AlliedSignal Friction Materials - Green Island - Executive Summary |
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Executive Summary The AlliedSignal Friction Materials facility is a manufacturing plant located in Green Island, NY. It is part of the Friction Materials 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 Avionic Systems, Aerospace Marketing Sales and Services, Federal Manufacturing and Technologies, Polymers, Specialty Chemicals, Electronic Materials, Consumer Products Group, Turbocharging Systems, Truck Brake Systems and Friction Materials. More information about AlliedSig nal 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. AlliedSignal's complete Health, Safety and Environment Policy may be found at the AlliedSignal Web Page. The AlliedSignal Green Island Plant is an automotive manufacturing facility that has approximately 165 employees. Several different product lines are made at this facility, which also manufactures phenol formaldehyde resin. This process involves the use of formaldehyde solution, which is on the RMP Rule's list of regulated substances. The AlliedSignal Green Island Plant' stores more than the Rule's specified threshold quantity of 15,000 lbs" and is therefore regulated under the RMP Rule. 1. Accidental Release and Emergency Response Policies I t is the policy of the AlliedSignal Green Island Plant to operate a safe and environmentally sound facility by identifying and controlling health, safety, or environmental risks related to its operations; by designing its processes to protect people, property, and the environment; by conducting and continually reviewing and improving programs for safety, health, and environmental excellence; and by establishing processes to assure that all laws and regulations applicable to its operations and products are known and observed. The accidental release prevention and emergency response policy associated specifically with the plant's use of formaldehyde involves the integration of safety devices and technologies inherent in the design of the process, safe operational plant emergency response plans, and the maintenance of onsite emergency response equipment. Coordinating our efforts and resources with local emergency response services, and communicating with the community are also included in our accidental release prevention and emergency response policies. 2. The stationary source and regulated substance handled The AlliedSignal Green Island Plant uses formaldehyde as a raw material in the manufacture of resin. It is stored and handled in quantities that exceed the threshold quantity specified in the RMP Rule. Formaldehyde is purchased from an outside vendor and is delivered to the Plant via tank truck on an "as needed" basis. The tanker's contents are unloaded by plant operators into an above ground bulk storage tank which is located in an outdoor tank farm. The maximum capacity of the bulk storage tank is 144,000 lbs. Formaldehyde is pumped from the bulk storage tank through an enclosed piping system into the production area where it is fed into the resin kettles. 3. Worse Case and Alternative Release Scenarios EPA's RMP Rule requires the Plant to prepare an analysis of a hypothetical worst case release of the chemicals covered by the RMP regulations. EPA defines a worst case release as the release of the largest quantity of the chemical from a vessel or process line failure. EPA also assumes that the failure takes place over 10 minutes and that all safety systems fail to operate. In addition, the release must take place during the worst possible weather conditions. For a number of reasons discussed in this submittal, it is extremely unlikely that this event would ever occur. In addition, the Green Island site is required to analyze the impact of an alternative accidental release scenario for the chemicals covered by the RMP regulations. The offsite consequence analysis for a "worst-case release scenario" at the Green Island Plant's stationary source was performed for the largest single vessel of formaldehyde solution. This vessel has a maximum capacity of 144,000 lbs. The vessel is a cylindrical steel tank located in an outdoor tank farm adjacent to the facility. The tank sits on a solid concrete base with a concrete wall ed dike designed to contain the full contents of the vessel should a release occur. The tank's actual operational storage content is maintained at an average of 75,000 lbs., which is intentionally below its maximum design capacity. The parameters used for the worst-case release scenario for the formaldehyde source were those defined and pre-set by EPA in the RMP Rule for toxic liquids. In accordance with the RMP Rule, the maximum 144,000-lb. full capacity contents of the vessel were assumed to be released instantaneously to the surrounding dike and allowed to evaporate for one hour. With these assumptions, the model run showed that there would be an offsite impact from this release. The Plant's "alternate-case" scenario is a hose uncoupling from a tank containing 46,000 lbs. of solution. The hypothetical spill of 40,000 lbs. was of a 49 percent formaldehyde solution in water. It was assumed that the 40,000 lbs. of solution was spilled into the dike over a 20 minute period. During the course of this release, a water spray mitigation system would be expected to reduce formaldehyde vapor emissions to the air by 75 percent. The calculated endpoint , with the water spray mitigation, is reduced and there would be a slight offsite impact from this release. However, no residential population would be impacted. 4. General Accident Prevention Program and Chemical Specific Accident Prevention Program AlliedSignal's prevention program for a Program Level 3 RMP facility is comprehensive, consisting of twelve elements. 7 Process Safety Information The Process Safety Information procedure is designed to help those involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. Process Safety Information accumulated at the Green Island facility included information on: 1) the hazards of the highly hazardous chemicals used or produced by our resin process, 2) information on the technology o f the process, and 3) information on the equipment design of the process. 7 Process Hazardous Analyses (PHA) Process Hazards Analyses are part of OSHA's Process Safety Management Directive. A PHAwas completed at our facility and it included an analysis and review of areas used in the transport, storage, or processing of resin. The Hazards and Operability Method was used to perform this Process Hazards Analyses. The information generated from the analyses was formalized into a safety improvement action plan with specific time frames and responsibility assigned for completeness. 