Callaway Chemical Company / Mayo Division - Executive Summary

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The Callaway-Smyrna plant has a long-standing commitment to worker and public safety and to the protection of the environment.  We are committed to operating and maintaining all of our processes in a safe and responsible manner, as demonstrated by the resources we invest to prevent accidents.  As a member of the Chemical Manufacturers Association, we adhere to the principles of Responsible Care..  In addition to ensuring that our employees have the best possible training in the operation of our processes, we demand that safety be the first priority in the design, installation, operation, and maintenance of our processes.  
We have implemented maintenance and inspection programs that ensure site integrity.  Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances.  Examples of controls to prevent releases include (1) installation of pressure relief valves to prevent rupture of v 
essels due to overpressurization, (2) routine visual inspection and thickness checks to ensure vessels and piping are in good condition, (3) using materials of construction that are compatible with the process chemistry, (4) vessel pressure and temperature are continuously monitored and (5) use of carbon and water scrubbers to remove small amounts of emissions. 
However, if a release does occur, trained personnel will respond to control and contain the release.  Mitigation measures that have been included in our design include installation of isolation valves, fire suppression systems in areas where flammable chemicals are present and fire fighting equipment in all process areas, a fully implemented emergency response plan, appropriate PPE and an alarm system for early notification of a release.  The local fire department is also familiar with our site. 
The Callaway-Smyrna plant is primarily involved in manufacturing phosphonates and polyme 
ric dispersants.  Raw materials are received and distributed via rail cars, tank trucks and in tote bins and drums.  As a part of this manufacturing process, we use several substances that are covered by the risk management program (RMP) rule (40 CFR 68).  However, we also use a combination of good design practices, an accidental release prevention program, and an emergency response program to ensure the safety of our employees, the public, and the environment.  We are committed to operating our facility in a safe and responsible manner.  Following is a brief description of the facility and a list of RMP-regulated processes at our facility. 
The Callaway-Smyrna plant is situated on 60 acres.  Covered processes are the phosphorous acid process and the  ammonia process.  RMP covered chemicals currently include phosphorous trichloride and aqua ammonia.  Maximum quantities of these chemicals include about 264,000 pounds of phosphorous trichloride and 90,000 pounds of aqua ammonia.  Both pro 
cesses are subject to Program Level 3. 
EPAs RMP rule (40 CFR 68) requires that we provide information about two types of offsite consequence analysis scenarios:  worst-case scenarios and alternative release scenarios.  There are strict requirements for choosing and modeling worst-case release scenarios; as a result, these scenarios are often exceedingly conservative.  The purpose of the alternative release scenarios is to provide emergency planners with more information about the chemicals we handle and about their relative hazards.  The alternative release scenarios are more realistic than worst-case release scenarios but are still unlikely to happen. 
Following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures that limit exposure distances. 
Worst-case toxic release scenario 
The worst-case release scenario representing the toxic substances handled by Callaway-Smyrna  
is a catastrophic rupture of a Phosphorous Trichloride tank.  This would result in 237,000 pounds of phosphorous trichloride being released into secondary containment.  The phosphorous trichloride reacts with any moisture in the air or ground to form hydrochloric acid vapors.  The vapors travel about 3.5 miles before reaching the toxic endpoint.  Approximately 175,000  people live within this distance from the tank.  Some of the public and environmental receptors that are located within this distance are as follows:  Nickajack Creek, the Chattahoochee River, Lindley Middle School,I-20 and Six Flags, I-285 and numerous businesses and houses. 
Alternative toxic release scenarios 
The alternative release scenario for phosphorus trichloride is a break in the hose used for unloading phosphorus trichloride from a tank truck into our process.  The liquid is pumped to the ground at a flow rate of 440 lb/min for 2 min, which is the length of time required for a Callaway employee to shut the pump 
off.  The phosphorus trichloride evaporates from the liquid pool and travels about 0.20 miles  before dispersing below the toxic endpoint. Approximately 20 people live within this distance from the tank truck.  The public and environmental receptors that are located within this distance are as follows: a church, Nickajack Creek and a few houses. 
