Rhodia Inc. - Martinez Plant - Executive Summary |
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Executive Summary 1. Accidental Release Prevention and Emergency Response Policies The Martinez plant is a part of Rhodia Inc. The written corporate Health, Safety, and Environmental policy for Rhodia Inc. is: At Rhodia Inc. we are committed to excellence in our Health, Safety, and Environmental efforts. Nothing is more important to our company than this commitment. Our objective to be the best we can be in this effort is never ending and must be taken into account in every decision made and action taken. We will proactively plan to define needs, determine actions and allocate resources to meet this objective. Rhodia Inc. expects each individual to accept their personal responsibility and role in attaining HSE excellence. Our Shared Values of: * Integrity * Safety * Quality/Customer Focus * Partnership * Innovation will be incorporated into every aspect of the HSE effort. We will include employees, contractors, business partners, communities surrounding our sites, supplier s and customers in our efforts to continuously improve our mutual ability to protect the well-being of people and the environment in which we all live. We will share our HSE knowledge with and learn from others. Being a learning organization is viewed as a key sustainable competitive advantage in improving HSE and our business success. We are committed to the belief that being the best we can be in HSE is an essential element of our business, management and manufacturing processes and, therefore, vitally tied to our long-term viability and growth. Proactive approaches to HSE are essential to building a company we can be proud to work for and one with which our customers wish to do business. The above policy is implemented at the plant level through programs described in detail later in this document and through the following corporate wide programs: * Process Hazard Management Program (PHMP) * Management System Requirements and Recommendations (MSRR) * Maintenance Integrity and Ma intenance Management (MIMM) The Martinez Health, Safety and Environmental Program Manual provides a consolidated version of these programs. Regular audits are conducted as detailed in Section 4 to ensure that these programs are in place and functioning well at the Martinez plant. 2. The Stationary Source and the Regulated Substances Handled The process unit at the plant regenerates sulfuric acid from "spent" sulfuric acid which is received from oil refineries. Oleum is also produced in the process. Current operations at Martinez are performed by 41 full time employees. Operation of all equipment and processes is performed by these full time employees. Contractor personnel are used for some maintenance activities as required by plant operations. Contractor personnel receive training in accordance with their potential contact with hazardous materials or when assigned to work with equipment which could affect the processing or the handling of hazardous materials. Sulfuric acid is th e primary product at the facility. The majority of this sulfuric acid is shipped to refineries and used in the manufacturing process for gasoline. The strength of the acid produced at the Martinez Plant varies from 93% to 105.5% (oleum). These different strengths satisfy a wide variety of applications, including metals mining, processing pulp and paper, agricultural chemicals and pesticides, and water treatment. The chemicals used or stored in the Martinez plant that are covered by the RMP regulation are ammonia (NH3), oleum (H2SO4 supersaturated with SO3) and sulfur dioxide (SO2 dissolved in lubricant spent acid (LSA)). Table 1 identifies the location, quantity, and function of these hazardous materials. Table 1 Material: Ammonia Unit: Ammonia Storage Function: Removal of sulfur dioxide from effluent gas Max Inventory: 198,000 pounds Program Level: 3 Material: Oleum Unit: Oleum Tower/Storage Function: Product Ma x Inventory: 651,000 pounds Program Level: 3 Material: Sulfur Dioxide (disolved in lube spent acid) Unit: LSA Storage Function: Received as raw material Max. Inventory: 319,000 pounds Program Level: 3 3. Offsite Consequence Analysis To evaluate the worst case scenarios, Rhodia used the EPA's OCA Guidance Reference Tables or Equations and the EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations. Wort-Case Scenario The Worst-Case Scenario (WCS) at the Martinez Plant, as defined by the USEPA, is the release of the total contents of a single 40,000 gallon horizontal vessel which is 80% full of anhydrous ammonia (NH3) over a 10 minute period. No credit for mitigation measures was taken into account for this scenario. The effected distance for the WCS was calculated using the look-up tables in the Risk Management Program Guidance for Wastewater Treatment Plants that was officially accepted by the EPA on October 28th, 1998. These look-up tables were used to be consistent with other stationary sources that store anhydrous ammonia. The maximum distance to the given toxic endpoint of 0.14 mg/L or 200 ppm is 5 miles. This