Tessenderlo Kerley, Inc. - Pasadena Facility - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

Tessenderlo Kerley, Inc. seeks to provide a safe work environment for their employees as well as ensure the safety of those offsite.  In addition, Tessenderlo Kerley is keenly aware of the potential environmental impacts of their operations and they are committed to minimizing the negative effects of their processes on the environment. 
 
According to EPA 40 CFR 68, part 68.155, the Executive Summary should contain the following items: 
 
a) The accidental release prevention and emergency response policies at the stationary source 
b) The stationary source and regulated substances handled 
c) The Worst-case release scenario(s) and the alternative release scenarios(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
d) The general accident release prevention program and chemical-specific prevention steps 
e) The five-year accident history 
f)      The emergency response program 
g) Planned changes to improve safety. 
 
A. Accidental Release  
Prevention and Emergency Response Policies 
 
Tessenderlo Kerley, Inc. has a long-standing commitment to worker and public safety.  This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our process.  Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances.  However if a release does occur, our trained personnel will respond to control and contain the release. 
 
B. Description of Stationary Source and Regulated Substances Handled 
 
The Tessenderlo Kerley site manufactures and/or ships sulphur based fertilizers, photographic, food grade, and industrial chemicals.  The most common of these would be Ammonium Thiosulfate, in varying assays.  The facility exports internationally and domestically by several means such as ships, barges, trucks, rails or barrels. 
 
The only substance regulated by the EPA RMP Rule that  
is found above threshold quantities at the Pasadena site is Ammonia. 
C. Offsite Consequence Analysis 
 
The EPA RMP requires offsite consequence analysis to include the worst case flammable and toxic release scenarios as well as alternative cases for at least one flammable and all toxic substances. 
 
Worst Case Toxic:    Release of the entire 156,000 lb. Inventory of ammonia from tank V-23 in 10 minutes. 
 
 
Alternate Case Toxic:    (1)  Tank V-23 becomes overfilled with liquid.  The relief valve opens and fails to reseat, resulting in a release.  The storage conditions were assumed to be 72 degrees F and 120 psig.  The release duration for this case was 60 minutes.  Relief valve diameter is 2.5 inches and is found at an elevation of 14.7 feet.  The distance to toxic endpoint was found to be 0.43 miles. 
 
   (2)  Catastrophic rupture of liquid loading hose caused by the truck driving off while still connected (or other cause).  Duration assumed is 30 minutes and a hose diameter of 3 inches is assume 
d.  The truck inventory is assumed to be 20 tons and the liquid head was set to 3.3 feet.  Unfavorable weather conditions of night time and low wind were used for this modeling.  The distance to the toxic endpoint was found to be 6.0 miles. 
 
 
Worst Case Flammable:    None applicable. 
 
 
   Alternate Case Flammable:    None applicable. 
 
D. General Accidental Release Prevention Program Steps 
 
The following is a summary of the accident prevention program in place at the Pasadena facility.  The processes at the plant that are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP) regulations are also subject to the Occupational Safety and Health Administrations (OSHA's) process safety management (PSM) standard.  Therefore, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.  The facility is in the process of reviewing the accident prevention program and is in various stages  
of implementing changes to improve workplace safety. 
 
EMPLOYEE PARTICIPATION 
 
Active employee participation and involvement in the development and implementation of the Facility's PSM program is an important step toward achieving the objective to prevent or minimize the consequencs of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.  Employee involvement will help to ensure that all perspectives regarding PSM are considered, and that the best ideas are implemented.  Open communications are encouraged between supervisors and employees regarding all safety and health issues. 
 
The Facility strongly promotes employee involvement in safety issues through existing programs.  These programs include regularly scheduled safety meetings, Hazard Communication, "near-miss" reporting, and special training programs (emergency response training, first aid, etc.). 
 
The Pasadena facility actively seeks employee involvement in the development and conduct of all accident preve 
ntion activities through the appropriate existing safety programs.  Accident prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary.  Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments or suggestions. 
 
PROCESS SAFETY INFORMATION 
 
Complete and accurate written process safety information (PSI) concerning process chemicals, process technology, and process equipment is essential to effective PSM and RMP programs and to completing and maintaining a process hazard analysis (PHA).  The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans.  Process Safety Information is to be readily available to all employees. 
 
A variety of technical documents are to be kept that are used to help maintain safe operation of  
the process.  These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.  Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). 
 
Numerous technical documents are to be maintained that provide information about the design and construction of process equipment.  This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment.  This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. 
 
PROCESS HAZARD ANALYSIS (PHA) 
 
There is a comprehensive program to help ensur 
e that hazards associated with the various processes are identified and controlled.  Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. 
 
