AlliedSignal Medical Products Facility - Executive Summary |
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AlliedSignal Kingman Plant Kingman, AZ. EPA Risk Management Program Executive Summary 1. Introduction: The Kingman facility is a manufacturing plant located in Kingman Arizona. It is part of the Specialty Chemicals Business Unit of AlliedSignal Inc. Headquartered in Morris Township, New Jersey, AlliedSignal is an advanced technology and manufacturing company serving customers worldwide with aerospace and automotive products, chemicals, fibers, plastics and advanced materials. With 1998 sales of approximately $15 billion, the company ranks among the top 100 of the Fortune 500. AlliedSignal has approximately 70,500 employees at 300 facilities in 40 countries. AlliedSignal operates twelve major businesses: Aerospace Equipment Systems, Aerospace Engines, Electronic and Avionics Systems, Aerospace Marketing Sales and Services, Federal Manufacturing and Technologies, Polymers, Specialty Chemicals, Electronic Materials, Consumer Products Group, Turbocharging Systems, T ruck Brake Systems and Friction Materials. More information about AlliedSignal may be found at its Web Page: www.AlliedSignal.com It is the world wide policy of AlliedSignal to design, manufacture and distribute its products and to handle and dispose of materials throughout their life cycle in a manner that protects the environment and safeguards employees, customers and the public from unacceptable risk. AlliedSignals complete Health, Safety and Environment Policy may be found at the AlliedSignal Web Page. This facility participates in the Responsible Care program of the Chemical Manufacturers Association. The Community Awareness and Emergency Response Code of Responsible Care brings chemical plants and local communities together through communications and cooperative emergency planning. The Process Safety Code of Responsible Care is designed to prevent fires, explosions and accidental chemical releases. The code requires safety audits, inspection and maintenance pr ograms, and safety training for employees and contract workers. Facilities are encouraged to listen to the concerns of the community and to consider these concerns when designing and implementing process safety systems. 2. Plant Description The Kingman Facility is located in the Kingman Airport Industrial Park at 4790 Olympic Drive, Kingman, Arizona. The facility currently has 10 employees. At the Kingman facility chlorotetrafluoroethane (Refrigerant-124) is mixed with ethylene oxide and chlorotetrafluoroethane (Refrigerant 124) and chlorodifluoromethane (Refrigerant 22) are mixed with EO to make Oxyfume 2000 and Oxyfume 2002 respectively. Oxyfume 2000 is used primarily by medical device manufacturers to sterilize medical devices such as sutures and lens implants for the eye prior to shipment to hospitals and doctors offices. Oxyfume 2002 is used primarily by hospitals to sterilize reusable heat sensitive devices such as various types of scopes used for arthoscopic surgery prior to reuse. The Kingman facility supports the local community by paying over $ 80,000 per year in taxes. The Plant Manager of the Kingman facility is a member of the Local Emergency Planning Committee (LEPC) and is active in helping to prepare the community to handle a potential emergency situation. The only chemical in the Kingman facility that requires the facility to participate in EPAs Risk Management Program is EO. At the Kingman facility, EO is stored in the same rail car in which it is shipped. The car is surrounded by a water deluge system for fire protection and to suppress vapors in the unlikely event a leak should occur. The EO car is only connected to the EO distribution piping when a transfer is being made to a blend tank. At all other times the car is disconnected and sealed. Transfers occur on an average of once per week and take about 4 hours. 3. Accidental release and emergency response policies The Kingman facility strictly adheres to all AlliedSignal corporate policies concerning Health Safety and Environmental Issues. It is the policy of the Kingman facility to: Protect people, property, and the environment by conducting programs for safety, loss prevention, product safety and integrity, occupational health and environmental excellence, and by formally reviewing and continually improving the effectiveness of the health, safety and environmental processes. The Kingman facility has a written facility specific Plant Emergency Response and Spill Plan. It is the objective of the Plan to provide sufficient information to formulate an initial response to a fire, explosion, or any unplanned release of hazardous material to the air, soil, or surface water at the facility. The Kingman Facility has a management employee who is dedicated to managing all Health, Safety, Environmental and Emergency response issues. This individual is responsible for ensuring compliance with all regulatory requirements and ov erseeing the facilitys response to any unforeseen incident. It is the Plant Managers responsibility to ensure that all policies and procedures are comprehensive, complete and followed. Local emergency responders are familiar with the Kingman facility. The facility has conducted tours for the firefighters from the local fire district and has held joint emergency response drills with those individuals. The facility has also provided financial support to the local fire district by purchasing equipment used for emergency response and donating it to the fire district. The Kingman Regional Medical Center has been given information on all of the chemicals at the Kingman facility. Treatment protocols for exposed patients have also been provided. 