7 Operating Procedures The purpose of operating procedures is provide clear instructions for safely conducting activities involved in all of our processes. All of the resin production processes were identified and specific written instructions were addressed for each process including operating phases, operating limits, emergency actions, safety and health considerations, and safety systems. Operating manual s have been prepared for Control Operators, Pump and Compressor Operators, Senior Operators, and Maintenance personnel. 7 Contractors Written procedures are in place to assure that contractors who work in the Green Island plant do so without compromising their safety or the safety of others in the plant. All contractors working in or adjacent to the resin plant production area or tank farm are covered by this procedure. A comprehensive training session is conducted with each contractor prior to work. Re-training is conducted for all involved contractors for each successive job relating to the resin production plant. 7 Pre-Startup Safety Review Pre-Startup safety reviews help to ensure that designs and procedures are complete and thorough prior to bringing a new facility on line or restarting an existing unit after a change or shutdown. A documented checklist is completed at our facility whenever a change in equipment or procedures occurs. This pre-start up review is then communicate d to all involved personnel via the process safety management team. 7 Mechanical Integrity The written procedures that are in place regarding mechanical integrity assure that equipment used to process, store, or handle highly hazardous chemicals is designed, fabricated, installed, and maintained to minimize the risk of releases of these chemicals. This standard applies to all equipment designated as "critical". Critical equipment is defined as pressure vessels, storage tanks, piping systems, pumps, compressors, and relief devices that handle any of the chemicals listed in OSHA 1910.119. In addition, safety-critical equipment such as emergency shutdown systems, emergency generators, control power sources, and designated controls are included in the mechanical integrity program. A thorough mechanical review was conducted on our process piping, vessels, and storage equipment. A weekly preventative maintenance schedule was compiled to assure the ongoing integrity of our process equipme nt. This schedule is reviewed each week and all work is documented upon completion for follow up review. 7 Hot Work Permits All hazards involving hot work operations have been identified and are communicated to personnel whose work could affect the safety of those performing those procedures or of the process in general. A comprehensive "hot work permit" is completed prior to work being performed that involves burning or welding. The requirements included on the permit are reviewed with all involved personnel 7 Management of Change The Management of Change procedure is the process by which any permanent or temporary modifications to process chemicals, technology, equipment, procedures, and facilities are managed to sustain or enhance the level of process safety within the Green Island Plant. This procedure assures that any changes made to the process are identified and communicated. Before any change to the process, equipment, or instructions are made, a "management of change" form is completed and reviewed with operators, supervision, engineering, maintenance, and management. A "consequence to safety" review is a critical part of this procedure. All involved personnel are trained on the requirements and objectives of the procedure. 7 Incident Investigation Proper incident investigation is necessary to continuously improve the safety process. By identifying contributing factors that create variations (incidents) and defining corrective actions, prevention efforts can be properly focused. The boundaries of the incident investigation process include those conditions or practices that cause or have potential to cause injury to personnel or significant damage to equipment, the environment, or the public. An incident investigation procedure is in place at our facility. Involved personnel have been instructed to report any incidents that occur in the resin process. The process safety management team uses an incident investigation process that covers a complete review of the incident including description of incident, results of incident, root cause, and corrective action. All corrective actions are assigned a timetable and responsibility for follow-up. 7 Employee Training An effective training program is an essential element for employees to enhance their safety, the safety of their fellow employees and the community in general. Employees must fully understand the safety and health hazards associated with the chemicals and processes in their work environment. All employees, including maintenance and contract employees involved with highly hazardous chemicals, are trained on the specific safety and health hazards of the process, emergency operations including shutdown, and other safe work practices that apply to the employee's job tasks. All changes to the process, equipment, or procedures, and all incidents involving the process are reviewed in training sessions with all involved personnel. 7 Compliance Audits A complete program audit is conduct ed at least every three (3) years on all the elements of the Risk Management program. All items identified from these audits are addressed in a timely manner to assure the integrity of the process. 7 Employee Participation Employee participation is an important element of the program. All involved employees are tapped for their knowledge of the process and all ideas and concepts are reviewed and accepted as a team effort. This team includes operators, maintenance, engineering, and management personnel. 6. Five Year Accident History No accidental releases involving formaldehyde solution have occurred at the AlliedSignal Green Island Plant during the past five years. 7. Emergency Response Program The AlliedSignal Green Island Plant has an emergency preparedness planning and response program designed to deal with accidental releases and other unplanned events associated with the facility's use of formaldehyde. The plant has a written Emergency Response Plan that addresses various t ypes of contingencies including specific actions for responding to an accidental release of formaldehyde. The plan provides for both internal plant and external community emergency alerting and notification with established means of communication identified. The plan addresses emergency health care, evacuation, emergency responsibilities, response and control procedures, and emergency equipment. The plan has been coordinated with local fire and police departments who would direct all offsite community response activities, along with the County HazMat Team and LEPC. 8. Planned Changes to Improve Safety A Process Hazard Analysis was conducted at our facility in 1997 and a process improvement action plan was created. The facility also has a process safety management team that meets regularly to review the action plan, management of change, and incident investigations. |