Unilever Home & Personal Care USA - Raeford - Executive Summary |
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Unilever Home & Personal Care USA Raeford Facility (formerly Chesebrough-Ponds USA) RMP Executive Summary 1.0 Facility Description / Regulated Substances Handled The Unilever Home & Personal Care USA - Raeford, North Carolina facility manufactures consumer personal goods such as hairsprays, mousses, and deodorants. Several manufacturing lines at the facility use propellants to pressurize aerosol cans. EPA regulates these propellants due to their flammability. The specific regulated substances that are used onsite above the threshold quantities are: * Butane (CAS No. 106-97-8) * Difluoroethane (152a) (CAS No. 75-37-6) * Isobutane (CAS No. 75-28-5) * Methyl Ether (DME) (CAS No. 115-10-6) * Propane (CAS No. 74-98-6) The methyl ether and difluoroethane tanks contain pure product, while several different mixtures of the butane, isobutane, and propane are stored in separate tanks. The above-listed regulated substances can be handled at the facility either by rail car or by truck. Ra il cars loads are tested, chocked, and pressurized to storage tank pressure. The contents are loaded from the rail car to the storage tanks using grounded iron pipes and pressure relief valves for safety. Afterwards the vapors from the rail car are drawn down to near atmospheric pressure before moving empty rail cars offsite. Truckloads are grounded, then pumped to the storage tanks through rubber hoses and control valves. Truck transfers rely on the on-board pump and compressor of the truck to perform unloading. Propellants are transferred from Storage Tanks to the manufacturing gashouses through iron pipes that have relief valves and control system actuators. The propellants are vaporized in a heat exchanger inside the gashouse for use in the making of aerosols. Excess propellant is vented back to the storage tanks. Preparation of the Risk Management Plan has shown that the distance to a flammable endpoint for a worst-case release assessment is greater than the nearest public receptor. This assumption, coupled with the fact that processes at the Raeford facility are subject to the OSHA PSM standard, makes the facility subject to Program 3 requirements. In addition, Unilever maintains several warehouses on site containing finished products. These warehouses contain propellants in excess of the regulatory threshold. The individual warehouses are listed as separate Program 1 processes. 2.0 Accidental Release Prevention & Emergency Response Policies The Raeford facility affirms to its employees, customers, shareholders, and the public that it will conduct its business with respect and care for the environment and the health and safety of its employees and the public. The Unilever HPC USA Company pledges accountability to ensure the continued maintenance of its Process Safety Management policy and program that will endure throughout the life cycle of the process. In particular, Unilever will support this principal goal by incorporation of these specific objectives in each of the PSM Program Elements: Establishment of a corporate culture in support of the PSM effort; Sustained perspective on the scope and importance of the PSM program; and Demonstration of management support for PSM program objectives. To effectively manage the element of accidental release and emergency response in the PSM program, Unilever HPC has developed an Emergency Planning and Response Program. The program document lists the requirements, applicabilities, and responsibilities, for the program to ensure that compliance with each requirement will be achieved. In particular, Unilever HPC has incorporated the following objectives into all of its PSM program documents: Continuity of Operations; Continuity of Systems; Continuity of Organizations; Control of Exceptions and Variances; Management Accessibility and Accountability; Employee Involvement; Communications; and Reduction in incidents, injuries, and property loss. A statement from the plant manager that reiterates the commitment above precedes the Emergency Response Manual. 3.0 Five-Year Accident History The following table outlines the accidental releases that have occurred in the aerosol process during the previous five years and involved regulated substances listed above. For all these events, no injuries, deaths, or property damage occurred, either on- or off-site. Date Substance Response & Changes 2/20/95 Isobutane/ propane mixture Activated fire brigades onsite and involved Raeford FD. Evacuated both the Aerosol and Main Process Buildings as a precautionary measure. Improved/upgraded equipment; revised operating procedures, and revised the emergency plan 6/8/95 Butane/ propane mixture Activated fire brigades onsite and involved Raeford FD. Evacuated the Aerosol Process Building as a precautionary measure. Improved/upgraded equipment 11/10/95 Butane/ propane mixture Activated fire brigades onsite and involved Raeford F D. Evacuated the Aerosol Process Building as a precautionary measure. Improved/upgraded equipment 11/18/95 Isobutane/ propane mixture Activated fire brigades onsite and involved Raeford FD. New mitigation system installed to cease operations if set percentage of LEL exceeded 1/9/96 Isobutane/ propane mixture Activated fire brigades onsite and involved Raeford FD. Evacuated the Aerosol Process Building as a precautionary measure. Improved/upgraded equipment 6/24/96 Isobutane/ propane mixture Activated fire brigades onsite and involved Raeford FD. Evacuated the Aerosol Process Building as a precautionary measure. Evacuated some 30 persons from offsite facilities as precautionary measure; notified state spill response agency although Reportable Quantity was not exceeded. Improved/upgraded equipment 9/8/97 Isobutane/ propane mixture ctivated fire brigades onsite and involved Raeford FD. Improved/upgraded equipment 4.0 Worst-Case and Alternative Scenarios Worst-C ase Scenario is the failure of largest vessel, a railcar load containing isobutane. Railcars are dropped by locomotives before unloading, therefore railcar volume is assumed to contribute to site totals. The railcar contributes approximately 160,000 pounds (lb.) to the event. The entire contents are assumed to be released as vapor. Ten percent of the released quantity is assumed to participate in the vapor cloud explosion. Distance to the endpoint of 1-psi overpressure is 0.44 miles. Public receptors inside this radius include businesses and residences. The estimated population within the modeled radius is 61. Alternative Scenario is taken from the most significant incident from the five-year accident history. On June 24, 1996, a relief valve failed on the A-75 propellant line releasing 488 lb of isobutane/propane mixture. The excess flow valve system stopped the flow and the relief valve vented to atmosphere. Vapors were dispersed using water. Grounding systems prevented ig nition of the vapors. The alternative scenario of a vapor cloud explosion from this release was modeled from Worst-case conditions in RMP*Comp. Distance to the endpoint of 1-psi overpressure is 0.06 miles. No public receptors occur within this radius; however, the radius does extend across the railroad line on the east boundary of the facility. Worst-case Scenario for Warehouse Operations is failure of one 14-ounce aerosol container (this contains 0.30 pounds of propellant). The worst-case scenario would affect a radius of 0.005 miles, which does not affect any off-site receptors. Due to limitations of RMP*Submit, the input parameters were 1 pound and 0.01 miles. 