4. Worst case and alternative release scenarios and administrative and mitigation controls in place to limit the impact of a release EPAs RMP regulations required the Kingman facility to model the dispersion and off-site impacts of EO which would be released to the atmosphere in the event of a hypothetical worst case release scenario occurring at the Kingman facility. The Kingman facilitys worst case scenario is the hypothetical failure of an EO railcar containing a maximum of 75,000 pounds of EO. As required by EPAs regulations, the worst case scenario air dispersion modeling assumed that the resulting spill from the railcar could not be controlled by the facilitys EO spill mitigation system (described more fully below) and furthermore, that the entire 75,000 pounds of spilled EO would vaporize in 10 minutes. Under these unlikely assumptions, the toxic cloud formed by the vaporized EO would reach offsite endpoints and public receptors under certain meteorological conditions assumed in the air dispersion modeling required by EPA. For a number of reasons, it is extremely unlikely that this event would ever occur. Should the entire liquid EO contents of the railcar be released through failure of the railcar while located at the Kingman facility, the EO would fall into the collection pan below the railcar and drain to a collection sump. Upon release of the EO, a sensor above the EO railcar would alarm notifying plant personnel and turn on a water deluge system. The water deluge would serve to suppress the evaporation and dispersion of the EO. Thus, although a portion of the 75,000 pounds would evaporate immediately, most evaporation would occur and be dispersed more slowly over an extended period of time without the same off-site consequences predicted by the worst case scenario modeling. EPAs regulations also require the modeled dispersion and off-site impacts of EO which would be released to the atmosphere in the event of a more credible alternate scenario occurring at the Kingman facility. The alternate scenario for the Kingman facility involves a leak in a stainless steel braided hose on the discharge of the EO transfer pump. It was assumed that the ho se would crack and that an opening 1/16 of and inch wide and extending for < of the circumference of the hose would occur. Mitigation of this type of release would automatically occur through a system of interlocks and alarms. An EO detection pickup point is located in close proximity to the EO transfer pump. When that sensor detects an EO concentration above 15 ppm, an alarm will sound alerting on-site personnel. A system of interlocks will also be activated. The interlocks will shut down the EO transfer pump reducing the pressure at the leak site. The interlocks will also close the outlet valves on the EO railcar, minimizing the amount of EO that could potentially escape through the leak. Plant personnel responding to the alarm in appropriate personnel protective equipment will further isolate the leak through a system of manually operated valves. EO monitoring points located at the plant fence line will detect any potential off site impact and prompt notification of community emergency response personnel. The anticipated plume from this release will not impact any private residences. However, it could impact the exercise yard of a local prison. The buildings in the prison are outside the anticipated impact zone. 5. General accidental release prevention program and chemical specific accident prevention program The Kingman facility has a comprehensive general accidental release prevention program. The program is comprised of 12 elements. The activities at the Kingman facility in each of these elements are described briefly below. Process Safety Information: The Process Safety Information section of the program is designed to help those involved in operating the process to identify and understand the hazards posed by those processes involving regulated chemicals. Process Safety Information will include information on: - The hazards of the regulated chemicals used or produced by the process. - Information on the technology of the process. - Information on the equipment in the process Process Hazard Analysis: A Process Hazards Analysis has been completed for all processes that use regulated chemicals. These analyses are used to review areas involved in the use, storage, manufacturing, handling, or onsite movement of regulated chemicals. The Hazards and Operability Method (HAZOP) is to be used to perform PHAs at the AlliedSignal Kingman facility. Standard Operation Procedures (SOP): Written operating procedures have been developed that provide clear instructions for safely conducting activities involved in the processes that use regulated chemicals. Each of these SOPs includes steps to complete the operating phases, operating limits, and safety and health considerations. All RMP operation procedures are reviewed modified as necessary, and reissued annually. Training: All employees, including maintenance and contract employees involved with the covered process, are trained on the specif ic safety and health hazards of the process. They are also trained on emergency operations including shutdown, and other safe work practices that apply to the employees job