experience and knowledge of the processes affected by the incident, their supervisors and the project manager were appropriate. 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 incident; (c) date of the incident investigation; (d) description of the incident, including a chronology of events; (e) root causes and co ntributing causes and; (f) 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 Buffalo Research Laboratory involved in the boron trifluoride complexes project have opportunities to access and participate in the sharing of information related to process safety for the process involving boron trifluoride and ethyl ether. 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. Employees routinely have opportunities to participate in other safety processes under the prevention program such as process hazard analyses, employee training, and incident investigations. 4k. Hot Work Permits The AlliedSignal Buffalo Research Laboratory has established a hot work permit system. The hot work permit system applies to processes involving boron trifluoride or ethyl ether. 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 shift. 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 after the completi on of the hot work. 4l. Contractors Prior to retaining contractor services for work in the process areas involving boron trifluoride and ethyl ether the contractor's safety performance and program is evaluated. This includes a 3 year review of the contractor's Total Case Incident Rate (TCIR), OSHA recordable injuries and illnesses, Lost Work Day Cases Away (LWDCA), review of the contractor's safety program including safety policies, training, and 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 process areas where the work will be performed, safety procedures and systems to be used, overview of the site emergency response program including s pecific 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. The five year accident history: No accidental releases (as defined by EPA in the RMP Rule) from the boron trifluoride process involving either boron triflu oride or ethyl ether have occurred at the AlliedSignal Buffalo Research Laboratory in the past five years. 6. The emergency response program: The AlliedSignal Buffalo Research Laboratory has an emergency preparedness planning and response program designed to deal with accidental releases and other unplanned events associated with the facility's research and development activities, including the boron trifluoride complexes project. The Site has a written Emergency Response Plan that addresses various types of contingencies including specific actions for responding to an accidental release of boron trifluoride or ethyl ether. The Plan addresses emergency health care, sheltering in place, evacuation, emergency responsibilities, response and control procedures, and emergency equipment. The Plan provides for the implementation of an Incident Command System to direct and coordinate the Site's response activities. The Plan has been coordinated with the LEPC and with the Buffalo Fir e Department who would direct all offsite community response activities. The AlliedSignal Buffalo Research Laboratory maintains its own professionally trained Emergency Response Team (ERT) which is knowledgeable and prepared to respond to incidents involving accidental releases of boron trifluoride or ethyl ether. The ERT holds annual Plant emergency response drills and exercises that have been conducted jointly with the Buffalo Fire Department response group. The Plan also provides for both internal site and external community emergency alerting and notification. Through a contractual agreement set up and funded by AlliedSignal's Buffalo Research Laboratory, along with two other neighboring industries, approximately 5,000 residents within the surrounding community can be notified of an emergency situation via a Community Alert Network (CAN System). Within minutes of an incident, the CAN System will begin placing computerized telephone calls with a recorded message to neighbori ng homes. The message is designed to give residents information concerning the nature of the incident and the appropriate actions to be taken, such as sheltering in place. 7. Planned changes to improve safety: The most recent process hazard analysis of the boron trifluoride process was completed in October of 1998. As a result of this systematic safety review, several action items were identified and implemented to improve upon the existing safeguards of the covered process and to further reduce the potential for accidental release. The process hazard analysis for the boron trifluoride process will be reviewed and revalidated every five years. |