Niklor Chemical Company, Inc. - Executive Summary |
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Executive Summary Chlorine is used extensively in various products manufacturing processes. The Niklor Chemical Company (Niklor) Carson Facility also uses chlorine as part of its product manufacturing process. Storing and handling large quantities of chlorine can create hazardous situations. The Niklor facility takes all possible safety measures to prevent the accidental release of chlorine as well as mitigating the impacts of any chlorine release to the atmosphere. Niklor facility has an excellent safety record with chlorine. The Niklor facility chlorine handling process is subject to the U.S. Environmental Protection Agency (EPA) Risk Management Program Rule and also to the California Accidental Release Prevention (CalARP) Program regulation. Both of these regulations require submission of a Risk Management Plan (RMP). An integral part of the RMP is a summary of policies and procedures followed to safely operate the facility, including a description of the possible consequence s in case of an accident and the actions which will be taken by the facility in an event of an emergency. The following information is specifically required in the RMP Executive Summary: 7 Accidental release prevention and emergency response policies. 7 General facility and regulated substances information. 7 Offsite consequence analysis results. 7 Summary of the accidental release prevention program and chemical-specific prevention steps. 7 Five-year accident history summary. 7 Emergency response program summary. 7 Planned changes to improve safety. The above information for the Niklor facility Chlorination System is provided below. Accidental Release Prevention and Emergency Response Policies The Niklor facility accidental release prevention policy involves a unified approach that integrates proven technology, trains staff in operation and maintenance practices, and uses tested and proven management practices. All applicable procedures of the State of California and EPA's Preven tion Program are adhered to, including key elements such as training, systems management, and emergency response procedures. The Niklor facility emergency response policy involves the preparation of an emergency response plan which is tailored to the facility and to the emergency response services available in the community; and is in compliance with the EPA and CalARP Program Emergency Response Program Requirements. Niklor has prepared an Emergency Response Plan for handling chlorine to facilitate coordination and emergency planning with offsite response officials and facilities in the event of an emergency. The emergency response plan has been coordinated with local response agencies (Los Angeles County Fire Department). Niklor facility has an excellent record in preventing accidents from occurring. General Facility and Regulated Substance Information The Niklor facility is located at 2060 East 220th Street in Carson, California. The Facility is situated north of Interstate High way 405, and approximately 2 miles west of Interstate Highway 710, between Wilmington Avenue and Alameda Street. The facility covers an area of approximately 1.5 acres. The facility currently stores and uses anhydrous chlorine, a regulated toxic substance under the EPA and CalARP Program rules. The Niklor facility has two basic product lines, both of which utilize chloropicrin manufactured form the chlorine. The first line produces Chloropicrin (PIC) for shipment to distributors, while the second product line produces PIC/methyl bromide mixtures for use as a soil and structural fumigant. Anhydrous chlorine used as part of the process is received at the Facility in 90-ton rail tank cars. One chlorine rail car is unloaded at a time at only one location at the Facility. The maximum quantity of chlorine present at Niklor facility at any given time exceeds the listed threshold quantities in the EPA and CalARP rules. It also exceeds the listed threshold quantities in the federal and Ca lifornia Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standards. The chlorine unloading area is continuously monitored in the control room by a chlorine leak detector. A chlorine leak sensor is also provided in the chlorine processing area. In case of a major chlorine leak, the chlorine rail car can be isolated by the emergency shutoff valve located on the piping downstream of the rail car manway. There are emergency shutdown switches located near the rail car, in the chlorine processing area and in the main office control room. The alarms are annunciated at the main office as well as throughout the facility. Once alerted, fully trained personnel will respond to terminate the chlorine leak. Emergency showers and eye wash stations are also provided in the chlorine unloading area, in the chlorine process area and in the adjacent PIC manufacturing building. Access to the facility is restricted by a gated chain link fence that is six feet and /or 12 feet in height. An alarm system is used to protect the office. At night the area is locked and the buildings are lighted externally. A patrol service checks on the facility during nighttime hours. When railcar shipments are made at night an operator remains at the plant until the shipment is complete. Offsite Consequence Analysis Results The offsite consequence analysis includes consideration of two chlorine release scenarios, identified as "worst-case release scenario" and "alternative release scenario". The first scenario is defined by EPA, which states that "the owner or operator shall assume that the ... maximum quantity in the largest vessel ... is released as a gas over 10-minutes," due to an unspecified failure. The alternative scenario is defined as "more likely to occur than the worst-case release scenario". The released liquid chlorine is assumed to form a denser-than-air cloud consisting of chlorine vapor and liquid droplets (aerosols) and then disperse in the atmosphere. The distance to the toxic endpoint was estimated using the EPA's RMP*Comp software (version 1.06). The toxic endpoint selected by EPA and CalARP rules for chlorine is 3 ppm, which is the Emergency Response Planning Guideline Level 2 (ERPG-2). The toxic endpoint was conservatively set by EPA to ensure public notification and that local emergency response planning takes into account the greatest possible impacted area surrounding the release point. EPA-mandated meteorological conditions, namely atmospheric Stability Class F, wind speed of 1.5 meter per second, highest daily maximum temperature (77 deg F), and average relative humidity (50%) were