Kaiser Aluminum & Chemical Corp. - Trentwood Works - Executive Summary |
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Facility Background Kaiser Aluminum & Chemical Corporation's Trentwood flat-rolled products facility in Spokane, Wash., is an aluminum sheet and plate rolling mill. Trentwood annually manufactures over 550 million pounds of aluminum for world-wide markets in the aerospace, ground transportation, general engineering and packaging (beverage can) industries. Trentwood has achieved and maintained numerous quality certifications including: ISO 9002, D1 9000 (Boeing's quality certification), AS 9000(the aerospace industry's quality certification), and QS 9000 (the automotive industry's quality certification). The facility obtains molten aluminum from Kaiser's Mead reduction plant, recovered aluminum from a beverage can recycler, purchased aluminum ingot and sow, and internal scrap aluminum from the Trentwood Works facility. The raw materials and alloys are melted and cast into aluminum rolling ingots. The molten metal is mixed with alloying metals and fluxed with chlorine to remove impu rities to provide the aluminum alloy required by the final customer for the products they produce. The various alloys are processed through various areas which may include, hot and cold rolling, heat treating, coating and other processes which ready the material for distribution to the end customer. Kaiser Trentwood is committed to a zero injuries/illness approach to safety as described in the Kaiser Aluminum Corporation Safety and Health Policy issued by the company's Chairman and Chief Executive Officer. This policy states among other things that, "All accidents, injuries, and occupational illnesses are preventable and the causes leading to them are manageable," and that, "Assurance of a safe and healthy environment is everyone's responsibility." The Corporation has comprehensive written safety, health, and environmental programs and procedures. The facility is staffed with safety, health, and environmental professionals. Introduction The Clean Air Act Amendments of 1990 included provisions that require facilities that use certain substances above a threshold amount to develop a plan to reduce the likelihood of an accidental release of the substances to the atmosphere and reduce the likelihood of serious harm to the public and environment. The plan must also include mitigation measures to reduce the potential impact on the public in the unlikely event of a release. The requirements of the plan, commonly referred to as a Risk Management Plan (RMP), are detailed and codified in 40 Code of Federal Regulations (CFR) Part 68. Kaiser Trentwood is subjected to the RMP requirements because chlorine is stored at the facility in quantities above the regulatory threshold. There are 3 different RMP compliance programs. Because the facility is subject to the Washington State Department of Labor and Industries Process Safety Management (PSM) regualtions (which is equivalent to being subject to the OSHA PSM program), the facility's chlorine distribution system process is s ubject to the most stringent of three RMP programs (Program 3). The RMP consists of three major parts. The first part is the Hazard Assessment. The Hazard Assessment is done to determine the effects that a release of a regulated substance could have on the public. The hazard assessment includes a worst-case (low probability) and alternate release (more probable) scenario, and a 5-year history of accidental releases of chlorine. The second part is a Prevention Program that consists of 12 elements designed to improve the system safety and decrease the likelihood of a release. The third part is the Emergency Response Program, which develops a plan for dealing with a release in the unlikely event that one would occur. Because the regulations are very similar, the Prevention Program and the Emergency Response Program also serves as the OSHA Process Safety Management (PSM) plan, and this document is therefore referred to as the RMP/PSM plan. The RMP regulations require a submittal to the USEPA. This submittal includes an Executive Summary and is referred to as the RMP Submittal. Hazard Assessment for RMP A Chlorine Distribution System Hazard Assessment was performed to determine the effects a release would have on the public. For chlorine, the Hazard Assessment determined the distance a set endpoint concentration of chlorine gas would travel from the source. In addition, an estimate of the population that could be affected by a release of chlorine was determined and sensitive receptors such as hospitals, schools, and nursing homes were identified. The Hazard Assessment considered two release scenarios-a "worst case" (low probability) and an "alternative" (more probable) case. Worst-Case Scenario (Low Probability) The worst-case scenario for the Kaiser Trentwood Works facility was the release of the entire contents of the largest single vessel at the facility containing chlorine. The release of this vessel was assumed to occur in 10 minutes (as required by the RMP regulations). The Dense Gas Dispersion (DEGADIS) model was used to estimate the distance to the toxic end point for chlorine for this scenario. Under this scenario, the release had offsite impact on receptors. The regulations require that the development of a worst-case release scenario be based on conservative assumptions. For example, it is required to assume that the entire contents of the largest single container of chlorine will be released over 10 minutes without any active intervention from