AlliedSignal, Inc. - Executive Summary |
|
RMP*Submit: Executive Summary Orange Plant The AlliedSignal Inc. Orange plant is a manufacturing facility located in Orange, Texas. 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 ab out AlliedSignal may be found at its Web Page: www.AlliedSignal.com. It is the worldwide policy of AlliedSignal to design, manufacture and distribute its products and to handle and dispose of materials throughout their life cycle. AlliedSignal does this 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 Orange plant supports the Responsible Care initiative developed by the Chemical Manufacturers Association. The Community Awareness and Emergency Response (CAER) Code of Responsible Care brings chemical plants and local communities together through communications and cooperative emergency planning. The AlliedSignal Orange plant has established two-way communications by sponsoring and regularly meeting with a multi-industrial local Community Advisory Panel since 1992. The Community Advisory Pane l was heavily involved in the Orange County's industrial RMP communications/public awareness efforts. Another Responsible Care Code is the Process Safety Code, which 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. 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 Orange plant is a polyethylene wax manufacturing facility that currently employs 100 personnel with an annual payroll of $5 million. In addition, the plant purchases in excess of $34 million worth of raw materials, supplies and services from local vendors. The Orange plant pays approximately $1 million annually in local and state taxes. Major uses of the polyethylene that the facility manufactures are as additives into plastics, polish, textiles, rubber, paper, paint, cable filler, inks, adhesives, cosmetics, pharmaceuticals, agricultural, and wax blends. The facility's manufacturing process involves polymerizing ethylene, with the introduction of vinyl acetate and acrylic acid into the process, to produce a variety of polyethylene waxes. Two of these chemicals, vinyl acetate and ethylene, are on the EPA list of chemicals regulated by the RMP regulation. The following seven elements describe policies, activities and information at the AlliedSignal Orange 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 Orange 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 improv ing 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 Orange 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 plant security and safety rules. The AlliedSignal Orange plant's emergency response policy 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 plant emergency response pl ans, the maintenance of onsite emergency response equipment, the coordination with local emergency response services, and communicating with the community. 2. The stationary sources and regulated substances handled: The AlliedSignal Orange plant operates 24 hours per day and uses two RMP regulated chemicals, vinyl acetate and ethylene, as raw materials in the manufacture of various grades of polyethylene wax. Vinyl acetate is stored in quantities that exceed the threshold quantity specified in the RMP Rule. Vinyl acetate is purchased from an outside vendor and is delivered to the Plant via tank truck on an "as needed" basis. The tanker's contents are unloaded by plant operators into an above ground bulk storage tank identified as RC-835 which is located on the east side of the plant. The maximum capacity of the storage tank is 10,000 gallons. Vinyl acetate is pumped from the storage tank through a piping system into the production area where it is fed into the polyethylene wax unit. Ethylene is used in quantities that exceed the threshold quantity specified in the RMP Rule. The plant's stationary source of ethylene consists of three reaction vessels. Ethylene is brought into the plant from either of two outside vendors via one pipeline on a continuous basis. Ethylene is transferred through an enclosed piping system into the production area where it is fed into the three reactors in the polyethylene wax unit. 3. The worst-case release scenarios and the alternative release scenarios, including administrative controls and mitigation measures to limit the distance for each reported scenario: EPA's Risk Management Program requires the Orange plant to prepare an analysis of a hypothetical worst case release of the chemicals covered by the RMP regulation. EPA defines a worst case scenario as the release of the largest quantity of the chemical from a vessel. EPA also assumes that the release takes place over 10 minutes and that all safety systems fail to oper ate. In addition, the release must be assumed to 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 Orange plant is required to analyze the impact of an alternative accidental release scenario. The alternative scenario involves a technical evaluation of a more realistic accidental release that could cause off-plant impact. In this scenario, safety control systems are assumed to operate as designed. The AlliedSignal Orange Plant has two chemicals that are currently subject to the RMP rule: vinyl acetate and ethylene. Vinyl acetate is classified as a toxic substance and ethylene is classified as a flammable substance under the RMP rule. For the Orange plant, the RMP rule requires modeling the worst case scenario for one toxic (vinyl acetate in this case), the worst case scenario for one flammable (ethylene in this case), and one alternative release sc enario for each of the two regulated chemicals at the plant. a) Worst Case Scenarios The Orange plant's worst case scenario for vinyl acetate is the hypothetical failure of the storage tank containing a maximum of 78,000 pounds of vinyl acetate. All active safety control systems are assumed to have failed and no emergency response takes place after the release. The methodology recommended in EPA's Offsite Consequence Analysis Guidance document was used to determine the impact of the release. Under these unlikely assumptions, the vaporized vinyl acetate would reach offsite public receptors. The worst case scenario analysis for ethylene assumed the failure of the three reactors and the release and explosion of 15,000 pounds of ethylene. Using the EPA selected endpoint, a 1 psi overpressure, for such a release, there would be would an impact at a neighboring industrial site but none on any residential population. b) Alternative Scenarios The alternative release scenario for vinyl a cetate involves a leak in a three-inch transfer hose during the unloading of vinyl acetate from a tank truck into its storage tank. The standard operating procedure for vinyl acetate unloading requires the operator to remain at the unloading facility throughout the unloading process, so a 15-minute response time was factored into the calculations. The vinyl acetate is spilled onto concrete and following the spill, 3,500 pounds of vinyl acetate would evaporate. The cloud formed by the evaporating vinyl acetate would impact a neighboring industrial facility but it would not impact any residential population. The alternative scenario for ethylene involves a technical evaluation of an accidental release which could cause off-plant impact. In this scenario, safety control systems are allowed to operate as designed. In this alternative scenario three reactors fail venting 7,500 pounds of ethylene in the form of a vapor cloud which finds an ignition source. Using the EPA selected endpoint , a 1 psi overpressure, for such a release, this release would impact a neighboring industrial site but it would not impact any residential population. 