toxic endpoint is determined by the EPA and corresponds with the ERPG2 value for ammonia. The definition of ERPG2 is the maximum airborne concentration below which nearly all persons exposed for up to 1 hour will not experience or develop irreversible or other serious health effects or symptoms that could impair their ability to take protective action. Using the census data from LandView III, the estimated population within the worst-case scenario circle is about 34,000. This population includes residences, schools, hospitals, child-care facilities, nursing homes, libraries, churches, parks, business/industrial facilities and correctional facilities. Alternate Release Scenarios An Alternate Release Scenario (ARS) for each toxic substance stored on site was selected from the results of the process hazard assessments that were done for each unit. The scenarios were modeled using PHAST. PHAST is a dispersion modeling program that takes into consideration more details than the look-up tables allow. Ammonia Alternate Release Scenario (ARS) The ARS associated with the release of ammonia at the Martinez Plant is defined as a failure of a hose during the unloading of an ammonia truck. The truck is equipped with an excess flow valve that closes at a flow rate above 283 lb/min. The hose rupture was assumed to be big enough to get the maximum flow out of the excess flow valve, but small enough not to close the valve. This represents the most conservative assumptions. The driver is present at the unloading station during the entire unload process. The truck is equipped with an emergency handle in the back that will close the valve if pulled. This can be done by the driver as soon as a problem is observed. For this scenario it was assumed that it takes the driver 3 minutes to pull the emergency handle. This is once again conservative. The result is a spill of 849 pounds of ammonia in 3 minutes time. The maximum distance to the given toxic endpoint of 0.14 mg/L or 200 ppm is 0.6 miles. This toxic endpoint is determined by the EPA and corresponds with the ERPG2 value for ammonia. The definition of ERPG2 is the maximum airborne concentration below which nearly all persons exposed for up to 1 hour will not experience or develop irreversible or other serious health effects or symptoms that could impair their ability to take protective action. Using the census data from LandView III, the estimated population within a 1 mile radius of the plant is 490. There are no sensitive receptors within this radius. The unloading hoses are property of the ammonia distributor. Before allowing the truck to unload a Rhodia operator completes a safety checklist. This checklist includes checking the date the hoses were last officially inspected and doing a visual inspection on the hoses. Employees are expected to turn away any truck that does not pass the safety checklist for any reason. This has been very successful as a preventative measure. Oleum The ARS associated with the release of oleum at the Martinez Plant is defined as a leak in the circulation loop for the storage tank, which is located outside of the containment building. A failure of the pipe was estimated to result in a pinhole leak 1/8" in length. It was assumed that the leak continues unnoticed for two hours. This is very conservative since a cloud would result making the leak immediately noticeable to operating personnel, who could then shut down the unit remotely from the control room. The total quantity of SO3 released in a two hour period would be about 143 pounds. The maximum distance to the given toxic endpoint of 0.01 mg/L is 0.3 miles. This toxic endpoint is determined by the EPA and corresponds with the ERPG2 value for SO3. The definition of ERPG 2 is the maximum airborne concentration below which nearly all persons exposed for up to 1 hour will not experience or develop irreversible or other serious health effects or symptoms that could impair their ability to take protective action. Using the census data from LandView III, the estimated population within a 1 mile radius of the plant is 490. There are no sensitive receptors within this radius. Routine visual inspections of oleum process piping are performed 7 days per week by our operations personnel. Oleum piping is formally inspected and documented at least every 5 years as part of our maintenance integrity program. Sulfur Dioxide (dissolved in Lubricant Spent Acid) The ARS associated with the release of lubricant spent acid at the Martinez Plant is defined as the over-pressurization of a trailer during the unloading sequence. This failure is said to cause the trailer to be compromised spilling its contents for 15 minutes. A calculated total of 2,946 pounds of lub ricant spent acid would spill containing approximately 133 pounds of dissolved sulfur dioxide. A containment pit in the unloading area prevents the spill from exiting the area. The maximum distance to the given toxic endpoint of 0.0078 mg/L or 3 ppm is 1 mile. This toxic endpoint is determined by the EPA and corresponds with the ERPG2 value for SO2. The definition of ERPG2 is the maximum airborne concentration below which nearly all persons exposed for up to 1 hour will not experience or develop irreversible or other serious health effects or symptoms that could impair their ability to take protective action. Using the census data from LandView III, the estimated population within a 1 mile radius of the plant is 490. There are no sensitive receptors within this radius. In order for this scenario to happen the following safety systems would have to fail: 1. A high pressure interlock that stops the nitrogen flow to the trailer. This interlock would prevent putting any additional p ressure on the trailer. 