facility personnel or systems. This worst-case scenario is unlikely to occur since the physical properties of chlorine are not consistent with the assumptions required by the regulation. In other words, the regulation assumes the facility would do nothing in the event of a release and it does not consider the fact that the physical properties of chlorine are such that it would not allow the release to happen. The largest single vessel at the Trentwood facility containing chlorine is d esigned to prevent releases from the vessel. This vessel has safety relief valves to prevent the vessel from rupturing and from releasing large quantities of its contents in a short period of time. The facility also has ambient chlorine monitors in the area of this vessel. These monitors would detect a chlorine release from the vessel, which would allow the facility's emergency action plan to be activated. Local response agencies would be immediately notified of the release, the agencies would take actions to mitigate the impact of the release, and members of the public potentially impacted by the release would be notified. Alternative Scenario (More Probable) The RMP rule also requires that at least one alternative (more probable) release scenario be evaluated for chlorine. The alternative scenario reflect a type of release that is more likely to occur compared to the worst-case scenario. Unlike the worst-case scenario, the alternative release scenario may consider "active" mitiga tion such as shut-off valves, and a more realistic release quantity and release rate. Active mitigation is defined as requiring mechanical, electrical, or human input. Lastly, it assumes local, typical meteorology, which is more realistic than the conservative meteorological conditions that must be assumed for the worst-case scenario. The alternative release scenario for chlorine that was chosen at Trentwood consisted of a release of chlorine through a broken pipeline, which resulted in offsite impacts. This scenario was chosen as the alternate release scenario because the release would occur in an area that would be more difficult to notice as compared to other areas, and therefore, may take longer to detect the release. The Dense Gas Dispersion (DEGADIS) model was used again to estimate the distance to the toxic end point for chlorine for this scenario. Five-year Accident History There have been ten (10) accidental releases of chlorine in the past five years; the largest release w as a maximum of 100 pounds. No one offsite was injured nor was there any known offsite response activities or property or environmental damage. Prevention Program for RMP/PSM Plans The Prevention Program, together with the Emergency Response Program, makes up the RMP/PSM Plan. The Prevention Program consists of 12 elements designed to improve system safety and decrease the likelihood of a release. These 12 elements are summarized below. Employee Participation Kaiser supports and encourages employee participation in its safety program. Employee participation is valuable because it increases the safety awareness of the employees and it allows the employee's experience in operating and maintaining the processes to be incorporated into the plan. Employees are involved in the facility's hazard control program, incident investigation of near misses, as well as accident investigations, behavior observation safety (which is observation of safety aspects while a job is being performed), sa fety meetings, and employees participating in the Process Hazard Analysis that is described below. Casting Department employees and contractors receive RMP/PSM awareness training that instructs them on how the RMP/PSM requirements may impact their jobs. Those employees who operate and maintain the RMP/PSM (chlorine) process are trained in how to safely maintain and operate these processes. Process Safety Information The RMP regulations require that information concerning process chemicals, technology, and equipment be compiled as part of a RMP program. Emergency response planners can use such information to develop training programs and procedures, or as a general resource. The information is supplied to contractors who work in the chlorine process area as part of the requirements outlined in the Contractors element. Process Hazard Analysis A Process Hazard Analysis (PHA) was conducted systematically to evaluate potential causes and consequences of accidental releases. This informa tion is being used by Kaiser staff to improve safety and reduce the consequences of accidental releases. Equipment, instrumentation, utilities, human actions, and external factors that might affect the process were the focus of the PHA that was performed for the chlorine process. The chlorine PHA was conducted in 1998 by an interdisciplinary team of Kaiser employees familiar with the process operation and maintenance, and plant management. The PHA was done using a combination of Hazards and Operability (HAZOP) and Checklist methods. Based on the results of the PHA, changes in operating and maintenance procedures, and other process safety management practices (i.e., evaluation of changes to process instrumentation, piping, and development of preventative maintenance programs) that would improve the overall safety of Kaiser's Trentwood facility were identified. The changes in operating procedure and training that most affect the severity and likelihood of a release have been adopted by the Trentwood Works facility and incorporated as part of the overall Process Safety Management Program. The other improvements and process