5.0 General Accidental Release Prevention Program Unilever HPC manages accidental releases in several elements of the PSM Program, each of which is described below: 5.1 Process Hazard Analysis The purpose of the process hazard analysis program document is to ensure that an initial process hazard analysis is performe d for each process covered by the PSM standard and to ensure that the process hazard analysis is appropriate to the complexity of the process. This document helps to ensure that the PHA identifies, evaluates, and controls the hazards involved in the process. A Process Hazard Analysis must be performed on each of the covered processes using a team with the appropriate expertise; The Hazard Analysis method may be HAZOP, FMEA, WHAT-IF, CHECKLIST, or an equivalent method appropriate to the complexity of the process; The hazard analysis must address: hazards of the process previous incidents or near misses engineering and administrative controls facility siting, human factors evaluation of effects of failures on employees The PHA aspects requirements of the PSM rule require the system to handle recommendations and findings to ensure that they are resolved, scheduled, completed, fully documented, and communicated to affected employees in a timely manner. The priority order for hazard analy ses must be documented and based on considerations including the hazards, affected employees, age of the process, and history of the process; 5.2 Pre-Startup Safety Review Pre-startup safety review occurs immediately prior to the initial startup of any new or modified existing process, ensuring that a team of specialists performs a complete, consistent and systematic safety evaluation. An additional purpose of the review is to confirm that safety devices are properly checked and operational. A Pre-Startup Safety Review must be performed for new or modified facilities when the modification is significant enough to require a change in Process Safety Information. This review must confirm that: construction and equipment meet design specifications; safety, operating, maintenance, and emergency procedures are in place; training has been completed; for new processes, the Hazard Analysis has been completed and the recommendations resolved; for modified facilities, the Management of Chan ge requirements have been met. 5.3 Design Codes And Standards Employed Design codes and standards employed in the construction and operation of the Aerosol Plant include both regulatory and industry consensus guidelines. Regulatory codes employed include: OSHA 1910.110, Storage and Handling of Liquefied Petroleum Gases; National Fire Protection Association (NFPA) 58, Storage and Handling of Liquefied Petroleum Gases; NFPA 12A, Halon 1301 Fire Extinguishing Systems; NFPA 30, Flammable and Combustible Liquids Code; NFPA 30B, Manufacture and Storage of Aerosol Products; NFPA 68, Venting of Deflagrations; and NFPA 69, Explosion Prevention Systems. Industry standards employed in the Aerosol Plant design include Factory Mutual Data Sheet 1-44, Damage Limiting Structure: Pressure-Resistant Walls; The Aerosol Handbook, by Montfort A. Johnson (Wayne E. Dorland Company, publisher); Static Protection for Flammable Materials, published by Du Pont; Factory Mutual Engineering Handbook of Indust rial Loss Prevention, Chapter 43, "Liquefied Petroleum Gas;" and Hydrocarbon, Dimethyl Ether, and other Propellants: Considerations for Effective Handling in the Aerosol Plant and Laboratory, published by the Chemical Specialties Manufacturers Association. 5.4 Safety Systems Safety systems associated with the aerosol process lines include a halon system in the Gas Houses; an MSA vapor detection and alarm system; an automatic line shutdown; the SCRAM alarm; and a fire protection sprinkler system. 5.5 PSM Training Program Content The primary goal of training is to ensure that operating, technical, and maintenance personnel, including contractors, are aware of important PSM-related concepts, such as: hazards present in the process; the significance of their actions relative to process safety; how to operate and maintain the process within safe operating limits as specified in established process safety information; and how to handle potential emergencies in the process area. These important PSM-related elements are presented to personnel through a combination of initial and refresher training programs. Finally, The RMP Accidental Release Program requirements are contained in the PSM Compliance Audit Program, which evaluates the health of the PSM program and the RMP accidental release program elements. 6.0 Emergency Response Program The Emergency Response Manual is designed to comply with the following requirements: 29 CFR 1910.119 (n) - OSHA Process Safety Management Emergency Planning and Response 29 CFR 1910.120 (q) (2) - OSHA Hazardous Waste Operations Emergency Response Planning 29 CFR 1910.38 (a) - OSHA Emergency Action Planning 40 CFR 264.52 - RCRA Emergency Contingency Planning NFPA 471 - Recommended Practices for Responding to Hazardous Materials Incidents Unilever HPC coordinates drills for emergency response activities with Terry Tapp, the Fire Chief for the City of Raeford. The last inspection of the facility by the fire department was March 199 8. In addition, facility also works closely with the Hoke County LEPC, led by the County Fire Chief, Alex Schwarcbher. 7.0 Planned Commitments to Safety Improvements Unilever HPC continuously improves its PSM program through a change-controlled process. No major changes are planned at this time for safety improvements. However, the PSM program has demonstrated its ability to manage improvements to safety, both proactively through HAZOP analysis of process changes and reactively through feedback from Emergency Response incidents and drills. |