task. Mechanical Integrity: The Mechanical Integrity Program at the Kingman facility is structured to assure that equipment involved in the use, storage, manufacturing, handling, or onsite movement of regulated chemicals is designed, fabricated, installed, and maintained to minimize the risk of releases of these chemicals. Management of Change The Management of Change process at the Kingman facility is the process by which any permanent or temporary modifications to process chemicals, technology, equipment, or facilities are managed. The process is used to sustain or enhance the level of process safety within the Kingman facility. The Management of Change procedure applies to all AlliedSignal employees and contractors at the Kingman facility that are involved in operating and/or maintaining any of the equipment covered by the Risk Management Program Pre-Startup Review: Pre-start-up safety reviews are used to help ensure designs and procedures are complete and thorough prior to bringing on line a new facility or a significantly redesigned existing unit. Reviews will be done on all units covered by the Risk Management Program. Compliance Audits: Compliance audits will be performed by Kingman facility personnel or outside corporate auditors as required. Incident Investigation: Proper incident investigation is necessary to continuously improve the safety in the Kingman facility. By identifying contributing factors that create variations (incidents) and defining corrective actions, prevention efforts can be properly focused. All incidents that cause or have the potential to cause injury to personnel or significant damage to equipment, the environment, or the public are investigated. Employee Participation: The Kingman facilitys management consults with employees on the development and implementation of the elements of RMP. Management also consults with plant employees during the conduct of process hazards analysis. The plant will provide to employees access to process hazard analysis and to all other information required to be developed under this standard. Hot Work Permits: The Kingman facility has a comprehensive procedure outlining requirements for completing any activity involving hot work. The procedure requires that the activity must be reviewed and the hazards identified. Those hazards must be communicated to all personnel whose activities could affect the safety of the individuals performing the hot work or of the process in general. Contractors: The Kingman facility has a program to insure that contractors who work in the Kingman facility do so without compromising their safety or the safety of others in the plant. This program covers all contractors working in or adjacent to a covered process. Safety performance shall be considered during the contractor selection process. In addition, contractors shall maintain, for AlliedSignals review, records documenting that his employees are properly trained in their particular craft line(s). Contractors shall also maintain for AlliedSignals review, all records of safety meetings and safety-related incidents requiring disciplinary action. Chemical specific accident prevention programs: The facilities, equipment, and the chemical covered by the EPA Risk Management Program at the Kingman facility have been reviewed several times by multiple teams comprised of people from widely varying backgrounds. Recommendations from these reviews have been studied and implemented where appropriate. Consequently the chemical specific prevention programs at the Kingman facility are comprehensive and well engineered. Those safeguards include the following engineering controls: 1) EO is shipped to the facility in two specially designed and constructed railcars. These cars exceed DOT standards for the transport of EO and are only used to transport EO to the Kingman facility. In order to minimize the amount of EO in the facility at one time these cars hold a maximum of 75,000 pounds. The facility also restricts the number of cars on site at any time to one. 2) The only storage of pure EO that occurs at the Kingman facility is in the railcar in which the EO was shipped to the facility. The same railcar is used for shipping and storage to minimize the risk of contamination of the EO. The EO car is only connected to the facilitys EO distribution system while a transfer to a blend tank is occurring. At all other times, the car is disconnected and sealed. By following this procedure, the facility can minimize the risk of contamination of the railcar and reduce the potential for leaks in the transfer piping. 3) The EO car is positioned under a water deluge system at all times while on the facility. In the event of a g rass fire or a fire on the car, the deluge will protect the car from the heat of the fire or extinguish the fire if the fire is on the car. If the car should begin to leak, the water deluge can be used to suppress the escaping vapor. Should an exothermic reaction occur in the car, the deluge can be used to remove the heat of reaction in the car. The deluge is activated by fire on the car, high EO concentration above the car (see No. 4) or by manual activation. Water from the rail car deluge system falls into a collection pan. The collection pan drains underground to a below ground lined collection basin. Adding large amounts of water to any EO release will reduce the vapor pressure of the EO and suppress the flammability. 