ISP Chemicals - Huntsville - Executive Summary |
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ISP Huntsville Plant Risk Management Plan 1. EXECUTIVE SUMMARY The ISP Huntsville Plant is committed to operating in a manner that is safe for Huntsville Plant workers, Redstone Arsenal (RSA) on-site personnel, the public, and the environment. For example, as a member of the Chemical Manufacturers Association and the Synthetic Organic Chemical Manufacturers Association, ISP implements the principles of Responsible Care to ensure a safe and environmentally sound operation. In addition, there are RSA coordinated environmental, health, safety, and emergency response programs and procedures, which ISP adheres to. Also as part of ISP's over-all commitment to Envirnmental Health and Safety, the Huntsville Plant has established systems to help ensure safe operation of the processes at our facility. One part of these systems is a risk management program (RMP) that helps manage the risks at the Huntsville Plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) rule 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at the Huntsville Plant. This document is intended to satisfy the RMPlan executive summary requirements of the RMP rule and to provide the public with a description of the risk management program at the Huntsville Plant. 1.1.1 Accidental Release Prevention and Emergency Response Policies The ISP Huntsville Plant is committed to the safety of Huntsville Plant workers, RSA employees, and the public, and to the preservation of the environment through the prevention of accidental releases of hazardous substances. The Huntsville Plant implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, our trained personnel will respond to control and contain such releases. The Huntsville Plant evaluates each situation, evacuates workers as necessary, responds based on our capabilities and training, and if necessary, contacts the RSA Emergency Response Team which has both the resources and training to respond to major fires and hazardous substance releases. The RSA Installation Response Team (a.k.a. the RSA Fire Department) coordinates emergency response activities with both base and if need be additional local emergency personnel (e.g., the Huntsville- Madison County Emergency Management Agency) to assist in controlling and containing the release and to prevent and/or reduce the consequences of the release. The Huntsville Plant and the RSA Installation Response Team have established a system for warning RSA employees if an accident occurs that could threat en the base or surrounding community. The Huntsville plant manager has overall responsibility for the development and implementation of the risk management program for EPA-regulated processes at the facility. However, the specific responsibilities for certain aspects of that program have been delegated to the plant engineer and the plant foreman who report directly to the plant manager. Specific responsibility for the implementation of certain portions of the process safety management (PSM) and accident prevention program has been delegated to the aforementioned employees. The responsibility for the RMP hazard assessment and risk management plan, and the emergency response program, including compliance with the RMP aspects has been delegated to the plant manager and plant engineer. In keeping with our policy that safe operation is part of everyone's job, many other personnel are also involved in RMP activities on an ongoing basis. 1.2 The ISP Huntsville Plant Regulated Substances The ISP Huntsville Plant is a chemical manufacturing facility located at the Redstone Arsenal in Huntsville, Alabama. We lease this from the US Army and we have been operating at this site since 1949. There are approximately 22 ISP employees who work at this site. We use ammonia, hydrogen, carbon monoxide, and iron as our feed materials. The principle products made at the ISP Huntsville Plant are Carbonyl Iron powder and Iron Pentacarbonyl. Some of these feed materials and products are toxic substances that EPA has specifically listed in the RMP rule and are present in our process units above the specified EPA threshold quantity. 1.3 Offsite Consequence Analysis The Huntsville Plant performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance that could affect the base, public or the environment. The offsite consequence analysis consists of evaluating both worst-case scenarios and alternative release scenarios. The Hunt sville Plant does not expect a worst-case release scenario to ever occur. An alternative release scenario represents a release that might occur during the lifetime of a facility like The Huntsville Plant. Alternative release scenarios can be used to help the Redstone Arsenal LEPC and the RSA Installation Response Team (a.k.a. the RSA Fire Department) improve the emergency response capabilities. We have shared that information with the Redstone Arsenal LEPC and other base emergency personnel. It is also available to local residents and businesses. If you are interested in this information, please contact our RMP coordinator at 256-882-0177. The main objective of performing the offsite consequence analysis is to determine the distance at which certain effects might occur to RSA employees or the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance: - When considering the release of a toxic substanc e, most people at the endpoint distance would be able to walk away from the exposure without any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely. Some people who are particularly susceptible to the substance released could be incapacitated. - Although there are no flammable substances above the RMP threshold, the following effects were considered as a part of emergency response planning effort. - When considering explosion of a flammable substance, people at the endpoint distance are likely to be knocked down by the blast. Windows could shatter, and the potential for structural damage to buildings exists, although a building collapse is unlikely. People could be seriously injured by being knocked down by the force of the blast, by flying glass, or by falling objects. - When considering the fire hazard of a flamma ble substance, people at the endpoint distance are likely to receive