Kao Specialties Americas LLC - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At Kao Specialties Americas LLC, we are committed to operating and maintaining all of our processes (especially those using hazardous
substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency
response planning programs to help ensure the safety of our employees and the public as well as protection of the environment.
This document provides a brief overview of the comprehensive risk management activities that we have designed and
- A description of our facility and use of substances regulated by EPA's RMP regulation
- A summary of results from our assessment of the potential off site consequences from accidental chemical releases
- An overview of our accidental release prevention programs
- A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
- An overview of our emergency response program
- An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and
adversely affecting our employees, the public, and the environment
STATIONARY SOURCE AND REGULATED SUBSTANCES
Our facility produces specialty and textile chemicals using a variety of chemicals and processing operations. Plant 1, the Textile
Plant, produces 400 different products by reacting and blending different chemicals in a variety of 25 different vessels to support the
textile industry. Plant 2, the Surfactant Plant, also uses reactions and blending, utilizing four commercial and one pilot plant trains.
Plant 3, the Toner Binder Plant, produces resin-based products using one of two reactors. In our processes, we use the following
chemicals that EPA has identified as having the potential to cause significant off site consequences in the event of a substantial
Ethylene Oxide is utilized in the Surfactant Plant to make surfac
tants. The material is received via railcar, where approximately
170,000 pounds is unloaded to a storage tank. The ethylene oxide storage tank will hold a maximum of 289,000 pounds of material.
Quantities of up to 62,800 pounds of ethylene oxideper batch are used in reactions to make a variety of products.
Propylene Oxide is utilized in the Surfactant Plant to make surfactants. The material is received via railcar, where approximately
170,000 pounds is unloaded to a storage tank. The propylene oxide storage tank will hold a maximum of 83,000 pounds of material.
Quantities of up to 34,500 pounds of propylene oxide per batch are used in reactions to make a variety of products.
Isopropylamine is utilized in the reactor department of the Textile Chemical Plant. The material is received via tanker, where
approximately 16,600 pounds is unloaded into a storage tank. The isopropylamine is mixed in the storage tank with
monobutylamine, where the isopropylamine makes u
p approximately 26% of the mixture. The mixed amines storage tank will hold
approximately 72,600 pounds, 16,600 pounds of which is isopropylamine.
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are
posed to our employees, the public, and the environment by our use of these chemicals.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
Kao Specialties Americas LLC has performed offsite consequence analysis (OCA) to estimate the potential for an accidental
release of a regulated substance to affect the public or the environment. The OCA consists of evaluating both worst-case scenarios
(WCSs) and alternate release scenarios (ARSs). Kao Specialties Americas LLC does not expect the worst-case release scenario to
ever occur. An ARS represents a release that might occur during the lifetime of a facility like Kao Specialties Americas LLC. ARSs help
the Local Emergency Planning Committee (LEPC) improve the communi
ty emergency response plan. We have shared that
information with the LEPC and other organizations involved in emergency response activities. It is also available to the public. If you
are interested in this information, please contact our RMP Coordinator at 336-878-4266.
The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public because of
an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance. At distances less
than the endpoint distance, the effect would be greater; at distances greater than the endpoint distance, the effects would be less.
? When considering the release of a toxic substance, most people at the endpoint distance would not experience any long-term
health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely. Some people who
are particularly susceptible to the substance released could be inc
? When considering explosion of a flammable substance, people at the endpoint distance are likely to be knocked down by the
blast. Windows at the distance could shatter, and the potential for structural damage to buildings exists, although a building collapse
is unlikely. People could be seriously injured by being knocked down by the force of the blast, by flying glass, or by falling objects.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals and to ensure safe operation
of our facility. Our management systems address each of the key features of successful prevention programs including:
- Process Safety Information (PSI): We maintain the following chemical process information for each regulated substance in a
covered process as well as for other hazardous materials in both covered and non-covered processes:
o Toxicity information
o Permissible exposure limits
o Physical data
o Reactivity data
o Corrosivity data
o Thermal and chemical stability data
o Hazardous effects of inadvertent mixing of different materials that could foreseeably occur
We use material safety data sheets (MSDS's) to provide most of the process chemical information. Whenever required
information, such as corrosivity data or hazardous effects of inadvertent mixing, is not available in MSDS's, we develop
the missing data from other sources and provide it in separate documents.