2. A pressure relief valve located on the trailer that will relieve at 42 pounds per square inch. The relief of this valve would remove the excess pressure from the trailer and not allow it to reach a pressure high enough to rupture. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps The Rhodia Martinez Plant has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68. The following sections briefly describe the elements of the release prevention program that is in place at our facility. Process Safety Information The Rhodia Martinez Plant maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled eff iciently. The methodologies used to carry out these analyses are HAZOPs, Checklists, and Fault Tree Analyses. The studies are undertaken by a team of qualified personnel with expertise in risk analysis, engineering, process operations, and maintenance. All process hazard analyses are revalidated at a regular interval of 5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 10/29/1998. Operating Procedures For the purposes of safely conducting activities within our covered processes, the Rhodia Martinez Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is readily accessible to operators involved in the processes. All operating procedures are reviewed and recertified annually Training T he Rhodia Martinez Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed. Mechanical Integrity The Rhodia Martinez Plant carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks include among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with training in maintenance practices and the potential hazards involved with each unit. Furthermore, specialized training is offered as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. This is tracked through an electronic work order system. Management of Change Written procedures are in place at the Rhodia Martinez Plant to manage changes in process chemicals, technology, equipment and procedures. All changes are reviewed for potential health, safety, or environmental concerns. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of the change and training is provided on the modification. All relative documentation and drawings are updated as part of the action items resulting from the review. Pre-startup Safety Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at the Rhodia Martinez Plant. The most recent review was performed on 02/16/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Pre-startup saf ety reviews are also performed for any process that has been idle for longer than six months. Compliance Audits The Rhodia Martinez Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years. The plant's Process Safety Engineer is responsible to develop an action plan to address all recommendations resulting from audits in a timely manner. Incident Investigation The Rhodia Martinez Plant promptly investigates any incident that has resulted in, or could reasonably result in the release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from recurring. All reports are retained for a minimum of 5 years. Employee Participation The Rhodia Martinez Plant believes that process safety management and accident prevention is a team effort. Company employe es are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Apart from their participation in process hazard analyses, pre-startup safety reviews, and management of change reviews, employees are encouraged to participate on the various health, safety, and environmental improvement teams that are active on site. Contractors Occasionally, our company must hire contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. The Rhodia Martinez Plant has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. Contractors working onsite are expected to work according to all of the safe work practice policies in place for our employees. 5. Five-year Accident History The Martinez Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there have been no accidental releases during this period that meet the definition. 6. Emergency Response Plan The Rhodia Martinez Plant has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In additio n, the plan is updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The removal of propane from the site and the relocation of our ammonia storage are some of the major steps we have recently completed as a result of this program. An evaluation of the identified options to reduce the inventory of anhydrous ammonia on site is expected to be completed by 12/31/2000. |