Process Safety Management of Highly Hazardous & Explosive Chemicals. EPA Clean Air Act - CAA 112 (r) Risk Management Plans

Transcription

1 Process Safety Management of Highly Hazardous & Explosive Chemicals EPA Clean Air Act - CAA 112 (r) Risk Management Plans

2 Risk Management Plans Risk Management Plans Many Times Companies Who Must Comply with PSM, must also Comply with the Requirements of EPA Risk Management Plans (RMP) The RMP Standard was to be a Mirror of the PSM Standard Didn t happen! Remember PSM Protects the Workforce, RMP Protects the Community

3 Could RMP Be Required Here?

4 Risk Management Plan Mandated by CAAA, Section 112 (r), 40 CFR Part 68 Promulgated - May 24, 1996 Published Federal Register - June 20, 1996 More than 100,000 facilities affected Designed to help reduce risk of accidental release of hazardous substances 3 years to implement

5 Risk Management Plan (continued) Affects owners of a stationary source with regulated substances above a threshold quantity (TQ): 77 acutely toxic 63 flammable Department of Transportation (DOT) classified explosive substances Focuses on lethal effects resulting from acute exposures Includes mandated substances Not the Same as PSM

6 Mandated Substances Ammonia Anhydrous Ammonia Anhydrous Hydrogen Chloride Anhydrous Sulfur Dioxide Bromine Chlorine Ethylene Oxide Hydrogen Cyanide Hydrogen Fluoride Hydrogen Sulfide Methyl Chloride Methyl Isocyanate Phosgene Sulfur Trioxide Toluene Diisocyanate Vinyl Chloride

7 Toxic & Flammable Substances How Did EPA Select Toxic & Flammable Substances Extremely hazardous substances under SARA Gases and highly volatile liquids Vapor pressure > 10 mmhg Thresholds ranging from 500-2,000 lbs. Thresholds based on toxicity and volatility NFPA 4 - Most dangerous Flammable gases and volatile flammable liquids that could create vapor cloud explosions Thresholds set at 10,000 lbs.

8 Threshold Quantity Determination Total quantity of a regulated substances contained in a process at any one time Process included interconnected vessels or separate vessels that could be involved in a release (OSHA PSM definition)

9 EPA Risk Management Plans (RMP) Basics CAA 112(r)

10 Requirements of 112 (r) Established a general duty clause to: Identify hazards that may result from releases Design and maintain a safe facility Minimize the consequences or releases

11 Requirements of 112 (r) Management system for RMP Required Offsite consequence analysis must be performed including: Worst-case scenario Alternative release scenario Must Include 5-year accident history

12 Requirements of 112 (r) Prevention program must be developed including: 7-elements mini-psm program 14 elements OSHA-PSM program expanded to address offsite effects Emergency response program is required Risk management plan Submission: Electronic submission to Federal EPA Available to public (in the public record) Regulatory audits must be performed

13 Requirements of 112 (r) Requirements of 112 (r) Basic Requirements Executive summary Registration Off-site consequence analysis Five-year accident history Emergency response plan Prevention program summary information Certification Submission Sound Much Easier than PSM Right?

14 Requirements of 112 (r) A summary (RMP) is Provided to: EPA Indirectly to: States Locals Public

15 Manufacturing Industries Affected Chemical manufacturers Industrial Organics & Inorganics Paints Pharmaceuticals Adhesives Sealants Fibers

16 Manufacturing Industries Petrochemical Products Refineries Industrial Gases Plastics and Resins Synthetic Rubber Affected

17 Non-Manufacturing Affected Non-Manufacturing Facilities affected Utilities Electric and Gas (Anhydrous Ammonia) Public Sources Drinking Water and Waste Water Treatment (Chlorine) Agriculture Fertilizers, Pesticides (Anhydrous Ammonia)

18 Other Manufacturing Electronics Semiconductors Paper Fabricated metals Industrial machinery Furniture Textiles

19 Other Industries Food and Cold Storage Propane Retail Warehousing Wholesalers Federal sources Military and Energy Installations

20 Hazard Assessment Offsite consequence data Population estimate in the release plume Public receptors in the release plume Environmental receptors in the release plume Performed at least every 5 years Performed Within 6 months of a change that increases or decreased distance by a factor of 2 or more

21 Overview Worst-Case Scenario Greatest release quantity from vessel or piping May include administrative controls Toxic gases Quantity released in 10 minutes Toxic liquids Instantaneous spill to ground; volatilization; passive mitigation Toxic gases liquefied by refrigeration

