Daikin America, Inc. - Executive Summary |
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Executive Summary A. Description of Stationary Source and Regulated Substances Handled Daikin America, Inc. (Daikin) is a fluorocarbon manufacturing facility located in Decatur, Alabama. As a result of the manufacturing process, the following regulated chemicals are present at the facility in quantities that exceed the threshold quantities specified by EPA regulations: chloroform, hydrogen fluoride (HF), ethylene, and tetrafluoroethylene (TFE). The facility has one covered process that requires the facility meet Program 3 requirements of the EPA Risk Management Program (RMP) regulation. Daikin has a joint venture with 3M, called MDA Manufacturing, Inc. (MDA). Daikin operates the MDA manufacturing process and oversees safety, environmental and maintenance for MDA. In an emergency involving either Daikin or MDA, Daikin personnel will be directly involved. According to Chapter 1 of the EPA General Guidance for Risk Management Programs (July 1998), for joint ventures, " the legal entity you have established to operate these processes should file the RMP. If you consider the entity a subsidiary, you should be listed as the parent company in the RMP". Therefore, Daikin is submitting the RMP for the covered process, which includes the MDA operations. HF and chloroform are delivered to the facility via railcars and are offloaded to storage tanks. In the process, HF and chloroform are used as raw materials in the production of chlorodifluoromethane (R-22) at MDA. TFE is produced from R-22 at Daikin. TFE is stored in storage tanks and is used as a raw material for other Daikin products. It is transported via pipeline to MDA to manufacture hexafluoropropylene (HFP) and is also transported via pipeline to a nearby 3M facility. Ethylene is delivered and stored on site in tube trailers. Ethylene is a raw material used in the production of ethylene tetrafluoroethylene at Daikin. B. Accidental Release Prevention & Emergency Response Policies of Daikin Daik in is committed to protecting facility personnel, the public and the environment from any workplace and accidental release hazards. Appropriate responses to releases of regulated chemicals are documented in the Plant Safety Manual. Safety, environmental protection and risk management programs are fully implemented and coordinated with community emergency responders for emergency planning and response efforts. C. Release Scenario Discussion In accordance with the requirements of the EPA RMP regulations each owner or operator of a stationary source is required to perform the following offsite consequence analyses. 7 One worst-case release scenario to represent all regulated toxic substances held in excess of the threshold quantity. A worst-case release scenario analysis was conducted for HF. 7 One worst-case release scenario to represent all regulated flammable substances held in excess of the threshold quantity. A worst-case release scenario analysis was conducted for TFE. 7 One alternative release scenario for each regulated toxic substance held in excess of the threshold quantity. An alternative release scenario analysis was calculated for both HF and chloroform. 7 One alternative release scenario to represent all regulated flammable substance held in excess of the threshold quantity. An alternative release scenario analysis was evaluated for TFE. The following are brief descriptions of the release scenarios that are being submitted by Daikin in the Risk Management Plan (RMPlan). Daikin elected to use the EPA Offsite Consequence Analysis Guidance document and the "look-up" tables contained in this document to calculate estimated release rates and to determine the distances to the appropriate toxic and flammable endpoints. Daikin evaluated numerous scenarios for each regulated chemical in order to select the most appropriate worst-case and flammable scenarios for inclusion in the RMPlan. More detailed information is provided in Sections 2, 3, 4 and 5 . Toxic Chemicals Worst-Case Release Scenario The worst-case toxic release scenario for Daikin was determined to be an instantaneous liquid spill and vaporization of the entire contents of a HF railcar. A major release of this magnitude is extremely unlikely due to the advances that have taken place in railcar design as well as the rigorous maintenance and prevention programs present at both the Daikin facility and that of our suppliers. Daikin used the EPA "look-up" tables to determine the distance to the toxic endpoint from the release location. Sections 2.12, 2.13 and 2.14 of the RMPlan provide information regarding the residential population, public and environmental receptors located within the distance to the endpoint for this scenario. Alternative Release Scenarios The alternative release scenario for HF was determined to be a pressure gauge failure on the discharge of the HF pumps. Vapor sensors in the area will provide indication to the control room that a HF leak has occurred. Upon verification of the leak the control room operator will stop the HF pump, close the HF receiver outlet valve and isolate the piping and pump from the reactor and receiver. The failure could result in a release of liquid HF. Daikin used the EPA "look-up" tables, to determine the distance to the toxic endpoint for HF from the release location. Sections 3.12, 3.13 and 3.14 of the RMPlan provide information regarding the residential population, public and environmental receptors located within the distance to the endpoint for this scenario. The alternative release scenario for chloroform was determined to be a release from a piping failure. Daikin used the EPA "look-up" tables, to calculate distance to the toxic endpoint for chloroform from the release location. The distance off-site for this release scenario is very short, resulting in no impacts to residential areas or environmental receptors. Flammable Chemicals Worst-Case Release Scenario The worst-case flamma ble release scenario for the facility was determined to be a vapor cloud explosion of a TFE storage tank. Daikin used the EPA "look-up" tables, to determine the distance to a 1 psia overpressure from the release location. The distance off-site for this release scenario is very short, resulting in no impacts to residential areas or environmental receptors. Alternative Release Scenario The alternative flammable release scenario for the facility was determined to be a gasket failure on the TFE storage