The Facility primarily uses the hazard and operability (HAZOP) method analysis technique to perform these evaluations.  However, as situations warrant, the Facility will use other inductive techniques such as what if/checklist and or other techniques.  The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise.  PHA team members include the process/project engineer responsible for the process/project; plant manager or knowledgeable plant person; perons knowledgeable in methods of hazard analysis; and others with particular expertise.  This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for a 
dditional prevention and/or mitigation measures when the team believes such measures are necessary. 
 
The PHA team findings are forwarded to local and corporate management for resolution.  Implementaion of mitigation options in response to PHA findings is based on a relative risk matrix assigned by the PHA team.  The matrix is base on severity (criticality) and probability (frequency).  This ranking helps ensure that potential accident scenarios assigned to the highest risk receive immediate attention.  All approved mitigation options in response to PHA ream findings are tracked until they are completed. The final resolution of each finding is documented and retained. 
 
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the PHA team periodically updates and revalidates the hazard analysis results.  These periodic reviews are conducted at least every 5 years and will be conducted at this frequen 
cy until the process is no longer operating.  The recommended order of analysis will be based upon the following criteria: 
    1.  age of process 
    2.  extent of process hazards 
    3.  number of affected employees 
    4.  operating history of the process 
 
The results and findings from these updates are documented and retained.  The team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. 
 
OPERATING PROCEDURES 
 
Written procedures are to be maintained that address various modes of process operations, such as the following: 
    1.  inital startup 
    2.  normal operations 
    3.  temporary operations 
    4.  emergency shutdown 
    5.  emergency operations 
    6.  normal shutdown 
    7.  startup following a turnaround 
    8.  startup after emergency shutdown 
These procedures provide guidance for experienced operators and also provides the basis for training new operators. 
 
Operating procedures to be are 
periodically reviewed and annually certified as current and accurate.  The review is to assure that the procedures reflect current operating practice, include changes from process technology changes, chemical changes, equipment changes, and changes to facilities.  The review and certification process involves both operators and technical staff. 
 
The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities.  To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees.  Operating procedures are specific instructions or details on what steps are taken or followed in completing the stated procedures.  The specific instructions include the applicable safety precautions and appropriate information on safety implications. 
 
TRAINING 
 
In addition to training on operating  
procedures, there is  to be a comprehensive training program for all employees involved in operating the process.  New employees are to receive basic training in process operations and procedures.  In addition, all operators are periodically to receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level.  This refresher training is to be conducted at least every three years.  The appropriate frequency of training is to be based on management in consultation with the employees involved in operating the particular process.  All of this training is to be documented for each operator including the means used to verity that the operator understood the training. 
 
CONTRACTORS 
 
The Pasadena facility uses contractors during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, there are to be procedures in place to ensure that contractors do the followin 
g: 
    1.  perform their work in a safe manner 
    2.  have appropriate knowledge and skills 
    3.  are aware of the hazards of their workplace 
    4.  understand what they should do in the event of an emergency 
    5.  inform plant personnel of any hazards that they find during their work 
 
This is to be accomplished by providing contractors with an orientation session that covers the following: 
    1.  a process overview 
    2.  information about safety and health hazards including known or potential fire, explosion, or toxic release hazards 
    3.  emergency response plan requirements 
    4.  safe work practices must be developed and implemented regarding control of entrance, presence and exit of contract personnel prior to beginning their work 
 
In addition, contractor safety programs and performance during the selection of a contractor are to be evaluated.  Contract employee injury and illness log should be maintained.  Plant personnel are to periodically monitor contract  
performance to ensure that contractors are fulfilling their safety obligations. 
 
PRE-STARTUP SAFETY REVIEW (PSSR) 
 
A PSSR should be conducted on any new facility modification that requires a change in process safety information.  The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment and highly hazardous chemicals into service.  This review provides on additional check to make sure construction is in accordance with desgn specification and that all-supporting systems are operationally ready. 
 
The PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.  The PSSR also ensures that procedures (safety, operating, maintenance, and emergency) are in place and are addequate.  Prior to startup, the facility determines that a PHA has been conducted, rec 
ommendations resolved, and training of employees involved in the process is verified as part of the PSSR. 
 
MECHANICAL INTEGRITY 
 
Well established practices and procedures for maintaining process equipment should be kept.  The basic aspects of this program are to include the following: 
    1.  training 
    2.  developing written procedures 
    3.  performing inspections and test consistent with good engineering practices 
    4.  correcting equipment deficiencies outside acceptable PSI limits 
    5.  applying quality assurance measures 
In combination, these activities form a system that maintains the mechanical integrity of the process. 
 