second-degree burns over the exposed parts of their bodies if they cannot quickly find cover or otherwise escape the heat of the flame. These burns are likely to require hospitalization. At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effects would be less. Worst-case Release Scenarios The worst-case scenarios associated with toxic substances in the RMP-covered process at the plant are a 30,600 pound pressurized storage tank failure, resulting in a release of ammonia and a 55 gallon drum failure containing IPC, resulting in the release of iron pentacarbonyl. The gaseous ammonia release was assumed to occur during a 10-minute period. In contrast, a liquid IPC release time of 135 minutes was calculated using the EPA off-site consequence manual. It should be noted that there are passive mitiga tion controls on the IPC storage tank system which we have taken credit for. This passive mitigation control incorporates a water seal on product leakage from the storage tank and this control is deemed to be both capable and reliable. It should be noted that we have numerous additional controls to prevent such releases and to manage their consequences. However, no credit was taken for them when evaluating the impact of worst case toxic releases (see table below.) RMP Regulated Toxic Chemical RMP Program Level Worst Case Scenario Ammonia 3 Will not travel off RSA property Iron Pentacarbonyl 3 Will not travel off RSA property Alternative Release Scenarios The alternative release scenario for toxic substances in the RMP covered processes at the plant are rupture of a 1/2" or ifice tap tubing, resulting in a release of 650 cubic feet of ammonia, and a spill from a 55 gallon drum containing an IPC mixture, resulting in the release of iron pentacarbonyl. The release duration is 16 - 20 minutes. The impact of alternate case toxic releases is summarized in the table below. RMP Regulated Toxic Chemical RMP Program Level Alternate Case Scenario Ammonia 3 Will not travel off RSA property Iron Pentacarbonyl 3 Will not travel off RSA property 1.4 Accidental Release Prevention Program The following is a summary of the general accident prevention program in place at the Huntsville Plant. The processes at the Huntsville Plant that are regulated by the EPA RMP regulation are also subject to the Occupational Safety and Health Administration (OSHA ) process safety management (PSM) standard. Because the OSHA PSM requirements are very similar to the EPA RMP requirements for chemical manufacturing facilities, this summary addresses each of the OSHA PSM elements. The PSM program at this facility has been extended by the Huntsville Plant, where necessary, to satisfy EPA's Program Level 3 accident prevention program requirements. 1.4.1 Employee Participation The Huntsville Plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of process hazard analysis (PHA), incident investigation, and plant and process inspection teams. Employees have access to all information created as part of the Huntsville Plant accident prevention program. 1.4.2 Process Safety Information The Huntsville Plant keeps a variety of technical documents that ar e used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. The plant manager and plant engineer at the Huntsville Plant are assigned responsibility for maintaining up-to-date process safety information. Key reference documents are located in the plant engineer's office and are readily available. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address safe handling, storage and use. Some of the documents included are "Safety Requirements for the Storage and Handling of Anhydrous Ammonia" published by American National Standards Institute and the publication by Compressed Gass Association titled "Anhydrous Ammonia". Fo r specific process areas, the Huntsville Plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in a critical operating procedures/ Key Process Parameter Document). The Huntsville Plant ensures that the process is maintained within these limits by using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The Huntsville Plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process a re not compromised. 1.4.3 Process Hazard Analysis The Huntsville Plant has a comprehensive PHA program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage those hazards. The Huntsville Plant primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques available. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes recommendations for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team recommendations are forwarded to local Layer of Protection Analysis (LOPA) Team for Risk management evaluation and resolution. Implementation of safety improvements in response to PHA findings is based on corporate risk acceptance criteria. This ensures that potential accident scenarios with the highest risks receive immediate attention. All approved safety improvements being implemented in response to PHA team recommendations are tracked until they are complete. The final resolution of each recommendation is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Huntsville Plant periodically updates and revalidates the PHA results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and recommendations from these updates are documented and retained. Any new team findings are forw arded to the local Layer of Protection Analysis (LOPA) Team for risk analyses and the final resolution of the recommendations is documented and retained. 1.4.4 Operating Procedures The Huntsville Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made to the process. In addition, the Huntsville Plant operating procedures provide guidance on how to respond to events that result in exceeding safe operating limits for specific process or equipment parameters. The written operating procedures are readily available to ope rators in the process units and for other personnel to use as necessary to safely perform their job tasks. It should be noted that there are only 2 processes conducted at the Huntsville Plant. 1.4.5 Training To complement the written procedures for process operations, the Huntsville Plant has implemented a company training program for all employees involved in operating a process. New employees receive basic training in Huntsville Plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. Refresher training is conducted in concert with the routine job safety analysis and training improvement effort. All of this training is documented and include the means to verify operator understanding. 