4. The plant's general accidental release prevention program and chemical specific prevention steps: The general accidental release prevention program at the AlliedSignal Orange 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 the manufacturing process including vinyl acetate and ethylene. This enables the employees involved in operating these processes to identify and understand the potential hazards associated 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 manufacturing process 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 plant for the life of the process. In general, one or more of the following methodologies are used to complete each process hazard analys is: (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. A team of employees having experience and knowledge of the process design and operation, and knowledge of how to complete a process hazard analysis performs each 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. Operating Procedures Written operating procedures are prepared for the manufacturing process including vinyl acetate and ethylene. The program in place meets the requirements of ISO 9000 certification for the p lant. The operating procedures provide clear instructions for safely conducting activities in 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 include 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 operations such as lockout/tagout, confined space entry and line breaking. 4d. Training Employees currently engaged in operating the manufacturing process, including vinyl acetate and ethylene, 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 m inimum, 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 Orange Plant maintains the mechanical integrity of equipment used to process and handle vinyl acetate and ethylene. 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 process 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. In some cases, equipment inspections are driven by permit requirements as well as the mechanical integrity program. For example, process pumps 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 plant's Process Safety Management (PSM) program is a written procedure for the Management of Change. Except for "replaceme nts in kind", any change to the PSM-covered process 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 changes, 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 pro duct 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 vinyl acetate and ethylene, 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. 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. A team of employees having knowledge of the process, equipment, procedures and safety requirements operating conditions conducts the pre-startup safety review, procedures and safety requirements. All items on t he pre-startup review checklist must be satisfied prior to commencing startup. 4h. Compliance Audits Self-assessed compliance audits for the process are conducted annually to ensure that the elements of the general accidental release prevention program are up to date and are being implemented. Personnel having experience and knowledge of the covered processes, and knowledge of the program requirements conduct the compliance audits. 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 vinyl acetate or ethylene 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 h aving 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 incident, 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 Orange plant have opportunities to access and participate in the sha ring of information related to process safety for the processes involving vinyl acetate and ethylene. 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 Orange Plant "A" 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 Work Permits The AlliedSignal Orange plant has established a hot work permit system. The hot work permit system applies to the process. Under the system, a hot work permit must be issued prior to commencing hot work operations. Hot work operations may include burning, welding, torch cutting, or any spark-emitting equipment/activity. 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 after the completion of the hot work. 4l. Contractors Prior to retaining contractor services for work in the process area, the contractor's safety performance and program is evaluated. This includes a 3 year review of the contra ctor'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 plant-specific health and safety plan prepared by the contractor. The information supplied by the contractor is retained on plant while the contractor is engaged in work activities. Prior to commencing work on plant, 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 plant emergency response program including specific procedures to be followed in case of emergency, and a review of plant safety rules and applicable operating procedures. A record of each contractor emp loyee's sign-off on the safety orientation is maintained on file at the plant, including the date the training was completed. Once the safety orientation is complete, the contractor is responsible for ensuring 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 at the site. Failure of the contractor or any contractor employee to abide by these requirements is grounds for immediate dismissal from the plant. 5. The plant's five year accident history: In the past five years, there have been no deaths, injuries, or significant property damage onsite, or known offsite deaths, injuries, sheltering in place, property damage, or environmental damage resulting from any releases of vinyl acetate or ethylene from the Ora nge plant. 6. The Orange plant's emergency response program: The AlliedSignal Orange plant has an emergency preparedness planning and response program designed to deal with accidental releases and other unplanned events associated with the facility. The plant has a written Emergency Response Plan that addresses various types of contingencies including specific actions for responding to an accidental chemical release. The Plan provides for both internal plant and external community emergency alerting. 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 plant's response activities. The Plan has been coordinated with the LEPC and with the local Fire Department which would direct all offsite community response activities. The AlliedSignal Orange plant relies upon the local F ire Department and Mutual Aid (an association that makes available emergency response equipment and expert assistance in extreme emergencies) which is knowledgeable and prepared to respond to incidents involving accidental chemical releases. Annual in-house drills of the plant's emergency response system are performed. 7. Planned changes to improve safety: The Orange plant completed a process hazard analyis for vinyl acetate in May, 1997 and for ethylene in August, 1994. As a result of these systematic safety reviews, several action items were identified and implemented to improve upon the existing safeguards and to further reduce the potential for accidental release. The process hazard analysis for the vinyl acetate and ethylene will be reviewed and revalidated every five years. Currently, a new tank, U-33, is being installed to replace the existing vinyl acetate storage tank, RC-835. The new tank will sit on a solid concrete base within a concrete walled dike designed to conta in the full contents of the vessel should a release occur. Completion of this project in 1999 will significantly decrease the offsite impact of a spill of vinyl acetate. |