The alternative release scenario for ammonia solution is a break in the hose used for unloading aqueous ammonia from a tank truck into our process.  The liquid is pumped to the ground at a flow rate of 700 lb/min for 2 min, which is the length of time required for a Callaway employee to shut the pump off.  The ammonia evaporates from the liquid pool and travels about 0.10 miles before dispersing below the toxic endpoint. Approximately 15 people live within this distance from the tank truck.  The public and environmental receptors that are located within this distance are as follows: a church, Nickajack Creek and a few houses. 
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals.  Our management system addresses each of the key features of a successful prevention program, as described below in Sections 4.1 through 4.12. 
The Callaway-Smyrna plant maintains a variety of technical documents that describe the chemicals and processes at our facility.  These documents are kept up to date and are available to all employees and address important process parameters such as (1) operating limits for the equipment, (2) design basis and configuration of the equipment, and (3) physical properties and hazards of the chemicals used in our processes. 
Chemical information is usually documented within Material Safety Data Sheets (MSDSs). MSDSs contain information concerning both the physical properties and the hazards associated with each chemical.  This information typically includ 
es (1) toxicity information, (2) physical data, (3) reactivity and corrosivity data, (4) thermal and chemical stability data, and (5) hazards of mixing substances together.  MSDSs are available to all employees, as well as the emergency responders in our community.  MSDS's for all Smyrna materials are maintained on site. 
Important process parameters are also documented and maintained.  Engineering design documents may include (1) operating limits, (2) block flow or simplified process flow diagrams, (3) process chemistry, (4) maximum intended inventories, (5) design basis and configuration, (6) piping and instrumentation diagrams, and (7) other information that is important for understanding the design intent, operating limits, and hazards of each process. 
The Callaway-Smyrna plant has a comprehensive program for ensuring that the hazards associated with our processes are identified and controlled.  Each process is examined in detail to ensure that all hazards  
are identified and that appropriate controls are in place to manage those hazards. 
A hazard and operability (HAZOP) analysis is typically used for our process hazard analyses.  A team comprising personnel with engineering, operations, environmental and maintenance experience systematically examines each hazard in each section of the process and identifies potential causes and a range of possible consequences.  The team then compares the hazard to the existing set of prevention and mitigation measures designed to contain that hazard, making further recommendations when deemed necessary.  These recommendations are resolved by management and are tracked until they are implemented. 
We update and revalidate each process hazard analysis every five years or whenever a significant change is made.   The results and findings from these revalidation studies are documented and retained, and recommendations are tracked until resolved by management. 
Our engineers, operators, a 
nd supervisors work together to develop and maintain operating procedures that ensure the safe operation of our facility.  These procedures cover all modes of operation, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new or improved process. Operating procedures are used as a reference by experienced employees and provide a consistent basis for training new employees.  In addition to describing the steps for safely conducting operations, the procedures also contain valuable information about safe upper and lower limits, consequences of deviations, and applicable safety and health information.  Operating procedures are annually certified as accurate to ensure that they are updated following process changes.  
Callaway-Smyrna also operates using the Callaway batchsheet system.  Batchsheets are the detailed operating procedures for making a batch of product.  The batchsheets include proce 
ss deviation codes describing the actions to take under various conditions (e.g., high temperature, high pressure, loss of cooling, etc) that may be encountered while manufacturing batches of hazardous chemicals. 
The Callaway-Smyrna plant trains workers to safely and effectively perform their tasks.  Employees who are new to a process are given basic training that includes (1) a general overview of the process, (2) the properties of the substances used in the process and their associated hazards, and (3) a detailed review of the operating procedures for that process.  Once they have demonstrated their understanding of this initial training, they are paired with an experienced operator to learn their specific job functions and tasks.  After they demonstrate their competence in performing these tasks, they are allowed to work independently. 