We also maintain the following information pertaining to equipment in our regulated processes (as well as for many of
our non-regulated processes):
o Materials of construction
o Piping and instrument diagrams (P&ID's)
o Relief system design and design basis
o Ventilation system design
o Safety systems (interlocks, detection, or suppression systems)
Most of this information comes from the engineering design documents for the processes as well a
s from our own
maintenance files. Whenever required information was not available, we obtained the information from equipment
vendors, process designers, plant engineering, and/or research and development departments. In conjunction with our
equipment information collection efforts, we documented that our equipment complies with recognized and generally
accepted good engineering practices. For our older processes, where design information is obsolete, our Engineering
Department evaluated the existing design against appropriate safety criteria and documented that the equipment is
designed, maintained, inspected, tested, and operated in a safe manner.
- Process Hazards Analysis (PHA)- We conduct systematic PHA's of our regulated processes and other hazardous processes
at our facility according to an established schedule. This schedule ensures that we (1) address each process in a
prioritized order (based on the extent of process hazards, the number of potentially aff
ected employees and/or offsite
population, the age of the process, and the operating history of the process) and (2) update/revalidate each PHA at least
every five years (or more often if necessary because of process changes). We also conduct PHA's of all new processes
before those processes are placed in service.
Our PHA teams are composed of personnel with engineering and process operating experience, including at least one
person who has knowledge and experience in the process to be evaluated and a PHA team leader trained in the
application of the hazard evaluation technique used for the PHA.
We have a system in place to promptly resolve PHA team findings and recommendations, and we communicate
findings/recommendation resolutions to potentially affected personnel. PHA's are implemented in a written report for
each analysis soon after the analysis meetings are completed. Our managers review and resolve the PHA
recommendations after receiving the report. We
maintain a written action plan tracking the resolution status of each
recommendation, including an individual responsible for resolving each recommendation and a target completion date.
- Standard Operating Procedures (SOP)- Our process engineers, operators, and shift supervisors work together to develop and
maintain our operating procedures for all phases of operations including:
o Initial startup
o Normal operations
o Temporary operations
o Emergency shutdown, including the conditions under which emergency shutdown is required and assignment of
shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely
o Emergency operations
o Normal shutdown
o Startup following a turnaround or after an emergency shutdown
Our development teams use PSI, information from process designers/equipment manufacturers, and their own
experience to create and validate the procedures.
Our procedures address the follo
o Steps for safely conducting activities
o Safe operating limits
o Consequences of process deviations, as well as steps required to correct or avoid such deviations
o Safety and health considerations including (1) properties of, and hazards presented by, the chemicals used in the
process, (2) precautions necessary to prevent exposure, including engineering controls, administrative controls, and
personal protective equipment, (3) control measures to be taken if physical contact or airborne exposure occurs,
(4) quality control for raw materials and control of regulated substance inventory levels, and (5) any special or unique
o Safety systems and their functions
- Training - We provide our operators with initial and refresher training, which includes a general overview of the process,
properties of chemicals in the process, and safety and health hazards, as well as a detailed understanding of the
process operating procedures
and safe work practices. We provide initial training to new hires or newly assigned
employees before they are allowed to work independently as operators.
Periodically, at least every three years, we provide our operators with refresher training that, depending on job
classification, can include operating procedure training, equipment-specific training, and/or advanced (beyond
HAZCOM) chemical-specific training. Our refresher training courses emphasize process overview information, safe work
practices, operating procedures that are rarely used such as emergency shutdown, emergency operation and startup
following an emergency shutdown, and any operating issues requested by the shift group.
All training is accompanied by some form of evaluation to verify that our training has been understood. We use a
combination of physical demonstration of skills, oral reviews using a one-on-one format, and written tests. We review the
information missed by an employee who does not
pass all testing requirements, and we do not allow resumption of work
until minimum testing requirements are met.
All training is documented and includes the employee's name, date of training, and the means used to verify that the
employee understood the training.
- Mechanical Integrity (MI)- We consider all process-related equipment and safety systems that are critical for preventing
and/or mitigating releases of regulated substances to be covered by our MI program. This includes: pressure vessels
and storage tanks, piping systems including valves, relief and vent systems and devices, emergency shutdown systems,
controls such as monitoring devices, sensors, alarms, and interlocks, and pumps.