22 Worst-Case Scenario (continued) All flammable substances Quantity for vapor cloud explosion One worst case for each process One worse case representing all toxic substances

23 Alternative Release Scenario (ARS) Next likely release scenario Much reach endpoint offsite One scenario representative of all flammables is required

24 ARS Selection Past Accident history events Process hazard analysis events in PHA s Worse case with mitigation Example scenarios: Piping or hose failures Seal failures Vessel overfilling or venting

25 Offsite Consequence Analysis Toxic endpoint must be identified Flammable endpoints must be identified Use appropriate models or guidance Within circle, identify Public receptors and population Environmental receptors Hospitals, Nursing Homes, Schools, Governmental Agencies Receptor - Persons that could be affected by a release

26 All Public Facilities in this Release Plume Must be Identified & Surveyed Release Plume

27 Registration and Submittal Submit a comprehensive RMP to: EPA Indirectly or Referred to: State Emergency Response Commission (SERC) Local Emergency Planning Committee (LEPC) The Chemical Safety and Hazard Investigation Board With the New Administration - The Process Has Changed

28 Registration and Submittal (Continued) Name, mailing address, telephone of stationary source CAS number of all regulated substances greater than TQ SIC code Dun and Bradstreet number Certification signed by owner or operator

29 Auditing the Program Just Like PSM, You Must Audit the Program (at least every 3 years) Conduct audits of the management system

30 RMP Example RMP Example An Actual Example of a Submitted RMP

31 Basic Facility Info Facility ID Facility Name Dixie Cold Storage Street Address Line W. Bert City New Orleans State LA Zip Code County Cadme Parish Owner or Operator Name Alan Smith Parent Company Pride Corporation Latitude Longitude Number of RMP Submissions 4

32 Most Recent Submission Info RMP ID Submission Type correction for prior submission Submission Date 12/19/2006 Reason For Submission New accident history information Deregistration Date 12/29/2006 Deregistration Effective Date 12/28/2006 Deregistration Reason Other Deregistration Reason (Other) Sold facility Process Toxic Amount Total (lbs) 13,200 Process Flammable Amount Total (lbs) 0 Process Amount Total (lbs) 13,200 Number of Potential Offsite Consequence Processes 1 Potential Offsite Consequence Toxic Amount Total (lbs) 13,200 Potential Offsite Consequence Flammable Amount Total (lbs) 0 Potential Offsite Consequence Amount Total (lbs) 13,200 All Process NAICS Exec Summary Submission Date 12/19/2006

33 Executive Summary This Risk Management Plan (RMP) covers the Pride Storage Plant in New Orleans, LA. The reason for submitting this RMP is to comply with the mandatory five years update and to report the change of ownership from ACME Foods to Pride Corporation. This facility has two refrigeration systems using anhydrous ammonia as the refrigerant. The amount of anhydrous ammonia contained in only one of the systems is above the EPA threshold reporting quantity of 10,000 pounds. Because anhydrous ammonia is listed by both the US Occupational Safety and Health Administration (OSHA) and the US Environmental Protection Agency (EPA) as a hazardous chemical, our accidental release prevention program is designed to comply with the Process Safety Management (PSM) and Risk Management Program (RMP) regulations of these two agencies. These regulations are designed to prevent the accidental release of ammonia and to minimize the negative consequences should a release occur

34 Submission - Other Facility Info Owner or Operator Name Alan Smith Owner or Operator Address Line W. Bert Owner or Operator City Shreveport Owner or Operator State LA Owner or Operator Zip Parent Dun and Bradstreet Number Second Parent Dun and Bradstreet Number 0 Number of Full Time Employees 44 Number of FTE CBI Flag No Covered by OSHA PSM Standard Yes Covered by EPCRA Section 302 Yes Covered by CAA Title V No Last Safety Inspection Date 02/16/2005 Last Safety Inspection By State environmental agency OSHA Star or Merit Ranking No LEPC Name New Orleans / Cadme LEPC

35 Submission - Contact Info Owner or Operator Phone Facility URL Facility Phone Facility Dun and Bradstreet Number RMP Contact Linda Darnell RMP Contact Title Corporate PSM Director RMP Contact Linda.Darnell@pride.com Submission - Additional Info RMP Complete Flag Yes Predictive Filing No No RMP Accidents Last 5 Years No Complete Check Date 12/20/2006 Postmark Date 12/13/2006 Anniversary Date 06/21/2009 Confidential Business Information N