used for the worst-case release scenario analysis. The results of the dispersion analysis indicated that the worst-case release scenario has offsite impacts. RMP and CalARP rules require that a scenario which results in offsite toxic endpoint distance and is more likely to occur than the worst-case scenario should be selected as the alternative release scenario, unless no such scenario exists. Unlike the worst-case scenario, the alternative release scenario may consider "active" mitigation such as automatic shutoff valves, excess flow valves, and containment with scrubbers. Active mitigation is defined as requiring mechanical, electrical, or human input. The alternative release scenario selected involves the release of chlorine from the monel flexible hose connecting the railcar to the chlorine process. This scenario can occur if the operator uses a flex hose, which is worn or has a defect and results in a crack in the flex hose during the withdrawal of chlorine from the railcar. It is assumed that the crack developed in the flex hose (diameter 1-inch) corresponds to a hole of 0.1875-inch (3/16 inch) diameter. The control room would have been warned of the chlorine leak by the chlorine monitors installed at the Niklor facility. Once the chlorine monitors detect a chlorine leak, the automatic shutoff valv e, installed on the railcar angle valve side of the monel flex hose, will close stopping the chlorine flow. Therefore, the amount of chlorine released will be restricted to the amount of chlorine in the pipe. It may be noted that the occurrence of this scenario is highly unlikely because the flex hose is carefully inspected during each connection/disconnection operation, and during operator rounds, once each shift. The alternative release scenario toxic endpoint distance was also estimated using the RMP*Comp (version 1.06) software. Toxic endpoint for chlorine is 3 ppm. EPA suggested typical meteorological conditions used were Stability D, wind speed of 3.0 meter per second, average air temperature of 77 deg F, and average relative humidity of 50 percent. The results of the dispersion analysis indicated that the alternative release scenario has offsite impacts. Finally, no chlorine releases that could have caused safety or health hazard (no deaths, injuries, property or environm ental damage, evacuations, or sheltering in place) occurred at the Niklor facility during the last five years. Summary of the Accidental Release Prevention Program and Chemical-Specific Prevention Steps Niklor facility is in compliance with Federal and State Process Safety Management requirements. Niklor facility accidental release prevention program is based on the following key elements: 7 Detailed management system and clear levels of responsibilities and team member roles. 7 Comprehensive process safety information that is readily available to staff, emergency responders, and contractors. 7 Comprehensive preventive maintenance program. 7 Performance of process hazard analysis of equipment and procedures with operation and maintenance staff participation and review. 7 Use of state-of-the-art process and safety equipment. 7 Use of accurate and effective operating procedures, written with the participation of the operators. 7 High level of training of the operators and maintenanc e staff. 7 Implementation of an incident investigation, inspection, and auditing program using qualified staff. Chemical-specific prevention steps include availability of self-contained breathing apparatus (SCBA), respirators worn by the operators during connection/disconnection of chlorine supply, awareness of the hazardous and toxic properties of chlorine, presence of chlorine detectors and alarms, and a remotely controlled shutoff device on the chlorine railcar line. Process and Chemical Safety Information Comprehensive chemical data have been assembled to include regulatory reporting and action thresholds, health hazard, and chemical exposure limitations, as well as detailed physical properties of chlorine. This information includes chlorine background information and MSDS sheets. Equipment safety information was meticulously compiled on the chlorine process. Specifications for chlorine process are collected and provided in one place for easy reference. Details such as maximum intended inventory; safe upper and lower temperatures; safe upper and lower pressures; and applicable codes and standards are on file at the facility. Niklor facility also has procedures in place that is triggered to update process safety information if there is a major change that makes existing information inaccurate. Process Hazard Analysis In 1991 and 1999, detailed process hazard analysis (PHA) were conducted for the chlorine system equipment and procedures. The PHAs were further reviewed in January 1999 and will be updated again within a five-year period or whenever there is major change in the process. A list of recommended actions were developed in January 1999 to further improve the chlorine safety and staff is currently evaluating these recommendations. Staff will document the completion of recommended actions. A seismic walkthrough was recently completed based on the 1997 UBC. No recommendations were made based on the seismic walkthrough of the facility. Operating Procedures Niklor maintains up-to-date, accurate, written operating procedures that provide clear instructions for the chlorine process. The Niklor ensures effective operating practices by combining them with operating and maintenance training programs. Standard operating procedures (SOPs) provide system descriptions, specifications, equipment inspection requirements, and operating procedures for the chlorine system. The operating procedures include railcar inspection, connection/disconnection from railcar, routine and non-routine tasks and related safety procedures, and bleach preparation (used in the manufacture of chloropicrin). Also included are the maintenance procedures and schedules, including consequences of deviation and the steps to correct or avoid deviations. All procedures are reviewed at least every three years, or whenever a change occurs that alters the steps needed to operate safely. Operating procedures will be developed and put in place prior to any new process equipment coming on line or changes made in the handling of chlorine equipment, and reconfiguration of the facilities. Training Niklor employees presently involved in operating or maintaining the chlorine system are trained in an overview of the process and detailed applicable operating and maintenance procedures. Niklor ensures that each employee newly assigned to the process, is trained and tested to