Akzo Nobel Chemicals Inc. - McCook Plant - Executive Summary |
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The Akzo Nobel McCook Plant is committed to operating in a manner that is safe for the workers, the public and the environment. As part of this commitment, Akzo Nobel has established a system to help ensure safe operation of the processes at this facility. One part of this system is a risk management program (RMP) that helps manage the risks at this site and that complies with the requirements of the EPA's regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at the Akzo Nobel McCook Plant. This document is intended to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of this facility's risk management program. 1. Accidental Release Prevention and Emergency Response Policies: Akzo Nobel is committed to the safety of their workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. It is company policy to adhere to all applicable Federal and state rules and regulations. It is necessary to observe safety precautions in handling hazardous substances to prevent unnecessary human exposure, to reduce the threat to their own personal health as well as their co-workers, and to reduce the threat to nearby members of the community. Akzo Nobel implements reasonable controls including safety devices inherent in the design of the facility combined with safe handling procedures and provides proper training to prevent foreseeable releases of hazardous substances. "NO ONE WORKS TO GET HURT" is a corporate slogan that defines the company's emphasis on safety. In the event of a significant accidental release, the emergency response system will be activated and the Plant's trained personnel will respond to control and contain such releases. Akzo Nobel evaluates each situat ion, evacuates workers as necessary, and contacts the local fire department or other outside mutual aid to control and contain the release and to prevent and/or reduce the consequences of the release. Akzo Nobel and the fire department have established a program to warn the community if an accident occurs that could threaten the community. 2. The Facility and Regulated Substances Handled: At the Akzo Nobel McCook Plant, a wide variety of industrial surfactants are produced from naturally occurring fats from the meat packing industry and from vegetable oils. These raw materials are used to produce fatty acids and amines which are then reacted with other chemicals that include Ammonia, Ethylene Oxide, Methyl Chloride and Propylene Oxide to produce over 200 products. These materials have many applications and find their way into products used daily by most people. Many of the items that you buy at the store, such as laundry detergents, fabric softeners, hair shampoos and condition ers, plastic wrap and plastic bags are made with our products. There are three production units onsite in which the Plant handles four toxic substances regulated by the RMP rule that exceed the listed threshold quantities. All of these covered processes are eligible for program level 3. Arquad Unit: Methyl Chloride - 300,000 lbs. Amide Unit: Ammonia - 120,000 lbs. Etho Unit: Ethylene Oxide - 320,000 lbs. & Propylene Oxide - 200,000 lbs. 3. Offsite Consequence Analysis: The Akzo Nobel McCook Plant performed an offsite consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. The OCA consists of evaluating both worst-case scenarios and alternative release scenarios. The McCook Plant does not expect a worst-case release scenario to ever occur. An alternative release scenario represents a more likely release that might occur during the Plant's lifetime. These accident scenarios do not re present any new risks. Instead, they are intended to be used by emergency responders to plan appropriate responses to possible chemical accidents to minimize their impact. Likewise, development of these scenarios provides the opportunity for this facility to verify that they have the necessary procedures and protective measures in place to minimize the occurrence of such accidents. The Worst-Case Release Scenario (WCS) The chemical chosen for the WCS to represent all of the RMP regulated toxics is Ethylene Oxide. The WCS for the McCook site would be the failure of one full rail car containing 170,000 pounds of Ethylene Oxide. The entire contents of the rail car would be released over a 10-minute period forming a vapor cloud, assuming worst-case (stable) weather conditions. According to the lookup tables presented in EPA's RMP OCA Guidance document, the maximum distance to the toxic endpoint concentration is 10 miles. The WCS is highly unlikely to occur because of mechanisms and systems that are in place to prevent such a catastrophic episode. Detectors are dedicated to immediately sense a leak of Ethylene Oxide and set off an alarm. And, the rail car is equipped with a deluge system that can be manually tripped to knock down the vapors, which would then get carried to a collection sump, therefore greatly reducing the threat of such a release. There is a vast range of public receptors and one National Historic Site located within this 10 mile distance of the Ethylene Oxide rail car, with a total population of 2,000,000 people (based on census data provided by the U.S. Bureau of the Census on their Landview III CD ROM). Alternative Release Scenarios (ARS) For each of the four RMP regulated chemicals, the McCook Plant has defined one ARS. All four scenarios include the potential occurrence of unloading transfer hose releases due to splits or sudden hose uncoupling. In each case, the line empties between either two excess flow valves or an excess flow val ve at the rail car and a check valve at the storage tank which would limit the releases to under five minutes. An EPA-accepted, industry-recognized computer-modeling program called TRACE and typical weather conditions for the area were used to conduct the OCA. For the Ammonia ARS: 2,554 lbs. would be released and the distance to its toxic endpoint is 0.21 miles. There are some residences, schools and recreational areas located within this distance with a population of 36 people. For the Ethylene Oxide ARS: 7,093 lbs. would be released and the distance to its toxic endpoint is 0.53 miles. There are some residences, schools, and recreational and major commercial/industrial areas located within this distance with a population of 1100 people. For the Methyl Chloride ARS: 2,761 lbs. would be released and the distance to its toxic endpoint is 0.06 miles. There is one residence located within this distance with a population of 3 people. For the Propylene Oxide ARS: 250 lbs. would be r eleased and the distance to its toxic endpoint is 0.04 miles. There is no residential population located within this distance. 