36 Submission - Lat/Long Info Latitude Longitude Valid Lat/Long Yes Lat/Long Method GPS - Unspecified Lat/Long Location Type Storage Tank FRS Latitude FRS Longitude Submission - Counts and Totals Number of RMP Accidents 1 Number of Processes 1 Number of Process Chemicals 1 Number of Toxic Worst-case Scenarios 1 Number of Toxic Alternate Case Scenarios 1 Number of Flammable Worst-case Scenarios 0 Number of Flammable Alternate Case Scenarios 0 RMP Accident Flammable Total (lbs) 0 RMP Accident Toxic Total (lbs) 2,530 RMP Accident Amount Total (lbs) 2,530 Total RMP Accident Deaths 0 Total RMP Accident Injuries 0 Total RMP Accident Evacuated/Sheltering In Place 0 Total RMP Accident Property Damage $

37 Processes Process Description Ammonia Refrigeration Program Level 3 Confidential Business Information No Toxic Amount Total (lbs) 13,200 Flammable Amount Total (lbs) 0 Process Amount Total (lbs) 13,200 Number of Process Chemicals 1 Number of Toxic Worst-Case Scenarios 1 Number of Toxic Alternate Scenarios 1 Number of Flammable Worst-Case Scenarios 0 Number of Flammable Alternate Scenarios 0 Process Chemicals Process Chemical ID Ammonia (anhydrous) CAS number Chemical Type Toxic Process Chemical Amount (lbs) 13,200 Confidential Business Information N

38 Worst-Case Toxic Scenarios Percent Weight (Within Mixture) 0 Physical State Gas liquified by pressure Model Used EPA's RMP*Comp(TM) Release Duration (minutes) 10 Wind Speed (meters/sec) 1.5 Atmospheric Stability Class F Topography Urban Passive Mitigation - Dikes No Passive Mitigation - Enclosures No Passive Mitigation - Berms No Passive Mitigation - Drains No Passive Mitigation - Sumps No Confidential Business Information No

39 Alternate Case Toxic Scenarios Percent Weight (Within Mixture) 0 Physical State Gas liquified by pressure Model Used EPA's RMP*Comp(TM) Wind Speed 3 Atmospheric Stability Class D Topography Urban Passive Mitigation - Dikes No Passive Mitigation - Enclosures No Passive Mitigation - Berms No

40 Prevention Program 3 Safety Info Review Date 04/01/2004 PHA Update Date 03/31/2002 PHA Technique - What If No PHA Technique - Checklist No PHA Technique - What If/Checklist No PHA Technique - HAZOP Yes PHA Technique - FMEA No PHA Technique - FTA No PHA Change Completion Date 03/31/2005

41 Accidents Accident Date 09/12/2006 Accident Time 0540 Number of Chemicals 1 Flammable Amount Total (lbs) 0 Toxic Amount Total (lbs) 2,530 Released Amount Total (lbs) 2,530 Number of Deaths 0 Number of Injuries 0 Number Evacuated / Sheltered 0 Total Property Damage $0 Environmental Damage Yes NAICS of Process Involved Release Event - Spill No Release Event - Fire No Release Event - Explosion

42 Emergency Response Plan Info Facility In Community Plan Yes Facility Own Response Plan Yes Specific Facility Response Plan Yes Inform. Procedures in Response Plan Yes Emergency Care in Response Plan Yes Plan Review Date 04/01/2004 Response Training Date 04/28/2004 Local Response Agency Shreveport Fire Department

43 EPA RMP 1998 Changes Compliance Elements Follow-up / completion of PHA recommendation Re-validation of your PHA every 5 years Compliance audits (required every 3 years) Follow-up / completion of compliance audit recommendations

44 EPA RMP 1998 Changes Compliance Elements Annual review and certification of operating procedures Employee training Updates related to system modifications, inventory changes, operational changes Off-site consequence analysis Updated

45 EPA RMP Summary EPA RMP Summary Not all PSM sites are RMP sites and vice versa Chemical Substances and TQ s are Not the Same for PSM Focused on Protecting the Surrounding Community - Off Site Consequence Electronically submitted to EPA

46 PSM & RMP- Why? PSM & RMP- Why? To Protect the Workforce To Protect the Surrounding Community To Maintain System Integrity To Comply with the Law It s Not About a Program, It s About People!

47 What s Next What s Next Course Summary References & Resources Georgia Tech Research Institute 100% Guarantee Final Questions Certificates