modifications to reduce or eliminate potential hazards will be implemented or incorporated into the overall Process Safety Management Program. Operating Procedures Operating procedures for the chlorine distribution system process have been developed as part of the RMP/PSM. Written operating procedures assure continuous, efficient, and safe operation of the facility. The goal of the operating procedures is to provide clear instructions to safely operate the process. Operating procedures are also used to train new employees and to provide refresher training for existing employees. The detailed operating procedures include startup, shutdown and emergency operating procedures. The procedures describe how the system should be operated in order to minimize the chances of an accidental release. The procedures also emphasize safety considerations during operation and address hazardous situations that can occur and how to correct them. Training An effective RMP/PSM training program can significantly reduce the number and severity of accidental release incidences. Employees involved in operating or maintaining the chlorine distribution process must receive training that includes applicable operating and maintenance procedures and an overview of the process. Training must emphasize safety and health hazards, and safe work practices. Kaiser Trentwood's employees have received initial training on the operations and maintenance of the regulated processes, an overview of each of the RMP/PSM plan elements, and the procedures that must be followed to comply with the requirements of the RMP/PSM plan. In addition to RMP/PSM plan training, Trentwood Works' employees have been trained to respond to an accidental release. Refresher process operation training must be provided at least every 3 years. Refresher training for emergency response is c onducted annually. Contractors Kaiser Trentwood's facility must make contractors aware of the known hazards of the chlorine distribution system process related to the contractors' work. In addition, the facility must make contractors aware of the applicable elements of its emergency response plan. Kaiser screens contractors for those who can perform work on or adjacent to the chlorine distribution system process without compromising the safety and health of employees at the facility. Before allowing a contractor to work on or adjacent to the chlorine distribution system process, Kaiser must obtain and evaluate information regarding the contractor's safety performance and programs. When a contract involving work on or adjacent to the chlorine distribution system process is to be bid, the bidding procedures must ensure that contractor safety management requirements are met. If a contractor is to work in or adjacent to any covered processes, a safety briefing, to make the contractor aw are of the Trentwood facility's RMP/PSM plan requirements, must be conducted before work begins. Upon arriving at the plant for the first time to perform work, a Contractors Safety Orientation will be conducted for the contractor. For a contractor to enter the facility, a Notification of Contractor Entry will be completed by a Kaiser representative and submitted to the east gate guard office. Pre-startup Review A pre-startup safety review must be conducted for any new covered process or for significant modifications to the existing chlorine process that necessitate a change in the process safety information. No new or significantly modified process will start up and no acutely hazardous chemicals will be introduced into such a process prior to the pre-startup safety review. The purpose of the pre-startup safety review is to ensure that the facility is ready to operate new and modified regulated processes safely. To initiate the pre-startup safety review, all updated elements of the Process Safety Management Plan are assembled for review. This includes all process safety information, process hazard analysis, operating procedures, employee training and mechanical integrity. A pre-startup safety review team completes a pre-startup checklist. The pre-startup safety review team should complete and sign a Pre-Startup Safety Review Form. This form documents the process, and helps ensure that the review has been properly performed. The Pre-Startup Safety Review Form must be authorized before startup. Mechanical Integrity An effective mechanical integrity program is one of the primary lines of defense against a release. The mechanical integrity program also addresses equipment testing and inspection, preventative maintenance schedules, and personnel training. The intent is to ensure that equipment used to process, store, or handle chlorine is maintained and installed to minimize the risk of releases. Kaiser Trentwood's maintenance employees use a computerized maintenanc e management system to store equipment information, generate and prioritize work orders, schedule preventative maintenance (PM), provide safety procedures for work orders, and maintain an inventory of parts and materials. The computerized maintenance management system is used to generate work orders for preventative maintenance. In addition to preventative maintenance, the Trentwood Works employees performs corrective maintenance in the event of equipment malfunction or breakdown. Work orders indicate what safety precautions must be followed including whether lockout/tagout or confined space entry provisions are applicable. The employees that carryout maintenance are all trained as part of the RMP/PSM. Hot Works Permits RMP/PSM regulations require employees