USEPA Chemical Accident Prevention Risk Management, Process Safety, and Emergency Response

Transcription

1 USEPA Chemical Accident Prevention Risk Management, Process Safety, and Emergency Response

2 Overview Backgrond Region 9 Risk Management Program General Dty Clase Common Deficiencies Noted EPA National Compliance Initiative What s the latest news? Qestions?

3 Framework - EPA EPA Risk Management Plan (RMP)/General Dty Clase Emergency Planning and Commnity Rightto-know (EPCRA) reqirements Local emergency planning and preparedness, emergency release notification, commnity right-to-know: provision of hazardos chemical storage inventory and toxic chemical release inventory to the commnity and first responders State Emergency Response Commissions (SERCs) Local Emergency Planning Committees (LEPCs)

4 WHY

5 Why Chemical Safety Now? West Fertilizer Company West, Texas April 17, fatalities and 260+ injries $230 million in insrance-related losses $16 million spent on Federal disaster assistance $1 million insrance policy held by West Fertilizer Company Chevron Refinery Richmond, California Ag 6, ,000 people soght medical treatment $2 million in fines and restittion $447 million in increased gas prices passed onto consmers Deepwater Horizon Glf of Mexico April 20, workers killed, 17 workers injred $21 billion in settlements 4 million barrels of oil spilled

6 RMP Ammonia Refrigeration Incidents CUPA Conf. Thrs 9 Feb

7 RMP Ammonia Refrigeration Release Sorces ( ) CUPA Conf. Thrs 9 Feb

8 RMP Ammonia Refrigeration Reasons for Release ( ) 1,253 Total Releases CUPA Conf. Thrs 9 Feb

9 EPA Risk Management Program Smmary of Region 9 Risk Management Program General Dty Clase Common Deficiencies Noted Dring Inspections EPA National Compliance Initiative

10 Section 112(r)(7) of the Clean Air Act Hazard assessment that details the potential effects of an accidental release, an accident history of the last five years, and an evalation of worst-case and alternative accidental releases scenarios; Prevention program that incldes safety precations and maintenance, monitoring, and employee training measres; and Emergency response program that spells ot emergency health care, employee training measres and procedres for informing the pblic and response agencies (e.g., the fire department) shold an accident occr. Higher Program Levels = More Reqirements

11 Region 9 RMP Facilities by State US EPA Region Hawaii 16 Gam 4

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15 Section 112(r)(1) of the Clean Air Act Owners and operators of facilities tilizing hazardos sbstances have a General Dty to: Identify hazards that may reslt from accidental releases sing appropriate hazard assessment techniqes, Design and maintain a safe facility taking any necessary steps to prevent releases, and Minimize the conseqences of accidental releases that do occr. Note - Not limited to specific list of chemicals or threshold qantities

16 HOW DO I MEET MY GDC OBLIGATIONS? The General Dty Clase reqires yo to identify hazards yor facility may present from accidental releases of hazardos sbstances, design and maintain a safe facility, and minimize the conseqences of accidental releases which do occr. Generally, among other things, yo shold: (1) Adopt or follow any relevant indstry codes, practices or consenss standards (for the process or facility as a whole as well as for particlar chemicals or pieces of eqipment), (2) Be aware of niqe circmstances of yor facility which may reqire a tailored accident prevention program, and (3) Be aware of accidents and other incidents in yor indstry that indicate potential hazards.

17 Examples A facility installed a water-based fire sppression system in storage areas that contained water-reactive chemicals. This created a clearly hazardos condition. The General Dty Clase reqired the facility to install a fire sppression system that was compatible with water reactive chemicals. Preventing and mitigating accidental releases related to known eqipment failre scenarios is a GDC obligation.

