Pioneer Chlor Alkali Company, Inc. - Executive Summary |
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Pioneer Chlor Alkali Company TACOMA PLANT Risk Management Plan Executive Summary Introduction The Tacoma Plant of Pioneer Chlor Alkali Company is located in the Tideflats industrial area near the Port of Tacoma on the Hylebos Waterway. The facility has been engaged in chemical manufacturing at this site since 1929. Our products include chlorine, sodium hydroxide, muriatic acid and calcium chloride. These chemicals provide important benefits in critical applications such as water purification, household disinfectants, synthetic fibers, plastics manufacturing, cosmetics and pharmaceutical products. The facility's chlorine manufacturing operation is covered by both EPA's Accidental Release Prevention Program, and the Process Safety Management Program under WISHA. (Washington State agency responsible for OSHA regulations) It is our policy to follow responsible safety, environmental, and quality practices to ensure continuous improvements in protecting our employees, the public, and the environment. Additionally, our training programs ensure employees are aware of their responsibilities and understand the necessity of operating all processes in continuous compliance with all applicable safety and environmental regulations as well as stringent company standards. As a demonstration of our commitment to safe operations, the Tacoma Plant became the first designated Star Plant in the WISHA Voluntary Protection Program in 1997. The selection process involved a weeklong on-site audit of all safety and health program components by a team of WISHA personnel. The purpose of this voluntary review is to verify that all safety and health requirements are met or exceeded with complete employee involvement and documentation to support compliance. Since our initial VPP certification, we have continued and expanded this unique and mutually beneficial partnership with WISHA. We are not only making continuous improvements on our safety performance at the plant, we are also pro viding leadership, guidance, and encouragement to other industrial facilities throughout the state. As we look forward to our first 3 year re-certification, we expect to be held to even higher standards than before. Prevention Program The facility has developed a comprehensive accidental release prevention program based on the elements of WISHA's Process Safety Management Program. Each of the 12 elements is fully implemented and integrated into the standard operating practices of the plant. Summarized below are brief descriptions of each of the elements: Process Safety Information Critical information on chlorine properties, chlorine production techniques, and chlorine handling is made readily available to facility personnel through Material Safety Data Sheets, current drawings, and comprehensive operations manuals. Additionally, the Chlorine Institute provides information and guidelines in the form of regularly updated technical pamphlets. This information is used as the basis for our operating procedures and chemical process systems. Process Hazard Analysis The facility performs extensive Hazard and Operability Studies on an established schedule. A trained team rigorously scrutinizes the operating processes and makes recommendations for safety enhancements. The recommendations are then prioritized and implemented accordingly. Operating Procedures Clear and concise instructions have been developed by teams of experienced personnel for all facility operations. The procedures are included in our Standard Operating Procedures manuals. The manuals are kept current by frequent, regularly scheduled review, and by integrating the Management of Change procedures. Training We have a thorough training program in place that is designed to train operations personnel on the technical aspects of the processes as well as leading them step by step through the Standard Operating Procedures. The program also provides ongoing training and refresher courses to continual ly enhance the capabilities of all plant employees. All training is documented to ensure completion. Mechanical Integrity The Mechanical Integrity program in place at the plant is specifically designed to keep our equipment in viable condition. Trained maintenance technicians ensure that all pipes, tanks, valves, and other equipment involved in chlorine service are maintained and rigorously inspected on an established schedule. Recommendations from equipment inspections are then prioritized and implemented accordingly. Management of Change Written procedures are in place to ensure that all process changes at the plant undergo several levels of review at the planning stage. No changes are made without review by a team that includes operations and maintenance personnel. Once a process change has been made, systems are in place to make sure that communication of the change will be made to any who may be affected. Pre Start Up Reviews Before being placed into service, any new or m odified system is thoroughly reviewed by a team composed of a cross section of plant employees. This review is designed to ensure appropriate design, adequate safety systems, and sufficient training. All recommendations from the review are then completed before start up. Compliance Audits As a Star Plant in the WISHA Voluntary Protection Program, we are subjected to a meticulous audit on a three year cycle by a highly trained team from the agency. Recommendations from the audits are promptly converted into action plans. Incident Investigation Significant environmental, safety, or health incidents at the facility are fully investigated by appropriate teams to determine root cause and to put in place action plans designed to prevent recurrence. The findings are documented and communicated to facility personnel. Employee Participation Employee participation is the cornerstone of the Voluntary Protection Program. Plant operators, maintenance technicians, and engineers, as well as s upervisors and managers participate fully in Hazard and Operability Studies and incident investigations. All