tank. The facility is equipped with vapor sensors that provide leak indications in the control room. Operators also make regular rounds throughout the process. Daikin used the EPA "look-up" tables to determine the distance to the lower flammable limit for TFE from the release location. The distance off-site for this release scenario is very short, resulting in no impacts to residential areas or environmental receptors. D. Five-year Accident History Under the EPA RMP regulations, an a ccidental release is defined as a release of a regulated substance that "resulted in deaths, injuries or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage." On 11 May 1999 an explosion and fire occurred at the Daikin facility involving TFE, killing three (3) Daikin employees and injuring one (1) Daikin employee. No offsite impacts occurred as a result of this accident. This accident has been reported under Section 6 of the Accident History portion of the RMP Plan. However, at the time of the submission the accident is under investigation by Daikin and many of the details of the accident are not known. Daikin has not had any other accidents within the past five years that resulted in deaths, injuries or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. E. Management Program Daikin ha s a management program in place that assigns overall responsibility for the development and implementation of the Risk Management Program (RMProgram) to a qualified individual or position of responsibility. It clearly delineates accountability and responsibilities for any elements where responsibilities are delegated. F. Prevention Program Elements Process Safety Information - Up-to-date process safety information is maintained for use by employees operating the covered process in accordance with 40 CFR Part 68.65, including the following: 7 MSDSs for chloroform, HF, ethylene, and TFE that contain toxicity information, permissible exposure limits, physical data, reactivity data, thermal and chemical stability data and synergistic effects from mixing process flows. 7 Block flow diagrams for the covered process. 7 Process chemistry and maximum intended inventory data for the covered process. 7 Safe operating limits and evaluation of consequences of deviations from these limits f or the covered process. 7 Covered process equipment information consisting of materials of construction; piping and instrumentation diagrams (P&IDs); electrical classification; relief system design and design basis; ventilation system design; design codes and standards employed; and safety systems (interlocks, detection or suppression systems). The date reported in the RMP Plan in data element 7.3 is the date of the review for TFE. Other chemicals have been reviewed on previous dates. Process Hazard Analysis (PHA) - A PHA has been performed for the Program 3 covered process at Daikin in accordance with 40 CFR Part 68.67. The PHA was performed using What-If/ Checklist and Hazard and Operability Study (HAZOP) methods. The PHA identified the potential hazards associated with the regulated substances in the covered process; causes of potential accidental release scenarios; safeguards used to prevent accidental releases; and methods used to detect, monitor or control accidental relea ses. Any issues identified during the PHA were documented and resolved in a timely manner. The PHA will be revalidated and updated once every five years following completion of the initial PHA. Operating Procedures - Detailed and up-to-date process operating procedures have been developed and are maintained for the covered process in accordance with 40 CFR Part 68.69. Operating procedures provide clear instructions for safely conducting activities involving a covered process in a manner consistent with process safety information and are readily accessible to employees involved in a covered process. Operating procedures are reviewed annually to ensure that they remain current and accurate. Operating procedures cover each operating phase of the covered process including initial system startup, normal operation, temporary operations, emergency shutdown and conditions when required, emergency operations, normal shutdown and startup following a turnaround or emergency shutdown. Operat ing procedures also incorporate or reference relevant process safety information including the following: 7 Process Operating Limits (including consequences of deviations and steps to correct or avoid such deviations). 7 Safety and health considerations (including properties and hazards of covered chemicals, precautions necessary to prevent exposure, control measures to be taken upon physical contact or airborne exposure, quality control for raw materials, and control of regulated substance inventories). 7 Safety systems and their functions. Training - New employees working with a covered process receive initial training in accordance with 40 Part CFR 68.71. The training includes an overview of the process and emphasizes process operating procedures, safe work practices, health and safety hazards, and emergency operations including shutdown. Those employees already involved in operating or maintaining a covered process prior to 21 June 1999 have been certified in writing as having " the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures". Refresher training is provided at a minimum of every three years to all employees involved in working with a covered process. Documentation is maintained for each employee to ensure that he or she received and understood the required training. Mechanical Integrity - A mechanical integrity program has been developed in accordance with 40 CFR Part 68.73 for covered process equipment. Employees involved in the maintenance of the covered process receive additional training, which includes an overview of the process, its hazards, and applicable procedures to ensure that the employee can perform the job in a safe manner. Written procedures have been developed to ensure that covered process equipment is properly maintained, tested, and inspected at regular, scheduled intervals and that such activities are thoroughly documented. Maintenance, inspect ion and testing procedures and frequencies are consistent with applicable manufacturer's recommendations and follow accepted engineering practices. Any equipment deficiencies identified during maintenance, inspection or testing are corrected in a safe and timely manner. The mechanical integrity program also includes a quality assurance program Management