Flexsys America L.P. - Executive Summary |
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The Flexsys America L.P. (FLEXSYS) Monongahela, Pennsylvania facility, is located in a rural area outside of the town of Monongahela. Chemical production has occurred at the site since 1916, originally operating as the Stauffer Chemical Company. FLEXSYS is the world's leading producer of chemicals for the rubber processing and related industries. FLEXSYS products go into the production of rubber tires and other rubber articles. In June 1998, FLEXSYS was one of only six companies to receive the 1998 Presidential Green Chemistry Challenge Award. The award, which honors organizations that successfully research, develop and implement outstanding green chemical technologies, was presented at the National Academy of Sciences in Washington DC. Our workforce is comprised of production, maintenance, engineering, technical, clerical, and management personnel. The average level of chemical plant experience for our employees exceeds 15 years. We are proud of our facility and the stability of our workforce. The Federal Accidental Release Prevention Requirements under the Clean Air Act Section 112(r), codified in 40 CFR Part 68, were written to help prevent the accidental release of extremely hazardous substances and to minimize the consequences of any such release. All facilities with threshold quantities (TQs) of the listed regulated acutely toxic and flammable substances are subject to these provisions. The listed substances include 77 toxic chemicals with TQs ranging from 500 lbs. to 20,000 lbs., while the 63 flammable substances all have a TQ of 10,000 lbs. FLEXSYS has one chemical, carbon disulfide (CS2), that meets the toxic chemicals TQs, and thus, this substance must be included in a Risk Management Program for its use within a process. CS2 is a yellowish liquid with an unpleasant odor. In nature, very small amounts are found in gases from volcanic eruptions and in marshy areas. CS2 has been an important industrial chemical since the 1800s because of its many useful properties, including its ability to solubilize fats, rubbers, phosphorus, sulfur, and other elements. CS2 has been highly suitable for other industrial applications including the vulcanization and manufacture of rubber and rubber accessories; the production of resins, plywood adhesives, and flotation agents; petroleum-well cleaning; brightening of precious metals in electroplating; rust removal from metals; and removal and recovery of metals and other elements from wastewater and other media. In agriculture, CS2 was formerly widely used as a fumigant to control insects in stored grain. The major Clean Air Act Section 112(r) ("112(r)") requirements with which FLEXSYS must comply for use of CS2 include: - Management System development and documentation, - Hazard Assessment for each affected process, - Prevention Program completion, - Emergency Response Program coordination, and - Risk Management Plan submittal. In addition, FLEXSYS recognizes its responsibili ty under Section 112(r)(1) (the "general duty clause") to handle all Extremely Hazardous Substances safely and to identify hazards that may result from accidental releases. Furthermore, FLEXSYS works to prevent accidental releases and to minimize the consequences if a release occurs. Additional chemicals on site, not meeting their TQ or not identified in the 112(r) list rule, include hydrogen sulfide and small quantities of chemicals used in laboratory analysis. These "general duty" chemicals are managed using the sound risk-management principals applied to our chemical fully covered by 112(r). FLEXSYS follows a prevention program including the use of process safety information, operating procedures, employee training, mechanical integrity, management of change, pre-startup review, incident investigation, compliance audits, "hot work" by permit only, and evaluation of contractors. This Executive Summary to the FLEXSYS Risk Management Plan (RMP) provides an overview of how we are e ffectively meeting our responsibilities to the community through compliance with 112(r) requirements. MANAGEMENT SYSTEM FLEXSYS has established a management system to oversee the implementation of its Risk Management Program responsibilities. The management system is designed to help ensure that each element of our program is fully and effectively completed. A qualified engineer has been assigned overall responsibility for the development, implementation, and integration of the program elements. Responsibility for implementing individual requirements of FLEXSYS' program have been delegated to competent individuals. An organization chart has been prepared to identify the responsible personnel and lines of authority for implementing the program. Record-keeping responsibilities are also included in the management system. FLEXSYS fully supports the ideals and efforts of its Risk Management Program management system. HAZARD ASSESSME NT The Hazard Assessment portion of the 112(r) rule requires facility owners or operators to prepare "worst-case" and "alternative" release scenarios as appropriate to the operations. From the release scenarios, facilities are then to determine offsite impacts using specified "Offsite