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Assessment of Approaches for Using Process Safety Metrics at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants
Oregon, have collectively destroyed more than 79 percent of the original stockpile. JACADS, Aberdeen, and Newport have been closed.
Chemical agent destruction pilot plants that employ nonincineration alternative destruction technologies are currently under construction at the PCD near Pueblo, Colorado (the Pueblo Chemical Agent Destruction Pilot Plant), and at BGAD in Richmond, Kentucky (the Blue Grass Chemical Agent Destruction Pilot Plant). Consequently, destruction operations have not yet begun at these sites. This report concerns the appropriate process safety metrics for use at these two sites.2
THE SAFETY CHALLENGE—PROCESS SAFETYMETRICS
The law mandating the destruction of chemical agent and munitions requires that the destruction be executed with maximum protection to workers, the public, and the environment. In the initial years of the stockpile disposal program, reports by NRC’s Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program repeatedly encouraged the Army and its contractors to pay increased attention to safety and to engage in processes aimed at continuous improvement with respect to safety.3 More recently that committee’s successor committee, the standing Committee on Chemical Stockpile Demilitarization, and numerous ad hoc NRC committees concerned with chemical demilitarization have continued to emphasize safety.
The Army and its contractors have responded so effectively that the remaining operating facilities have attained Occupational Safety and Health Administration (OSHA) recordable injury rates of less than one injury per 200,000 hours worked. Even so, in the interest of continuous improvement, in 2007 the Army expressed a desire and intent to achieve safety performance that is equal to, or better than, that of the best industrial companies, which are consistently near an OSHA recordable injury rate of 0.5. To assist in achieving this goal, the NRC was asked to review existing safety and environmental metrics at operating chemical agent disposal facilities and to recommend additional metrics and/or program modifications, if necessary. The NRC issued its report, Evaluationof Safety and Environmental Metrics for PotentialApplication at Chemical Agent Disposal Facilities, in April 2009.
Having been provided with the 2009 report, and for reasons such as the use of first-of-a-kind equipment and the need to conscientiously adhere to congressional mandates that the destruction of chemical agent and munitions be executed with maximum protection to workers, the public, and the environment, the Program Manager for Assembled Chemical Weapons Alternatives (PMACWA) determined that it would be useful for the NRC to conduct a study on process safety metrics to guide it in formulating a process safety plan for PCAPP and BGCAPP. Accordingly, PMACWA asked the NRC to undertake a study that would guide its development and application of process safety metrics. Since the PCAPP and BGCAPP sites are presently under construction, PMACWA has a timely opportunity to develop process safety metrics to measure and monitor process safety performance.
Because process safety metrics can measure the effectiveness of process safety program management, they are increasingly being used by industry. An independent investigation following an industrial accident at the BP refinery at Texas City, Texas, on March 23, 2005, underscored the inadequacy of injury rates alone to measure process safety performance and called attention to the value of process safety metrics. Specifically, the ensuing report by the BP Independent Refiners Safety Review Panel (the Baker panel report) stated:
BP primarily used injury rates to measure process safety performance at its U.S. refineries before the Texas City accident. Although BP was not alone in this practice, BP’s reliance on injury rates significantly hindered its perception of process risk. BP tracked some metrics relevant to process safety at its U.S. refineries. Apparently, however, BP did not understand or accept what this data indicated about the risk of a major accident or the overall performance of its process safety management systems. As a result, BP’s corporate safety management system for its U.S. refineries does not effectively measure and monitor process safety performance (Chemical Safety Board, 2007, p. xiv)