Through oral reviews, written tests, and on-the-job demonstration, we ensure that our employees understand the training given to them.  Th 
e frequency of refresher training is decided, in part, by our employees but is performed at least every three years.  All training given to an employee is documented, along with the means used to verify that the training is understood. 
The Callaway-Smyrna plant maintains the mechanical integrity of our equipment to prevent equipment failures that could endanger workers, the public, or the environment.  Our inspection and testing program helps identify equipment damage or deterioration before the equipment fails.  When a deficiency is found, maintenance personnel will correct the problem and try to identify the root causes of the deficiency so that future problems are avoided.  Our quality assurance system ensures that new or replacement equipment meets the strict design standards required for service in our facility.  The mechanical integrity system includes (1) inspection and testing procedures, (2) replacement equipment specifications, (3) procedures for safe  
work practices, (4) maintenance personnel training, and (5) required documentation. 
We review any changes to our processes to determine if new hazards are introduced or existing prevention measures are threatened.  Except for replacements-in-kind (e.g., replacing a valve with an identical valve), all changes are subjected to a hazard analysis to ensure that (1) new hazards are not inadvertently introduced into the system, (2) safety consequences resulting from the change are addressed, (3) operators in the process are notified of the change and made aware of possible repercussions, and (4) all training material, process safety information, and operating procedures are updated.  The management of change system applies to changes in the chemicals used, process equipment, technology, procedures, and other facility changes. 
Whenever a change occurs that requires updating the process safety information, the Callaway-Smyrna plant performs a pre-st 
artup safety review.  This review ensures that safety features, procedures, personnel, and the equipment are prepared for service before the process is restarted. A pre-startup review will generally include field verification of new construction and also serves a quality assurance function by verifying that accident prevention measures are implemented correctly.  Generally, a pre-startup review will ensure that (1) construction and equipment are consistent with design standards, (2) adequate operating, safety, and maintenance procedures are in place, (3) training for all affected employees is complete, and (4) a process hazard analysis has been performed, if necessary. 
The Callaway-Smyrna plant trains its employees to promptly investigate each incident that resulted in, or could have resulted in, serious injury to employees, the public, or the environment.  Incident investigations are designed to determine the facts, identify the root causes, and provide recomm 
endations for ensuring that the incident does not recur.  Corrective actions resulting from an incident investigation are tracked until they are resolved. 
Incident investigations are conducted in accordance with Callaway Safety Standard 201 and utilized Non-Conformance Notices (NCN's) that are defined through our ISO Problem Elimination Procedure (AP-010). 
The Callaway-Smyrna plant encourages employees to be involved in every aspect of process safety management and accident prevention.  Employees are routinely asked to participate in process hazard analyses, incident investigations, management of change hazard analyses, and all other aspects of the prevention program.  Employees have access to all information developed as part of the prevention program, and are specifically informed of any changes that occur in their process areas.  The various ways employees are involved in the prevention program are documented in a written plan. 
The Cal 
laway-Smyrna plant has established safe work practices that ensure the safety of our employees.  Examples of these procedures include (1) a hot work permit that is designed to control spark- or flame-producing activities, (2) a permit and procedure to control confined space entry, and (3) a lockout/tagout procedure for isolating energy sources during maintenance.  These procedures and permits ensure that operations and maintenance activities are performed safely. 
The Callaway-Smyrna plant uses contractors for various activities, such as maintenance and construction. All contractors are evaluated to ensure that they are well trained and are able to perform their job function in a safe manner.  A contractors safety record and performance are reviewed during the selection process. 
Once a contractor is selected, the Callaway-Smyrna plant provides training and procedures to ensure that contractor employees (1) perform their work in a safe manner, (2) are aware of the hazards  
associated with the area in which they will be working, (3) understand the emergency response procedures, and (4) report any hazards they find during their work.  Our personnel periodically monitor contractor activities to ensure they are performing their work in a safe manner. 