Consequence Analysis" parameters for worst-case releases and more realistic parameters for alternative releases. As defined by the U.S. Environmental Protection Agency (EPA): - The worst-case release involves the release of the largest quantity of a listed toxic substance that is estimated to generate the greatest distance in any direction to a toxic endpoint defined in the 112(r) regulation. The probability that a worst-case release might occur or the possible causes of such a release are not considered. - The alternative scenario involves an accidental release that is "more likely to occur" than the worst- case re lease scenario. Scenarios to consider include transfer hose splits or uncoupling, process piping failures, process vessel or pump cracks and failures, vessel overfilling and spill or overpressurization and venting through relief valves or rupture disks, and shipping container mishandling and breakage or puncturing leading to a spill. FLEXSYS prepared worst-case release scenario analyses and alternative release scenario analyses for CS2, based on requirements given in the 112(r) rule. Worst-Case Release Scenario: 7 A rupture of a single 50 ton railcar and subsequent unmitigated release of its CS2 contents. Note, the railcar is off-loaded only once a year. In addition, work is underway to mitigate a potential spill at the railcar off-loading area. Alternative Release Scenario: 7 CS2 is discharged from a 3" process pipe due to a gasket rupture, but the amount released is limited by operator action. The Offsite Consequence Analysis of the chemical release was analyzed using appropriate air dispersion analysis and modeling techniques. Air dispersion modeling is the use of a computer to simulate the spread of air pollutants. Dispersion modeling can be used to determine the movement and concentration of toxic gases emitted from an accidental release. In both the worst-case and alternative Offsite Consequence Analysis modeling cases, "worst-case" weather conditions were used to simulate poor dispersion of the chemical, even though the 112(r) rule allows the use of more favorable dispersion conditions, such as increased wind speeds and a greater dilution factor, for the Alternative Release Scenario analysis. The topography surrounding the FLEXSYS operations will frequently contribute to poor dispersion conditions, especially at night and through early morning. Therefore, use of "worst-case" meteorology is prudent. To determine the Offsite Consequence Analysis of worst-case and alternative releases of CS2, FLEXSYS used the most-recent version of several air dispersion models and modeling techniques, as follows: RMP*Comp is based on the U.S. EPA's RMP Offsite Consequence Analysis Guidance (May 1996). This guidance document provides rough estimates of offsite impacts from evaporating pools of chemicals and vapor clouds. ALOHA (Areal Locations of Hazardous Atmospheres) dispersion model, developed by the National Oceanic and Atmospheric Administration and the EPA, incorporates specific chemical release characteristics that provide somewhat more refined estimates of offsite impacts from a variety of chemical releases. ALOHA is part of the CAMEO (Computer-Aided Management of Emergency Operations) system used by many emergency response teams. SLAB, developed by the Lawrence Livermore National Laboratory, is a n EPA-recommended dense- gas model that provides more refined estimates of offsite impacts from heavier-than-air chemical releases. Should an accidental release occur that has potential for offsite consequences, plant-wide alarms will sound. The emergency response team will provide an immediate and rapid response and emergency shutdown systems and procedures will be activated. Modeling Limitations and Assumptions Air-dispersion models are limited in their ability to accurately predict the impact of a chemical release. Their limitations increase as the complexity of the topography surrounding the release site increases. The EPA-recommended models used for the FLEXSYS worst-case and alternative release scenarios have likely over-estimated the impact distance, because of several complicating conditions: 7 Surrounding the CS2 railcars, storage tanks, reactor vessel, and piping are large industrial buildings and structures. These features disrupt and redirect air flow, but the models used assume winds are steady and moving in a straight line. 7 Beyond plant property, buildings, structures, vegetation, and terrain features also serve to disrupt and redirect airflow. 