of Change (MOC) - A written MOC procedure has been implemented to manage changes in process chemicals, technology, equipment and operating procedures for the covered process in accordance with 40 CFR Part 68.75. The MOC procedure does not apply to "replacements in kind" which are defined as replacements that satisfy the original design specifications (e.g., replace a pressure reducing valve with a new identical valve supplied by the original equipment manufacturer). Prior to introducing a change, the MOC procedure is implemented to ensure the following: 7 The technical basis for the change and its impact on health and safety have been fully evaluated; 7 Affected operating procedures and applicable process safety information have been updated accordingly; and 7 The schedule for implementing the change has been developed and required authorizations have been obtained. All employees involved in operating or maintaining the modified process are informed of the change and trained accordingly prior to startup of the modified process. Pre-startup Safety Review (PSSR) - PSSRs are performed in accordance with 40 CFR Part 68.77 for new covered processes and for modified covered processes when the modification is significant enough to require a change in the process safety information. The PSSR confirms the following prior to introducing a regulated substance into a process: 7 Equipment and construction satisfy design specifications; 7 Safety, operation, maintenance, and emergency procedures have been developed and are adequate; 7 A PHA has been performed for new covered processes, and all recommendations have been res olved or implemented prior to startup; 7 The MOC procedure has been completed for the process modifications; and 7 Training of all employees involved in operating or maintaining the new or modified process has been performed. Compliance Safety Audits - RMProgram compliance is confirmed through safety audits that are performed at least once every three years in accordance with 40 CFR Part 68.79. The audits are completed by at least one person knowledgeable in the process. A report of the findings is generated following the audit, and all deficiencies and/or recommendations are promptly addressed and the resolution is documented. The two most recent safety audit reports are maintained at the facility. Incident Investigation - Specific incident investigation, reporting, and documentation procedures have been implemented and are followed in accordance with 40 CFR Part 68.81 in response to any incident involving a covered process that did or could have reasonably resulted in a catastr ophic release of a regulated substance. Under EPA RMP, a catastrophic release is defined as a major uncontrolled emission, fire, or explosion involving one or more regulated substances that presents imminent and substantial endangerment to public health and the environment. The incident investigation procedure is initiated as soon as possible and no later than 48 hours following any incident. A team is established to perform the incident investigation and always includes at least one person knowledgeable in the process, a contract employee if the incident involves work by a contractor, and other persons with appropriate qualifications to investigate an accident. Following the investigation, a written report is prepared summarizing the following information at a minimum: date of the incident; date the investigation began; description of the incident and any contributing factors; and any recommendations resulting from the investigation. When completed, all affected personnel inclu ding contract employees review the report. Incident investigation reports are maintained at the facility for a minimum of five years. Employee Participation - A written employee participation plan has been implemented that provides employees with access to PHA and all other information developed under the RMP regulation in accordance with 40 CFR Part 68.83. The employee participation plan describes employee participation in conducting PHA and in implementing all other RMP elements. Hot Work Permit - An authorization and permit program for hot-work operations has been prepared and implemented for hot-work conducted on or near a covered process in accordance with 40 CFR Part 68.85. The permit is used to document that fire prevention and protection standards in 29 CFR Part 1910.252(a) have been implemented prior to beginning the hot-work operations. Also, the permit lists the date(s) authorized for the hot-work and identifies the equipment to be worked on or near. Contractors - A c ontractor safety program in accordance with 40 CFR 6 Part 8.87 is in place for all contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. The safety performance of each contractor is evaluated prior to selection. Each contractor employee is informed of the known potential fire, explosion, or toxic release hazards related to work on a covered process as well as the relevant provisions of the emergency response program. Procedures are in place to control the entrance, presence, and exit of contract employees in covered process areas. Periodically, the performance of the contract owner or operator is evaluated while working in or adjacent to a covered process. G. Emergency Response Program Daikin has an emergency response program that includes an emergency action plan addressing all EPA RMP regulated substances present at the facility. The emergency action plan includes: 7 Procedures for informing the Deca tur/Morgan County LEPC and the community about any accidental releases; 7 Documentation of first-aid and emergency medical treatment necessary to treat accidental exposures; and 7 Procedures for emergency response after and accidental release of a regulated substance. The emergency action plan is reviewed annually to reflect changes at the facility and ensure that employees are informed of the changes. The emergency response program includes procedures for the use of on-site emergency response equipment and for its inspection, testing and maintenance. Employees are trained periodically on emergency response procedures. H. Planned Changes to Improve Safety In an effort to improve safety and to reduce the risk of accidental releases, changes to the RMProgram and the facility will be implemented as identified. These improvements may be identified either as risk reduction measures during the PHA or as a result of an improved RMProgram and the dedication to an inherently safer proces s. |