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.
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