18 SOME POINTERS REGARRDING GDC OBLIGATIONS The GDC applies to many chemicals; it is not limited to the chemicals sbject to the RMP reglations. The GDC applies facility-wide, regardless of the amont of chemical stored. In analyzing the standard of care, EPA conslts indstry standards, codes and practices,

19 USEPA Region 9 RMP Inspections Typically annally >3% of 1071 Regional Total RMP Targeting Focs on High Risk facilities Approx. 150 in Region 9 > 35% of total inspections (~11) Releases and other RMP Reportable Accidents Inspect within 6 months CUPA, other referrals

20 USEPA Region 9 Inspections 1 day on-site for most (refineries longer) Notice typically given (~ 1 week) Team Approach CUPAs/PAs always invited Entry with CUPA (preferrably) Opening meeting with facility Meet with employee representative(s) Facility Process Walk-thr Interview & Doc Review Close-ot meeting

21 Commonly Observed RMP Deficiencies Failre to report accidents w/in 6 Months (especially those involving <RQ amonts) Failre to change ER POC w/in 6 Months Failre to resolve, docment, and track PHA, Adit, and Accident Investigation Findings Failre to develop SOPs for all operations, especially temporary operations Failre to certify SOPs annally Failre to inclde operating limits and conseqences of deviation in SOPs Incomplete PSI information Failre to ensre everyone gets refresher training MOC not completed PRIOR to change PSI, SOPs not pdated accordingly w/ MOC modifications

22 Commonly Observed RMP Deficiencies Failre to docment each individals training and how it was verified that employees nderstood the training Failre to develop and implement written maintenance procedres Failre to test/inspect at the freqency defined by indstry standards/ mfg. instrctions Deficient Annal Inspections and/or 5-year MI adits MI deficiencies PRVs Corrosion Inadeqate ventilation / relief system design basis Inadeqate component labeling Deficient SOPs

23 USEPA Enforcement Options Notice of Inspection Findings Finding of Violation Administrative Order (Unilateral or on Consent) Administrative Penalties Civil Jdicial Referral Criminal

24 EPA CAA 112(r) National Initiative 5 Sectors Goal Ammonia Refrigeration Fertilizer Distribtion Refineries Chemical Manfactring Gas Processing Improve corporate & sector-wide safety/compliance

25 Identifying Hazards Facility has completed a process hazard analysis or review. Hazard Addressed: Releases or safety deficiencies that stem from a failre to identify hazards in design/operation of system. Additional Elements For systems that employ hot gas defrost, the process hazard analysis/review incldes an analysis of, and identifies, the engineering and administrative controls for the hazards associated with the potential of vapor propelled liqid slgs and condensation-indced hydralic shock events.

26 Operating Activities: System has self-closing/qick closing valves on oil pots. Facility has written procedres for maintenance and operation activities. Only athorized persons have access to machinery room and the ability to alter safety settings on eqipment. Hazard Addressed: High risk of release from operating or maintenance activity Additional Elements Written procedres are in place for proper se and care of personal protective eqipment. If respirators are sed, facilities know the location of their respirators, and they are inspected and maintained per manfactrer or indstry standards. All changes to atomation systems (programmable logic controls and/or spervisory control and data acqisition systems) if present, are sbject to management of change procedres.

27 Maintenance/Mechanical Integrity: A preventative maintenance program is in place to, among other things, detect and control corrosion, deteriorated vapor barriers, ice bildp, and pipe hammering, and to inspect integrity of eqipment/pipe spports. All piping system openings except the relief header are plgged or capped, or valve is locked. Eqipment, piping, and emergency shtdown valves are labeled for easy identification, and pressre vessels have legible, accessible nameplates. All atmospheric pressre relief valves have been replaced in the last five years with visible confirmation of accessible pressre relief valves [note replacement every five years is the general rle bt there are two other options in IIAR Blletin 110, 6.6.3]. Hazard Addressed: Leaks/releases from maintenance neglect

28 Machinery Room and System Design The System(s) has/have emergency sht-off and ventilation switches otside each machinery room. The machinery room(s) has/have fnctional, tested, ventilation. Air inlets are positioned to avoid recirclation of exhast air and ensre sfficient inlet air to replace exhasted air. Docmentation exists to show that pressre relief valves that have a common discharge header have adeqately sized piping to prevent excessive backpressre on relief valves, or if bilt prior to 2000, have adeqate diameter based on the sm of the relief valve cross sectional areas. Hazard Addressed: Inability to isolate and properly vent releases

29 Contact Information EPA Region 9 Kathryn Lawrence Chief, Emergency Prevention and Preparedness Lawrence.kathryn@epa.gov