4. General Accidental Release Prevention Program and Chemical-specific Prevention steps: The following is a summary of the general accident prevention program in place at the Akzo Nobel McCook Plant. Because processes at this Plant that are regulated by the EPA RMP regulation are also subject to the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation The McCook Plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) te am. Employees have access to all information created as part of the Plant's accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the Plant and addresses individual accident prevention program elements. In addition, the Plant has a number of ongoing initiatives that address process safety and employee safety issues. These initiatives include sending all employees to a Managing Total Safety course and forming teams to promote both process and personal safety. The teams typically have members from various areas of the Plant, including operations, maintenance, engineering, and Plant management. Process Safety Information The McCook Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemi cal inventories, and equipment design basis/configuration information. Specific departments within the Plant are assigned responsibility for maintaining up-to-date process safety information. A list of the various reference documents and their locations, which includes the company Intranet, are outlined in the written process safety information plan to help employees locate necessary process safety information. Chemical-specific information, including exposure hazards and emergency response treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the Plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) within each unit's operating procedures. The Plant ensures that the process is maintained within these limits by using process controls a nd monitoring instruments, highly trained personnel, and protective instrument systems. The Plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, piping material specifications, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) The McCook Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Plant primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are individually assigned to the appropriate personnel/departments and then implemented in a timely manner based on a relative risk ranking assigned by the PHA team. They ensure that potential accident scenarios assigned the highest risk receive immediate attention. All action plans generated by the PHA recommendations are tracked until they are complete. The final resolution of each recommendation is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviat e significantly from the original design safety features, the Plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The results, findings and final resolution from these updates are documented and retained. Operating Procedures The McCook Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, (6) initial startup of a new process, and (7) startup following a turnaround or emergency shutdown. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. In addition, the procedures include operating limits, their consequences of deviation and steps to correct them. Safety and health considerations and safet y systems are also described. Procedures are periodically reviewed and annually certified as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made through the management of change process. Procedures are readily available to operators and other personnel in the process unit and posted on the Intranet to use as necessary to safely perform their job tasks. Training To compliment the written procedures for process operations, the McCook Plant has implemented a training program for all employees involved in operating a process. Training may be in the form of lectures, video tapes, audio tapes, or interactive computer sessions. Lesson plans and Operator Qualification Lists are uniquely tailored to each training session. On the job training is also utilized. This involves the employee observing a procedure during which time each step of the procedure is explained. The employee is then given hands on experience followed by rein forcement of the written procedure if available. The time needed to train each individual is determined by the trainer based of the trainee's previous work experience, education and demonstration of proficiency in material being taught. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they become qualified to work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every three years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Other sources of ongoing training for operators include the lessons learned from unusual incident reports and/or accident investigations. Contractors The McCook Plant uses contr actors to supplement its work force during periods of increased maintenance or construction activities and special projects. Because some contractors work on or near process equipment, the Plant has a Contractor Orientation Program and written procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with a Plant operations overview, information about safety and health hazards, emergency response plan requirements, and safe work practices prior to their beginning work. In addition, the Plant evaluates contractor safety programs and performance during the selection of a contractor. The Plant personnel periodically monitor contr actor performance onsite to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) The McCook Plant conducts a PSSR for all new process units that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides an additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The McCook Plant has well-established practices and procedures to maintain pressure vessels, piping s ystems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include conducting training, developing written procedures, and applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on an overview of the process, safety and health hazards, applicable maintenance procedures, emergency response plans, and applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Based on applicable standards and prior experience, inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits. If a deficiency is identified, employees will corr ect the deficiency before placing the equipment back into service if possible, or they will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The McCook Plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include control of the entry/presence/exit of support personnel, a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, a procedure for safe