1.4.6 Contractors The Huntsville Plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the Huntsville Plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Huntsville Plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirement s, and (4) safe work practices prior to their beginning work. In addition, the Huntsville Plant evaluates contractor safety programs and performance during the selection of a contractor. Huntsville Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 1.4.7 Pre-startup Safety Reviews The Huntsville Plant conducts a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information. The purpose of the review is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The review team uses checklists to verify all aspects of readiness. A review involves field verification of the c onstruction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. 1.4.8 Mechanical Integrity The Huntsville Plant is updating and revising its practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner . Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, management will correct the deficiency before placing the equipment back into service (if possible), or management of change will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Huntsville Plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. 1.4.9 Safe Work Practices The Huntsville Plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the en try/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control welding and other spark-producing activities, and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 1.4.10 Management of Change The Huntsville Plant has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change. 1.4.11 Incident Investigation The Huntsville Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to Huntsville Plant management for resolution. Corrective actions taken i n response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. 1.4.12 Compliance Audits To help ensure that the accident prevention program is functioning properly, the Huntsville Plant periodically conducts audits to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to Huntsville Plant management for resolution. Corrective actions taken in response to the audit tea m's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. 1.5 Chemical-specific Prevention Steps The processes at the Huntsville Plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all EPA RMP-covered processes at the Huntsville Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures or human errors. In addition to the accident prevention program activities, the Huntsville Plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safety features are used in various processes: Release Detection - Chemical-specific detectors with alarms in selected areas (e.g., hydrogen and carbon monoxide detectors). Release Containment/Control - Process relief valves that discharge to an elevated vent point to safely disperse any vapors. - Manual and automatic valves to permit isolation of the process - Automated shutdown systems for specific process parameters (e.g., high level, high temperature) - Curbing or diking to contain liquid releases - Release mitigation systems (water seal to contain IPC releases; locations include IPC storage tanks, feed system to decomposers, and IPC reactor area). - Fire suppression and extinguishing systems - Trained emergency response personnel - Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 1.6 Five-year Accident History No releases of regulated substances have occurred from Huntsville Plant in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site. 1.7 Emergency Response Program The Huntsville Plant maintains a written emergency preparedness manual, which is in place to protect worker, RSA employee, and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, plant evacuation plans and accounting for plant personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and postincident cleanup and decontamination requirements. The emergency response program is updated when necessary based on modifications made to plant processes or facilities. The emergency response program changes are administered through the management of change process, which inclu des informing and/or training affected personnel in the changes. The overall emergency response program for the Huntsville Plant is coordinated with RSA Installation Response Team (a.k.a. the RSA Fire Department) and Redstone Arsenal LEPC and with offsite responders who would be called to support emergency response efforts if required. The arsenal emergency response requirements are setforth in the RSA Installation Spill Contingency Plan (ISCP) which is the basis for the site's emergency response program. The ISCP serves as the basis for training, required actions, and joint response efforts. This coordination includes periodic meetings of the LEPC, which consists of RSA emergency response team members. The Huntsville Plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to participating in periodic LEPC meetings, the Huntsville Plant conducts periodic emergency drills that involve the RSA Installation Response Team, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant. 1.8 Planned Changes to Improve Safety Huntsville Plant constantly strives to improve the safety of its operations through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers. The Huntsville Plant resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned during the next 5 years: - Relocate a blow out panel for the decomposer oil fired furnace so that it relieves to a safer location. - Decrease process inventory inside process building by eliminating an ammonia storage tank. - Revised process instrumentation and/or controls in t he iron pentacarbonyl production unit (e.g., low low gasholder level interlock to CO compressor shut down switch.) - Revisions to personnel training programs - Revised written operating procedures in the iron pentacarbonyl reaction area - Install hard piping system to eliminate process handling of 55 gallon drums containing IPC |