Tenneco Packaging - NAPP, Visalia, CA - Executive Summary |
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Tenneco Packaging - NAPP, Visalia, NY 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES We at Tenneco are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with the Region 5 Local Emergency Planning Commission (LEPC) Inland South and the Visalia Fire Department to provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED Our facilitys primary activities encompass the manufacturing of polyethylene foam products that is used as packaging material. We have one regulated substance present at our facility, butane. This regulated substance is used as a blowing agent at our facility. The maximum inventory of butane at our facility is 45,000 lbs. 3. THE WORST CASE RELEASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIO, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO To evaluate the worst case scenario and alternative release scenario, we have used equations from the Environmental Protection Agency (EPA's) RMP Guidance for propane Storage Facilities. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted is for a Level 3 flammable substance which involves a catastrophic release from a butane storage tank. The scenario involves the release of 45,000 lbs. of butane. Passive mitigation systems such as dikes have not been considered when evaluating this worst case scenario. For this scenario, it i s assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under the worst case weather conditions, the consequence distance from the explosion of the vapor cloud to an overpressure of 1 pound per square inch (psi) is 0.3 miles. The alternative release scenario submitted is for a Level 3 flammable substance which involves a release of butane from an overfilled storage tank. The scenario involves the release of 9700 lb. of butane which is assumed to result in a pool fire. The maximum distance from the center of the pool where people can potentially receive second degree burns from a 40-second exposure is 0.1 miles. 4. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE CHEMICAL SPECIFIC PREVENTION STEPS Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. In additio n, we have one process at our facility which is subject to the Occupational Safety & Health Administration (OSHA) Process Safety Management (PSM) standard under 29 CFR 1910.119. The following sections briefly describe the elements of the accidental release prevention program that are in place at Tenneco. Process Safety Information Tenneco maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with the covered process. Process Hazard Analysis Tenneco conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. HAZOP/What-If methodology is used to carry out these analyses. These studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and revalidated at a regular interval of 5 years and when major changes are made to the covered process. Any findings related to the hazard analysi s are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within the covered process, Tenneco maintains written operating procedures. These procedures address various modes of operation such as startup, shutdown, normal operations, temporary operations, emergency shutdown and emergency operations. The information is reviewed on a regular basis and is readily accessible to operators involved in the process. Training Tenneco has a comprehensive training program in place to ensure that employees who are operating components of the covered process are competent in the operating procedures associated with these components. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity Tenneco performs documented maintenance checks on covered process equipment to ensure proper operations. Process equipment examined by these checks includes but is not limited to storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. The maintenance operations are done by qualified personnel with previous training in maintenance practices; and these personnel are provided specialized training as needed. Management of Change Written procedures are in place at Tenneco to manage changes in covered process chemicals, technology, equipment and procedures. Operators, maintenance personnel or any other employee whose job tasks are affected by a modification in the covered process conditions are promptly made aware of and given training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to additions and modifications to the covered process are conducted as a regular practice at Tenneco. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Tenneco will continue to conduct periodic audits to ensure that the provisions set forth under the RMP and PSM rules are being implemented. Any corrective actions required as a result of the audits will be undertaken in a safe and prompt manner. Incident Investigation Tenneco promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions that would prevent the release from reoccurring. All reports are retained at our facility for a minimum of 5 years. Employee Participation Tenneco truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and they actively participate in process s afety management. In addition, Tenneco employees have access to all information created as part of the facility's implementation of the RMP and PSM rules, including information resulting from process hazard analyses. Contractors On occasion, Tenneco hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough safety performance evaluation of the contractor is carried out. Tenneco has a strict policy of informing the contractors of known potential hazards related the contractor's work and the covered process. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. FIVE-YEAR ACCIDENT HISTORY Tenneco has an excellent record of preventing accidental releases over the last 5 years. As a result of Tenneco's stringent release prevention programs, there have been no significant accidental releases during this period. 6. EMERGENCY RESPONSE P LAN Tenneco maintains a written emergency evacuation plan for the safety of our employees during accidental releases of hazardous materials. The plan includes adequate first aid and medical treatment, evacuations and notification of local emergency response agencies Tenneco employees do not respond to the emergency. Emergency notification equipment is regularly inspected and serviced to ensure proper functioning. Upon modification of the covered process, the plan is promptly updated to reflect any pertinent changes within the covered process that would require a modified emergency response. 7. PLANNED CHANGES TO IMPROVE SAFETY To enhance our continuous improvement in occupational safety and health, we conduct monthly general safety planning meetings which includes employee participation. |