7 The chemical emitted is assumed to have no reaction with the ground, other chemicals, or other potential release conditions. However, it is likely that a release of CS2 will deposit on the ground and other surfaces as it disperses from a ground-level source. In addition, because of an auto ignition temperature, CS2 will likely ignite. In each case, the resulting impact distance is likely to be less than the distance predicted by the models. Note that a "synergistic effect" can occur from two chemicals interacting during an accidental release. Such synergism results when the effect of two substances acting together "is gre ater than the sum of their individual effects." No synergistic reaction is expected with respect to CS2. PREVENTION PROGRAM The Prevention Program ensures that regulated substances are safely stored, used, and handled. In addition, if a chemical release occurs, the Prevention Program ensures that procedures and equipment are established to detect and mitigate the impact of such a release. The completion of Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) requirements essentially satisfies the 112(r) Prevention Program requirements for CS2 in the Program-level 3 processes. Safeguarding the public from accidental releases through an effective Prevention Program is an important component of the 112(r) rule. FLEXSYS has been diligent in its completion of the Program 3 Prevention Program requirements for: 7 Process safety information: FLEXSYS compiled written process safety information that is completed prior to conducting any process hazard analysis required by the rule. This written information enables FLEXSYS and the employees involved in operating the process to identify and understand the hazards posed by those processes involving regulated substances. Minimum information includes hazards data such as that found on a Material Safety Data Sheet, technology information, and equipment information. 7 Process hazard analysis: A hazard evaluation has been performed by an experienced team to identify, assess, and control the hazards involved in each of the covered areas. The HAZOP and "what-if" methodologies were used for determining and evaluating the hazards of the process. The analysis addressed the hazards of the process, the identification of any previous incident which had a likely potential for catastrophic consequences, engineering and administrative c ontrols applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases, consequences of failure of engineering and administrative controls, stationary source siting, human factors, and a qualitative evaluation of a range of possible safety and health effects of failure of controls. These analyses are being updated and revalidated on a five year basis. 7 Operating procedures: Written procedures have been developed and implemented to provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information. Elements that are addressed include steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions. Operating procedures are readily accessible to employees who work in or maintain a process. These procedures are reviewed as often as necessary to assure they represent current operating practice. Annual certification helps to assure the currency and accuracy of the procedures. In addition, safe work practices, applicable to employees and contractor employees, are developed and implemented to provide for the control of hazards during a variety of plant operations. 7 Training: Initial and refresher training is conducted as appropriate for each employee involved in operating a process. FLEXSYS ascertains and documents that each employee has received and understood the required training. 7 Mechanical integrity: FLEXSYS has developed a comprehensive mechanical integrity program that applies to pressure vessels and storage tanks, piping systems, relief and vent systems and devices, emergency shutdown systems, controls, and pumps in the covered processes. Writt en procedures, training for process maintenance activities, inspection and testing, correction of equipment deficiencies, and quality assurance are all included in FLEXSYS' mechanical integrity program. 7 Management of change: Written procedures have been established and implemented to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and changes to other stationary sources that affect a covered process. The procedures assure that the technical basis for the proposed change, the impact of the change on the environment, safety, and health, the modifications to operating procedures, the necessary time period for the change, and authorization requirements for the proposed change are all addressed. Appropriate employees and contractors are informed of, and trained in, the change prior to startup of the process or affected part of th e process. Updates to the RMP are made if required by the nature of the change. 7 Pre-startup review: A pre-startup safety review is performed for new covered processes and for significantly modified covered processes at FLEXSYS. Such review confirms that prior to introduction of regulated substances to the process that construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and adequate; for new stationary sources, a process hazard analysis has been performed and for modified stationary sources, management of change requirements have been met; and training of each employee involved in operating a process has been completed. 7 Compliance audits: FLEXSYS evaluates compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. FLEXSYS' compliance audit is conducted by a team consisting of outside auditors, the Manager of Safety & Training and representatives from each covered process. A report of the compliance audit findings is developed. FLEXSYS promptly determines and documents an appropriate response to each of the audit findings, establishes a schedule for acting on the findings and documents that deficiencies have been corrected. The two most recent audit reports are retained. 