Tenneco Packaging, NAPP Div., Glens Falls Plant - Executive Summary |
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EXECUTIVE SUMMARY 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Tenneco is committed to employee, public and environmental safety. The NAPP division of Tenneco has aggressive environmental and safety goals. Corporate EH&S personnel assist facilities in developing programs to meet these goals. The Glens Falls facility has an EH&S Manager to coordinate safety and environmental programs. This commitment is inherent to a comprehensive accidental release prevention program that covers design, installation, operation, maintenance and training for processes at the Glens Falls facility. In the event any unforeseeable release might still occur, the facility coordinates emergency response primarily with local fire departments. The Warren County LEPC is also made aware of our storage of flammable substances. 2. GLENS FACILITY AND REGULATED SUBSTANCE HANDLED The Glens Falls facility manufactures packaging materials including padded mailers, polyethylene foam in the form of sheets and planks and polyethylene bubble. The foam process uses a regulated flammable gas as a blowing agent. The maximum inventory at the facility is about 68,000 pounds. The maximum in one tank is about 48,000 pounds. The remainder is located in smaller tanks several hundred feet from the larger tank. 3. THE WORST CASE AND ALTERNATE RELEASE SECNARIO The scenarios for Glens Falls are taken from the EPA's RMP Guidance for propane storage facilities because the regulated flammable gas stored in Glens Falls is very similar to propane. The worst case scenario submitted for a level 3 flammable substance involves catastrophic release from a storage tank. Our scenario is based on a maximum, one tank storage of 48,000 pounds. Passive mitigation systems have not been considered. It is assumed the entire contents are released as a vapor cloud and 10% of the cloud ignites in a vapor cloud explosion. This produces off-site consequences of a magnitude of one poun d overpressure up to 0.3 miles from the tank. The alternate release scenario submitted for a level 3 flammable substance involves a spill of flammable material, such as from overfilling the storage tank. The scenario assumes release of 9700 pounds of flammable material which is assumed to produce a pool fire. The guidance document indicates the maximum distance for people to suffer second degree burns from a 40 second exposure is 0.1 miles from the center of the pool. 4. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS The Glens Falls facility has taken the necessary steps to comply with the accidental release prevention requirements contained in 40CFR part 68. In addition, the Glens Falls foam process is subject to the requirements of 29CFR1910.119. The facility has also submitted a Title V air permit application. The elements of the Glens Falls program follow closely those contained in the PSM regulation. A brief description fo llows: Process Safety Information The facility maintains a detailed record of process safety information that describes chemical hazards, operating parameters and equipment designs associated with the covered process. Process Hazard Analysis In order to identify and then control the hazards of the process, the Glens Falls facility has performed a What-If, HAZOP analysis using a team of qualified people with expertise in engineering, process operations and a leader with hazard analysis expertise. The hazard review is updated at least every 5 years or when major changes are made. The findings are addressed in a timely manner and documented. Operating Procedures To ensure the covered process is operated safely, written operating instructions are developed, maintained, and made readily available to operators. These procedures address various modes of operation such as startup, shutdown, normal operation, temporary operations, emergency shutdown and emergency operation. Training The Glens Falls facility trains employees that operate the covered processes initially, as changes are made and refresher training is conducted at least every three years. Training records are maintained. Mechanical Integrity The Glens Falls maintenance personnel perform documented maintenance on covered process equipment to ensure proper operation. A list of critical equipment with required test frequencies is maintained. Identified deficiencies are corrected in a timely manner. The work is performed by trained maintenance personnel. Equipment covered includes storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Management of Change Written Management of change procedures are followed, covering changes to process chemicals, technology, equipment and procedures. Operating and maintenance personnel affected by changes made aware of the changes and retrained as needed. Pre-startup Safety Reviews These rev iews are conducted for initial startups and those following modifications. The reviews confirm that construction, equipment and operating and maintenance procedures are suitable for a safe startup prior to placing the equipment into operation. Compliance Audits Audits will continue be done to ensure that the provisions of PSM and RPM are being implemented. Any necessary corrective actions are undertaken in a safe and prompt manner. Incident Investigation Tenneco personnel will promptly investigate any incident that has or could reasonable have resulted in a catastrophic release of a regulated substance. The investigations seek to identify causes and any corrective actions that may be implemented to prevent recurrences. Reports will be maintained for at least 5 years. Employee Participation Tenneco believes that process safety management and accident prevention is a team effort. Employees are strongly encouraged to express their views concerning accident prevention issues through frequent safety meetings, safety committees and incentive programs. PSM information, including PHA's, as well as operating procedures, are readily available to affected employees. Contractors The facility occasionally uses outside contractors to perform specialized maintenance or construction activities. A written contractor safety program is followed that includes a safety performance evaluation prior to contract, a review of the hazards the contractor may encounter from the covered process, safety rules to be followed and emergency response procedures. 5. FIVE YEAR ACCIDENT HISTORY There have been no significant accidental releases from the covered process during the past five years at the Glens Falls facility. 6. EMERGENCY RESPONSE PLAN The facility maintains a written emergency response plan to deal with potential accidents related to the covered process. The plan includes first aid response, notification of emergency responders and evacuation. Tenneco employees do not directly respond to incidents such as fires beyond the incipient stage. The emergency response plan is communicated to employees and updated as needed. 7. PLANNED CHANGES TO IMPROVE SAFETY Tenneco involves all employees in managing safety by setting aggressive goals, conducting frequent safety meetings and training, forming safety teams, enforcing safety rules and rewarding the meeting of goals. |