Maintenance personnel receive training on the following: 
    1.  an overview of the process 
    2.  safety and health hazards 
    3.  applicable maintenance procedures 
    4.  emergency response plans 
    5.  applicable safe work practices to help ensure that they can perform their jobs in a safe manner 
 
Another integral part of the mechanical  
integrity program is quality assurance.  Quality assurance measures are incorporated into equipment purchases and repairs.  This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. 
 
SAFE WORK PRACTICES 
 
Several actions are to be incorporated during construction of new processes or equipment to ensure these are suiteable for the process application.  Checks and inspections are to be performed to assure that installation is consistent with design specifications and manufacturer's instructions suitable for the particular application.  The Facility has safe work practices in place to help ensure worker and process safety.  Examples of these include the following: 
1.  control of the entry/presence/exit of support personnel 
2.  a lockout/tag out procedure to ensure isolation of energy sources for equipment undergoing maintenance 
3.  a procedure for safe removal of hazardous and toxic substances before proc 
ess piping and equipment is opened 
4.  a permit and procedure to control spark-producing activities (i.e. hot work)  
5.  a permit and procedure to ensure that adequeate precautions are in place before entry into a confined space 
These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 
 
MANAGEMENT OF CHANGE 
 
There is a comprehensive system of written procedures to manage changes to all covered processes.  This system requires that changes to items such as process chemicals, process equipment, technology (including process operating conditions), procedures, impact to safety and health and other facility changes be properly reviewed and authorized before being implemented.  Prior to changes being made, they are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change.  Affect 
ed chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes.  In addition operating and maintenance personnel, including contractor employees, are provided any necessary training on the change. 
 
INCIDENT INVESTIGATION 
 
The Facility promptly investigates (within 48 hours) all incidents that resulted in or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury.  The goal of each investigation is to gather the facts, determine the root cause , and develop corrective action to prevent the reoccurrence of the incident or a similar incident.  The reports are maintained for five years. 
 
An investigation team is established to investigate each process incident.  The team will consist of members involved in the incident including at least one person knowledgeable in the process involved; a contract employee (if the incident involv 
ed the work of a contractor); and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.  The investigation team documents its findings in a report.  The report includes dates of the incident, and develops recommendations to prevent a recurrence, and forwards these results to the business management team for resolution. 
 
COMPLIANCE AUDITS 
 
To help ensure that the accident prevention program is functioning properly, the Pasadena facility periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented.  Compliance audits are conducted at least every three years.  Both hourly and staff personnel participate as audit team members with at least one person knowledgeable in the audit techniques.  The audit team develops finding in a report that is forwarded to plant management for resolution.  Corrective actions taken in response to the audit team's findings  
are tracked and documented until they are complete.  The final resolution of each finding is documented, and the appropriate enhancements to the prevention program are implemented.  The two most recent compliance audit reports are retained. 
 
CHEMICAL SPECIFIC AND UNIVERSAL PREVENTION STEPS 
 
The processes at the Pasadena facility have hazards that must be managed to ensure continued safe operation.  The following sections include descriptions of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. 
 
The accident prevention program summarized previously is applied to the RMP covered process at the facility.  Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. 
 
SPECIALIZED SAFETY FEATURES 
 
The Facility has safety features on many units to help (1) contain/control a release, (2) quickely detect a release, and (3) reduce the consequ 
ences (mitigate) of a release.  The following types of safety features are used in the RMP covered process: 
*  Pressure relief valves on applicable tanks 
*  Excess flow check valves designed to plug the outlet if outflow reaches equivalent of flow due to pipe rupture 
*  De-railer and chock blocks to prevent rail car movement 
*  Personnel trained in emergency procedures 
*  Personal protective equipment  
 
E. Five-Year Accident History 
 
The Tessenderlo Kerley Pasadena Site is very concerned about maintaining a safe work environment for their employees and preventing any negative impacts on the surrounding community.  In so doing, there have been no accidents in the last five years that have caused: 
 
' On-site deaths, injuries or significant property damage, or 
' Known offsite deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place. 
 
F. Emergency Response Program 
 
Tessenderlo Kerley, Pasadena maintains a written emergency response program that is in pla 
ce to protect worker and public safety as well as the environment.  The program consists of procedures for responding to a release of a regulated substance, including the possibility of a toxic substance being accidentally released.  The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs.   
 
G. Planned Changes to Improve Safety 
 
Tessenderlo Kerley, Inc. is constantly seeking to improve the safety of the plant.  The safety recommendations resulting the from Process Hazard Analysis and compliance audit are to be completed by April, 2000.
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