4) When the EO car is positioned under the water deluge system, there is an EO detection point immediately above the dome of the car. There is also a detection point next to the EO transfer pump. These detectors are set to activate a local alarm a t 15 ppm EO. The facilitys off site security company receives an alarm at 30 ppm EO so that it can notify plant personnel 24 hours a day. The detector on top of the railcar is set to turn on the water deluge at .7% EO to suppress escaping vapor and prevent ignition. Early awareness of small EO leaks helps the facility take the appropriate action to prevent a release that would impact off site population. 5) The hose used to transfer liquid EO from the EO railcar to the distribution system is a double walled hose. If the inner hose fails, the EO is trapped inside the outer hose and does not escape. The annular space between the hoses is checked for pressure every time the car is connected. The annular space is checked for trace amounts of EO every 6 months. If a leak in the inner hose is detected, the hose is replaced. This procedure reduces the risk of a serious failure of the transfer hose resulting in a significant leak. 6) The liquid and vapor outlets of the EO railcar are connected through automatic valves during transfers to the blend tanks. The automatic valves will close to isolate the contents of the railcar in the event of any abnormal circumstance. An abnormal circumstance could be the detection of EO in excess of 15 ppm by the EO detectors described in item No. 4. It may also be the shut down of EO transfer pump for any reason. By closing the automatic valves on the EO car during abnormal conditions, the amount of EO that can potentially be released if a leak should occur is minimized. 7) All five-blend tanks are equipped with safety relief valves to release excess pressure in the tank prior to catastrophic failure of the vessel. In addition each tank has remotely operated automatic valves on all bottom outlets from the tanks. The valves can be quickly shut isolating the tank contents from transfer piping from a remote location in the event a leak occurs. Shutting these valves minimizes the amount of material that would leak out if a leak were to occur. 8) In conjunction with the EO detection system described in Item 4 above, an additional EO monitoring system covers the Kingman facility. This system alarms when an EO concentration in excess of 1 ppm is detected at any one of 20 monitoring points. 3 of these monitoring points are located at the property fence line and will provide warning should a release in the facility have a potential off site impact. By detecting leaks in our piping systems with the above EO detection equipment when they are small, we can address those leaks before they become larger and can have a significant off site impact. 6. Five-Year Accident History The Kingman facility has never had a release of ethylene oxide that had an on site or offsite impact. 7. Emergency Response Program The Kingman facility has a written facility specific Plant Emergency Response and Spill Plan. It is the objective of the Plan to provide sufficient information to formu late an initial response to a fire, explosion, or any unplanned release of hazardous material to the air, soil, or surface water at the facility. In the event of a Plant Emergency all personnel in the facility will gather at the assembly point. After a head count, the nature of the emergency will be determined. If the emergency can be handled with plant personnel and there is no potential for off site impact, mitigation of the emergency will begin immediately. If the emergency includes a fire or has the potential for off site impact, the Hualapai Valley Fire Department and the Sheriffs department will be notified to coordinate fire fighting and evacuation of the surrounding population respectively. In addition the Mohave County Local Emergency Planning Committee (LEPC) will be notified to assist as necessary. First aid and subsequent treatment of any injured plant personnel or surrounding population will be handled by Kingman Regional Medical Center. KRMC has a fact book on the Kingman facilitys Chemicals, including Material Safety Data Sheets and treatment recommendations. All plant personnel receive a minimum of 16 hours of emergency response training each year. This training includes classroom training as well as hands on training of simulated emergencies. The Hualapai Valley Fire Department has sent personnel to participate in the 16-hour emergency response session held each fall. 8. Planned Changes to Improve Safety The Kingman facility has never had an RMP type accident. However, all incidents that cause or have the potential to cause injury to personnel or significant damage to equipment, the environment, or the public are investigated. From those investigations several changes have been made to the equipment and procedures at the Kingman facility. In addition, a Process Hazards Analysis has been completed for all processes that use regulated chemicals. These analyses are used to review areas involved in the use, stora ge, manufacturing, handling, or onsite movement of regulated chemicals. The analyses are reviewed and updated on a periodic basis. Recommendations for changes to improve process safety are gathered from the incident investigations and hazard reviews. All outstanding recommendations have been carefully reviewed and where appropriate implemented at the Kingman facility. There are currently no outstanding recommendations to improve safety in the Kingman facility. |