be competent in the operating procedures listed pertaining to their duties. Niklor training program includes four elements: (1) initial training and awareness training, (2) refresher training, (3) documentation, and (4) and testing. Each employee (presently involved in operating the chlorine process) has been trained to receive the required knowledge, skills, and abilities to safely carry out the duties and responsibilities, including chlorine emergency response, as provided in the operating procedures. Refresher training is provided annually or less to each employee operating the covered process to ensure that the employee understands and adheres to the current operating procedures. In addition, Niklor ensures that operators are trained in any updated or new procedures prior to startup of a process after a major change as indicated in their Management of Change procedures. Niklor prepares and retains records of initial and refresher training, provides certification of the records, which includes the identity of the employee, the date of training, and the signature of the person (s) administering the training. Contractors Niklor has procedures and policies in place that ensure that only contractors with good safety programs are selected to perform work on and around the chlorine process and that the contractors are properly informed of the hazards, access limitations to these process areas, and emergency response procedures, and prepared to safely complete the work. The contractors are informed, prior to the initiation of the work at the site, of the app licable provisions of the emergency response plan. Niklor holds contractor safety briefings before allowing them near or in the process area; controls access to the process areas, and evaluates the contractor's performance. Pre-Startup Safety Review and Mechanical Integrity Program Niklor ensures that a pre-startup safety review is completed for any new covered-by-the-rules process, or for significant modifications to an existing covered process that requires a change in the process safety information. Niklor maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment. Niklor mechanical integrity program includes the following: 7 Written procedures for maintaining mechanical integrity through inspection and testing of process equipment, based on instructions of equipment vendors, industry codes, and prior operating experience. 7 Implementation of the written procedures by performing inspecti ons and tests on process equipment at specified intervals. 7 Training of maintenance personnel in preventive maintenance program procedures; safe work practices such as lockout/tagout, line or equipment opening, and avoidance and correction of unsafe conditions; and safe use and application of special equipment and/or unique tools. Hot Work Permits and Management of Change Niklor requires employees and contractors to employ safe work practices when performing "hot work" in, on, or around the covered process. Niklor uses a permitting and training program to ensure hot work is conducted safely on or near a process involving chlorine. Niklor provides a system and approach to maintain and implement any management of change or modifications to equipment, procedures, chemicals, and processing conditions. This system allows Niklor staff to identify and review safety hazards or provide additional safety, process, or chemical information to existing data before the proposed change would eit her compromise system safety or need training to be completed. Internal Compliance Audits Internal compliance audits will be conducted every 3 years to verify compliance with the programs and procedures contained in the RMP. The Niklor will assemble an audit team that will include personnel knowledgeable in the Risk Management Program rule and in the process. This team will evaluate whether the prevention program satisfies the requirements of the Risk Management Program rule and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit will be documented, recommendations resolved, and appropriate enhancements to the prevention program will be implemented. Incident Investigation Niklor investigates all incidents that could reasonably have resulted in a catastrophic release (serious injury to personnel, the public, or the environment) so that similar accidents can be prevented. An investigation team is assembled and the in vestigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. Information found during the investigation is reviewed by affected staff and added or used to revise operating and maintenance procedures. Five-year Accident History Summary No chlorine releases that could have caused safety or health hazard (deaths, injuries, property or environmental damage, evacuations, or sheltering in place) occurred at the Niklor facility during the last five years. Emergency Response Program Summary All Niklor plant operators are trained as First Responders and Hazardous Materials Technicians to properly respond and mitigate any chlorine accidental releases. Niklor also has employees trained as hazardous material Incident Commanders at the Facility. Depending on the severity of the accidental release, external resources such as the Los Angeles County Fire Department m ay be solicited to aid in handling a chlorine release. As part of the emergency response program, the Niklor has developed and implemented an emergency response plan for the purpose of protecting public health and the environment. The emergency response plan has been coordinated with local response agencies (Los Angeles County Fire Department). The main elements of the emergency response plan are: (1) chlorine response flow chart, responsibilities of various personnel at the facility, duties of on-scene incident commander, (2) details of emergency recognition and prevention at the facility, and (3) procedures for planning and coordination with off-site emergency response organizations. Planned Changes to Improve Safety Numerous changes to improve safety (recommended actions) were previously identified for the chlorine system in 1991 and 1997 for equipment and procedures, when California Risk Management and Prevention Program (RMPP) and Process Safety Management (PSM) Programs wer e prepared for the facility. All of these recommendations have been evaluated and implemented as required. Additional three changes to improve chlorine safety were identified in January 1999, when the process hazard analysis review was performed. It is expected that these recommended actions will be evaluated by December 1999. The implementation of these recommendations will further improve the safety of the chlorine system. |