and contractors to employ safe work practices when performing "hot work" in, on, or around the chlorine process. To ensure that hot work is done safely, a Hot Work Permit Program (Welding & Burning Permit Procedure) has been develo ped that requires a permit to be issued before hot work is performed. Hot work is defined as the use of oxyacetylene torches, welding equipment, grinders, cutting, brazing, or similar flame- or spark-producing operations. The process of completing the hot work permit makes it necessary to identify the hazard, recognize what safeguards are appropriate, and then initiate the safeguards necessary to ensure a fire-safe workplace. Following the standards outline in this section aid in complying with the OSHA Hot Works Regulations (1910.252(a)). Management of Change A system for the proper management of changes and modifications to equipment, procedures, chemicals, and processing conditions is required under the RMP/PSM. Modifications to the chlorine distribution system will be reviewed before they are implemented to determine if the modification would compromise system safety. An effective change management system will help minimize the chance for an accidental release. If a modification covered under RMP/PSM is made, its effects must be addressed, employees must be informed, and the written procedures must be updated. The intent is to require that all modifications to equipment, procedures, and processing conditions other than "replacement in kind" be managed by identifying and reviewing them before implementation. Selected personnel from Casting Department, and Safety and Environmental Departments will evaluate any modifications that are covered under the RMP/PSM. The person requesting a change will complete a Management of Change Form that personnel from Casting Department, and Safety and Environmental Departments will review and authorize prior to initiation of a covered change. Incident Investigation Each incident that resulted in or could reasonably have resulted in a catastrophic release of chlorine must be investigated. A process to identify the underlying causes of incidents and to implement procedures for preventing similar events has been developed. To inv estigate an incident, an investigation team will be established. As part of the investigation, an incident report will be prepared and changes recommended as appropriate. The investigation team should ask questions such as what equipment failed, which behavior failed, and which material leaked, reacted, or exploded? As part of the incident review, employees actions that may have contributed to the incident will also be reviewed. A determination will be made as to whether it is necessary to institute additional training for the employees to prevent the incident from occurring in the future. On the incident investigation report form, the Casting Department Manager identifies which of the recommended system changes are approved for implementation. The incident investigation report and any changes resulting from the report will be reviewed with all employees members who operate and maintain the chlorine distribution system. Compliance Audit The Kaiser Trentwood Works facility is require d to complete a compliance audit for the RMP/PSM program. The primary goals of conducting an internal compliance audit are to gather sufficient data to verify compliance with RMP/PSM requirements and good process safety practices, identify process safety deficiencies and develop corrective actions, and increase safety awareness among plant employees. The compliance audit methodology is modeled after OSHA's guidelines for conducting regulatory PSM compliance audits: Compliance Guidelines and Enforcement Procedures, OSHA Instruction CPL 2-2.45A (September 13, 1994). An internal compliance audit must be conducted at the plant at least once every 3 years for the chlorine distribution system process. A team that includes at least one person knowledgeable in the covered processes and an audit leader (Safety Manager) knowledgeable in RMP/PSM requirements and audit techniques will conduct the audits. The Casting Department Manager and the audit team will promptly determine an appropriate corr ective action for each deficiency identified during the audit and document the corrective actions and the dates by which they must be taken. Emergency Response Program for RMP/PSM Plans The Emergency Response Program details a plan for dealing with a release. OSHA Process Safety Management regulation 29 CFR 1910.119(n) and EPA RMP regulation 40 CFR 68 Subpart E require that an Accidental Release Emergency Response Plan be prepared. The plan must be prepared in accordance with the provisions of another overlapping OSHA regulation-Employee Emergency Plans (29 CFR 1910.38(a)). In addition, provisions of the OSHA hazardous waste and emergency response standard, 29 CFR 1910.120 (q) must also be considered. The Emergency Planning and Response Plan described in this section complies with the requirements of 40 CFR 68.90 and 29 CFR 1910.38(a). The facility is a non-responding facility in accordance to definitions for responding and non-responding facilities as defined in the RMP/PSM regulat ions. The Kaiser Trentwood Emergency Procedure for a Chlorine Leak (Chlorine Distribution System) provides specific emergency response procedures for accidental releases of chlorine. The emergency response procedures cover a release from the initial discovery through evacuation. The facility's emergency response activities has been coordinated with the Spokane Valley Fire Department. |