Our MI program uses equipment surveillance and preventive maintenance activities to identify equipment that is
deteriorating and needs repair or replacement before failure occurs. This program also specifies the repairs (or parts
replacement) needed to return deteriorated
equipment to acceptable specifications.
We identify equipment deficiencies through our inspection, test, and preventive maintenance activities or from routine
operating and maintenance tasks and correct them promptly. If we cannot immediately correct identified equipment
deficiencies, we implement protective measures to ensure safe operation until repairs can be made. All inspections and
preventive maintenance activities are documented.
- Pre-Startup Review - We perform pre-startup reviews on new stationary sources and on modified stationary sources
when the modification is significant enough to require a change in the process safety information. Our pre-startup review
is completed before regulated substances are brought into the process and only after we have confirmed that:
o Construction and equipment are in accordance with design specifications
o Safety, maintenance, operating, and emergency procedures are in place and are adequate
o PHA's have been performed
on new stationary sources and all recommendations have been resolved
o Management of Change (MOC) requirements have been satisfied for modified processes
o Training has been completed (and documented) for affected employees
We use a Pre-Startup Safety Review Checklist as an aid in documenting the performance of our pre-startup reviews. Our
checklist contains a list of safety questions covering process considerations that must be addressed prior to startup.
The person responsible for the project or maintenance task prepares the Pre-Startup Safety Review Checklist and
Approval Form and provides the names of the reviewer responsible for confirmation of each of the pre-startup review
safety questions. Each reviewer signs off on the checklist and approval form when satisfied that all assigned safety
questions are complete and no problems exist. All reviewers must sign off on the Pre-Startup Safety Review Checklist
before startup can be authorized.
- Compliance Audits - W
e conduct and certify compliance audits of the prevention programs for RMP-covered processes
at least every three years. We integrate these audits into PSM audits. Our audit teams consist of a team leader and an
appropriate number of team members based on the size and complexity of the processes to be audited.
Our audit team members use a protocol or a check-sheet that contains a series of questions that systematically address
each requirement of the RMP regulation. The team leader assigns each auditor specific RMP elements to cover in the
audit. Information obtained through field observations, interviews, and document reviews is documented, and
weaknesses or noncompliances are identified. At the conclusion of the audit, our audit team prepares a report that
identifies any specific noncompliance issues that need to be addressed. Plant management promptly reviews the audit
findings, determines an appropriate response for each finding, assigns responsibility for i
mplementation of a corrective
action, and assigns a target completion date. The corrective actions are placed in a tracking system and progress is
monitored quarterly until open issues are resolved. We retain the two most recent audit reports.
- Incident Investigations - We investigate all incidents (including near misses) that result in, or could reasonably have
resulted in, a large uncontrolled release of a regulated substance, serious injuries to our employees or the public, and/or
damage to the environment. We train our employees to identify occurrences requiring investigation and to notify the
appropriate person should such an event occur. If the incident meets RMP-classification criteria, we initiate an
investigation within 48 hours. We assemble an investigation team consisting of:
o At least one person knowledgeable in the process or activity involved
o Others with appropriate knowledge and skills to thoroughly investigate and analyze the event
ation team follows a written investigation protocol that addresses the key steps of fact finding, determination
of cause, and development of recommendations/actions to be taken. From the raw data collected, the incident
investigation team prepares the text for an incident summary report, which contains:
o Date and time of the event
o Date and time the investigation started
o Description of the event
o Identification of contributing factors
o Recommendations from the investigation
We resolve the report recommendations and develop action plans that are tracked to completion. We review the
incident investigation report and action plan items with employees (and contract employees, as appropriate) who work in
the affected area and/or perform job tasks relevant to the investigation findings. We accomplish this review by discussing
the event at the next safety meeting. We retain incident reports for at least five years.
- Employee Participation - We have a written employe
e participation program that meets RMP requirements. In this
document, we describe in detail the many different ways that employees participate in each element of the RMP
regulations. We periodically update this document as changes occur.
We consult with the employees on ways to improve participation in the RMP. Periodically, in our safety meetings, we
review results of PHA's and resolutions of their recommendations.