7 Incident investigation: FLEXSYS will investigate each incident that results in, or could reasonably result in a catastrophic release of a regulated substance. This investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident. An incident investigation team will be established with appropriate personnel. A report, which shall be retained for five years, is prepared at the conclusion of the investigation. A system has been established to promptly address and resolve the findings and recommendations of the incident report, with documentation of resolutions and corrective actions. The report shall be reviewed with all affected personnel, including contract employees where applicable, whose job tasks are relevant to the incident findings. 7 Employee participation: FLEXSYS has developed a written plan of action regarding employee participation. Employees and their representatives are consulted with on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in the 112(r) rule. Employees and their representatives are also provided access to process hazard analyses and to all other information required to be developed under the rule. 7 Hot-work permit: FLEXSYS issues a hot-work permit for hot-work operations conducted on or near a covered process. The permit documents that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot-work operations. The permit further indicates the date(s) authorized for hot work and identify the object on which the hot work is to be performed. The permit is kept on file until the hot-work operations is completed. 7 Contractors: FLEXSYS and contract-company owners and operators comply with the requirements for contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. Contractor issues include, among other responsibilities, evaluation of past contractor safety performance and programs, and informing contractors of known potential fire, explosion, or toxic release hazards related to the contractor's work and the affected processes. (Note that this part of the RMP requirements does not apply to contractors providing incidental services that do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services.) In summary, FLEXSYS is prepared to prevent and mitigate accidental releases by safe process and equipment design, maintenance of equipment, operating safely, and auditing our operations. 7 Process and Equipment Design: Backup safety systems, pressure relief valves venting to the flare stack, insulated vessels and piping, local emergency shut down system, and a reservoir system for the storage of CS2 tanks, are used to help mitigate the potential for leaks from the affected processes and equipment. 7 Equipment Maintenance: FLEXSYS has a preventive maintenance program in place along with work planning, safety checks and reviews, per iodic inspections, and qualified maintenance personnel. 7 Safe Operations: Operators are trained and certified. Operations are continuously monitored by the operator and computer. Written procedures are in place and followed by operators. 7 Operations Auditing: Internal and Independent audits of the CS2 operation are performed. FIVE YEAR ACCIDENT HISTORY For at least the past five years, no accidental releases from covered processes have occurred that resulted in deaths, injuries, or significant property damage onsite or known offsite, deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. EMERGENCY RESPONSE PROGRAM An Emergency Response Program has been developed and was implemented as required for the purpose of protecting public health and the environment. In-plant emergency response consists of training and planning to prepare for, prevent, respond to, and recover from em ergencies. Those situations identified include hazardous material releases, fire, explosion, floods, severe weather, and terrorism. A plant specific incident command system has been installed. This system is designed to be used for all types of emergencies, and is applicable to both small releases or minor fires and large-scale disasters. A chain-of-command and assigned responsibilities have been established within this system in order to assess and respond to emergency situations. Plant-wide alarms are activated in the event of an emergency. In addition to in-plant emergency response events, a system has been established in order to notify outside personnel. Depending on the severity and type of event, facilities/agencies notified include, but are not limited to, local police, fire and ambulance service, Local Emergency Planning Committee of Washington County, Pennsylvania Emergency Management Agency (PEMA), and the Pennsylva nia Department of Environmental Protection (Pittsburgh). PLANNED CHANGES TO IMPROVE SAFETY Work is underway to construct a dike at the railcar off-loading area, although, as reported above, the railcar is off-loaded only once a year. In other areas of the plant, instrumentation has been added to the emergency flare stack to assure that all three pilots are burning. Also, only a limited quantity of CS2 is typically contained in the processes' reactor vessel, thus reducing the amount that could potentially be released during an accident involving this unit. FLEXSYS has an ongoing program to evaluate and upgrade its safety systems. |