A compliance audit is performed periodically to help ensure that the prevention program activities at our facility are adequate and that safety issues are addressed effectively.  Audits are performed by a team that is knowledgeable in our processes, but is independent of our facility, to ensure a thorough and complete evaluation.  The audit team systematically evaluates each aspect of the prevention program, ensuring both compliance with the RMP rule and effective hazard prevention.  The results of audits are documented, and recommendations are tracked until they are resolved.  Compliance audits are conducted at least every three years. 
The prevention prog 
ram described previously ensures the safe operation of our facility by providing our employees with a system they can use to safely perform their job functions.  This management system helps prevent hazards associated with equipment failures and human error. In addition to the prevention program, the Callaway-Smyrna plant has safety features built into the design of our facility that help to ensure safe process operation for our employees, the public, and the environment.  These features may contain or control a release, detect a release, or reduce the consequences of a release.  They may also prevent a release by providing strict design standards for process equipment.  The following types of safety features are used in various processes in our facility: 
Release detection 
7    Procedures require that a Callaway-Smyrna plant employee be present during loading and unloading operations 
Release containment and control 
7    Valves to permit isolation of the process 
7    Automated notification syste 
ms for some process parameters (e.g., high level, high pressure) 
7    Manual shutdown systems located in the control room 
7    Diked areas designed to contain a release 
7    Pressure relief valves and rupture disks that discharge safely to the atmosphere 
Release mitigation 
7    Fire suppression equipment 
7    Trained emergency response personnel 
7    Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 
      7     Spill Clean-up equipment 
Our five-year accident history shows that the site has had a number or minor releases of RMP chemicals.  However, none of these has resulted in any off-site consequences and none has involved injuries or deaths to our own employees or to the public.  In addition, no significant property damage has occurred on site or offsite.  No public evacuation have been conducted due to these incidents. 
For each of these incidents, we conducted an incident investigation to identify and correct the root causes of 
the events.  The following list describes some of the improvements made as a result of these investigations: 
- Tank Level Alarms and Guages 
- Implemented a Mechanical Integrity Program 
- Upgraded secondary containment 
- Implemented a Scrubber System Check List 
The Callaway-Smyrna plant maintains a written emergency response plan that is designed to protect employees, the public, and the environment.  The procedures include all aspects of emergency response, including proper first-aid and other medical procedures, the use of emergency equipment, the use of personal protective equipment, evacuation plans, and community emergency response notification procedures. 
Procedures for maintaining emergency response equipment are also contained in the emergency response plan.  There are procedures that address maintaining, inspecting, testing, and using the critical equipment needed in an emergency.  Employees receive periodic training in the duties they are expecte 
d to perform during an emergency, and any change in the emergency response plan is administered through the management of change process so that affected employees are notified. 
The emergency response plan is coordinated with local emergency responders (e.g., the fire department).  This includes periodic meetings among community responders facility representatives so that they are aware of the hazards of our processes.  Communication channels with local responders are kept open 24-hours per day.  This coordination and communication ensures that the public is quickly notified, if necessary, and that action is promptly taken to minimize the consequences of a release.  We periodically conduct emergency response drills so that all participants are familiar with their duties during an emergency. 
The Callaway-Smyrna plant continuously strives to improve the safety of our processes.  Suggestions for improving safety are regularly addressed through process  
hazard analyses, management of change procedures, incident investigations, and employee suggestions.  The following changes are currently planned or have recently been completed: 
- Install relief valves on reactors 
- Update procedures 
- Install ground fault protection 
- Install pump power monitors 
Callaway Chemical has implemented a comprehensive Year 2000 program that addresses all aspects of computer, microprocessor and software use throughout the company's business and industrial operations.  At the plant, the Year 2000 program addresses computers, microprocessors and software controlling operations of the plant.
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