findings and recommendations are made available. A broad range of facility personnel also make up the various safety committees and participate in a wide range of safety related activities. Hot Work The facility's Hot Work procedure requires that detailed permitting activities take place before, during, and after any job that has the potential to provide a source of ignition. Contractor Safety The contractor safety program in place at the plant places stringent qualification requirements on contracting firms. To become qualified to work at the facility, contractors must provide proof of training that matches our tough requirements. Additional facility specific training, including training on our emergency response plan is then required before any contract work can take place. Contractor safety performance and compliance with facility safety requirement are monitored close ly during all contract projects. Emergency Response Program The Tacoma Pioneer facility has in place a comprehensive written Emergency Response Plan. The plan includes 24 hour/day, 365 day/year response capabilities. The plant responders are trained and qualified on the proper response techniques and are equipped with the necessary equipment to perform critical response procedures. As part of the ongoing training program for responders, we routinely perform readiness drills. The drills include both table-top planning sessions as well as full field responses to simulated incidents in the plant. Additionally, we periodically conduct joint drills in conjunction with the Tacoma Fire Department to evaluate our coordinated response techniques. The plant is equipped with a facility wide alarm system that can be triggered by any employee from any of seven locations at the site. As soon as the alarm system is triggered, response teams, including those assigned the task of making criti cal notifications, assemble immediately. Current emergency phone numbers are always available in the facility's Emergency Operations Center so that timely notifications can be made. Another key safety feature in use at the plant is the facility wide perimeter monitoring system that can detect chlorine at very low concentrations. Operations personnel monitor the real time readings from the chlorine sensors and will respond immediately to any detection. Additionally, the facility utilizes a computer modeling system that can help to plan potential scenarios and develop appropriate responses. Hypothetical Models The Environmental Protection Agency has defined the Worst Case Scenario as the hypothetical rupture and full release of all contents of the facility's largest storage tank, assuming all safeguards have failed, during extremely stable weather conditions. While the probability of this scenario coming to pass at any facility is extremely low, it does provide a template for eme rgency response planning. The computer generated model for our largest chlorine tank results in a planning zone of up to 25 miles. The EPA has specified in the RMP rule that each facility must define a specific Alternate Scenario that could have an off site impact, based on plant operations. This scenario is to be modeled using the actual safeguards that are in place, during typical weather conditions. After a thorough review of our facility, we have selected the hypothetical rupture of a loading line while actively loading a chlorine rail car. It should be noted at this point that this facility has never experienced a chlorine loading hose rupture. Our loading system includes two sets of automatic valves that are specifically designed for this application which would close immediately if a loading hose were to rupture. The computer generated model for this hypothetical scenario results in a possible impact of up to 0.8 mile from the loading station. Five Year Release History There are three incidents in the facility's five year accidental release history. In each case, the response action taken by nearby industrial neighbors, evacuation or sheltering in place, determined that the incidents be listed on our five year history. As per our procedure, thorough investigations were performed to determine root causes of each of the incidents. The investigations were followed by responsible implementation of corrective action plans to ensure that there would be no recurrences. The facility has experienced no chlorine releases in the past five years that have exceeded the 10 pound Reportable Quantity threshold. Safety Improvements We believe that continuous improvement is the key to success in the future. This is especially true in the safety, health and environmental areas. Our philosophy is to continuously look for opportunities to improve our abilities in protecting our people and our community. The facility has also performed a comprehensive evaluation of all equipment and software systems with regard to potential Y2K issues to ensure safe and reliable operations as we approach the next century. Action plans have been enacted which will result in complete Y2K compatibility well in advance of the new year. A few recent examples of our ongoing safety improvement efforts include the following: * Equipment Vibration Monitoring Program * Perimeter Monitor System Expansion * Chlorine Loading Station Enhancements * Enhanced Incident Investigation Techniques We aim to further enhance our partnerships with regulatory agencies and local responders, as well as with other industrial facilities in the common goal of protecting our employees, our communities, and our futures. Furthermore, we will be looking increasingly to our Community Advisory Panel and other groups in the area to establish an open, ongoing dialog regarding community concerns and expectations. Summary We at Pioneer Chlor Alkali are committed to the principles of the Chemi cal Manufacturers Association's Responsible Care program that directs member companies to continuously enhance safety performance. We would also encourage members of the community to contact us with questions, concerns, or to arrange a plant tour. Please feel free to call us at (253) 383-2661, or visit our web site at www.piona.com. |