removal of hazardous materials before process piping or equipment is opened, a permit and procedure to control spark-producing activities (i.e., hot work), and a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures and others, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The McCook Plant has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology including process operating conditions, procedures, and other facility changes be properly reviewed and authorized through a Process Change Authorization before being implemented. Changes are reviewed to ensure that adequate controls are in place to mange any new hazards and verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In ad dition, operating and maintenance personnel are provided with any necessary training on the change. Incident Investigation The McCook Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent recurrence, and assigns responsibilities for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees including contractors who could be affected by the findings. Incident Investigation reports are retained fo r at least five years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, the McCook Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted by the corporate safety, health and environment (SH&E) department at least every three years. The audit team develops findings that are forwarded to Plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. In addition, Plant employees conduct internal audits on individual PSM elements more frequently. Chemical-specific Prevention Steps The processes at the McCook Plant have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all EPA RMP and OSHA PSM covered processes at the Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. In addition to the accident prevention program activities, the Plant has safety features on many units to help contain/control a release, quickly detect a release, and reduce the consequences of a release. For the RMP covered processes, the following types of safety features are used: Arquad Unit: vents, relief valves, check valves, manual/automatic shutoffs, interlocks, process alarms and procedures, backup pump, grounding equipment, excess flow device, purge system, sprinkler system, dikes, deluge system, water curtain, video monitors, trained emergency response personnel and personal protective equipment. Amide Unit: vents, relief valves, check valves, scrubbers, manual/automatic shutoff s, interlocks, process alarms and procedures, grounding equipment, excess flow device, purge system, sprinkler system, deluge system, water curtain, trained emergency response personnel and personal protective equipment. Etho Unit: vents, relief valves, check valves, scrubbers, manual/automatic shutoffs, interlocks, process alarms and procedures, keyed bypass, emergency air supply, backup pump, grounding equipment, rupture disks, excess flow device, purge system, sprinkler system, dikes, blast walls, deluge system, water curtain, neutralization, process area detectors, perimeter monitors, trained emergency response personnel and personal protective equipment. 5. Five-Year Accident History: No releases involving Ammonia, Ethylene Oxide, Methyl Chloride or Propylene Oxide have occurred at the McCook site in the last five years that would have resulted in deaths, recordable injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site. 6. The Emergency Response Program: The McCook Plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including functions of the Incident Command System and Plant Hazmat Team, proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel, notification of local emergency response agencies and the public if a release occurs, and postincident cleanup and decontamination requirements. In addition, the Plant has procedures that address maintenance, inspection, and testing of emergency response equipment. Employees receive training in these procedures as necessary to perform t heir specific emergency response duties. The emergency response program is updated when necessary and reviewed annually by the Plant's emergency response committee. The Plant has recently acquired a weather station and a dispersion modeling system, known as SAFER Real-Time, that together are used to predict the immediate downwind impact of a hazardous release. The Plant has provided the local fire department with their own copy of the SAFER dispersion modeling software. The fire department is also equipped with a Plant radio and has been given the Plant's emergency response plan as well. Additionally, the Plant periodically conducts emergency response drills, including annual drills coordinated with the local fire department. 7. Planned Changes to Improve Safety: The McCook Plant constantly strives to improve the safety of the processes through periodic safety reviews, the incident investigation program, and a reward program soliciting safety suggestions from the workers. The Plant resolves all findings from PHAs, some of which result in modifications to the process. In our efforts to continually improve our performance in the safety and environmental arenas, the Plant will implement changes and enhancements during 1999 to meet the stringent environmental standards established under the International Standards Organization (ISO) 14001. In order to fulfill Responsible Care obligations, the Plant is progressively extending the process safety code of management to all areas of the Plant. In an effort to simplify and integrate various emergency response procedures, the Plant will compose one contingency plan to suit every type of incident including hazardous waste releases to meet Resource Conservation and Recovery Act (RCRA) requirements. Currently, the Plant is undergoing some major renovations, collectively known as McCook 2000, that will incorporate a state-of-the-art computerized control system, new facilities and modernization of blending, loading a nd unloading operations. These enhancements will be built and operated in accordance with the highest standards for safety and environmental responsibility, thus improving overall Plant and process safety. Ultimately, as the Plant continues on this path towards procuring the highest quality in its safety programs, eligibility for the highest honor for safety in the workplace, OSHA's VPP Star status, will be attainable. The Akzo Nobel McCook Plant is confident that through its strong commitment to making continual improvements in risk management and process safety inherent in their accident prevention and emergency response programs, they can avoid the impeding threats posed by hazardous materials and protect the employees, the community and the environment from such harms. |