- Hot Work Permits - We studied OSHA's fire prevention and protection regulation 29 CFR 1910.252(a) and developed a
procedure that addresses these requirements. We also created a Safe Work Permit Form to document job requirements,
the dates for the hot work, and the object on which the work is to be performed. We distributed the Hot Work Procedure
and Safe Work Permit Forms to employees in safety meetings and used a workshop approach to train all employees
who may use or enforce a hot work permit activity. New employees are trained on the hot work perm
it procedure as part
of the safe work practices orientation. The Safety Manager audits completed Safe Work Permit Forms to ensure that any
errors in preparation or approval are identified and brought to the attention of those involved to prevent recurrence.
- Contractor Safety Programs - We have a detailed contractor safety program that applies to contractors performing
maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to an RMP-covered process.
This program does not apply to contractors providing incidental services that do not influence process safety.
We select contractors based on prior site work history and on information that they are required to provide as part of the
bid process. The bid information includes their current safety programs (i.e., safety organization, employee education
and training, and accident prevention program) and their prior safety performance (i.e., OSHA injury rates, property loss
ory compliance history, and worker's compensation insurance experience). Bidders that do not
provide all of the requested information, that do not have the desired skills, or that have an unsatisfactory safety record
are dropped from further consideration. Contractors that meet the minimum safety requirements are then judged on
whom can do a quality job at the lowest cost.
We provide a safety orientation for Contractor Supervisors before they begin work on site. (We require these Contractor
Supervisors to provide this same safety orientation to their employees who will work in our plant.) We use the orientation
meeting to familiarize contractors with the type of operations and associated hazards in the areas in which they will be
working. We provide copies of our Contractor Safety Training Program, which contains plant safety rules/policies, safe
work practices, a material hazard summary, and an outline of emergency actions for contractors. We make MSDS's
lable for our hazardous materials that may affect the contractor work area, copies of plant safe work practices and
policies, and emergency response actions associated with the contractor's work.
We require our contractors to perform the following tasks to help ensure process safety:
o Train each of their employees in the work practices necessary to safely perform the contracted work
o Provide each of their employees with the same safety orientation that we provide for contractors and supervisors
o Train each of their employees on our plant's safe work practices
o Document that each of their employees has received and understands the training noted above
o Ensure that each of their employees follows our plant safety rules and safe work practices
o Report to our staff any hazards created or found by their employees at the job site
o Provide information on contract employee job site injuries/illnesses to our designated representative
Additionally, Kao Specialties Ameri
cas LLC has instituted the following programs designed to enhance our prevention programs:
- Field Patrols conducted by employees each shift to identify and correct potential problems.
- Daily walkthrough inspections by the Safety Manager.
- Weekly walkthrough inspections by each operations department.
- Monthly area inspections by the High Point Chemical Safety Committee.
- Annual inspections by the High Point Fire Department, Factory Mutual Systems, and Wausau Insurance.
- Incident and Injury Reduction Incentive Program.
- Kao Specialties Americas LLC is an active member of the Chemical Manufacturer's Association, and as such, actively participates
in Responsible Care and Process Safety Code activities.
As part of our prevention efforts, we have implemented the following chemical-specific prevention steps:
Ethylene Oxide and Propylene Oxide:
- Continuous release monitoring of eight (8) locations throughout the plant utilizing a Gas Chromatograph.
- Continuous release monitorin
g of eight (8) locations throughout the plant utilizing a combustible gas indicator.
- Continuous production monitoring utilizing the computerized process control system to detect variances in production
processes that could lead to chemical releases.
- Use of locking control valves to protect against inadvertent process changed that could lead to chemical releases.
- Continuous production monitoring utilizing the computerized process control system to detect variances in production
processes that could lead to chemical releases.
- Improved operator certification and training.
These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and
our employees are committed to the standard that these management systems set for the way we do business, and we have
specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.
We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of
accidental chemical releases involving materials covered under EPA's RMP rule during the past five years:
No releases of RMP-covered chemicals have occurred from Kao Specialties Americas LLC in the last five years that have resulted in deaths,
injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or
environmental damage off site.
EMERGENCY RESPONSE PROGRAM
Kao Specialties Americas LLC maintains a written emergency response program, which is in place 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 fire or explosion if a flammable substance in accidentally releases. The procedures address all
aspects of emergency response, includi
ng 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, and
post-incident clean-up and decontamination requirements. Employees receive training in these procedures as necessary to
perform their specific emergency response duties. The emergency response program is updated when necessary based on
modifications made to Kao Specialties Americas LLC plant processes or the Kao Specialties Americas LLC plant facilities.
We coordinate our emergency response plans with local emergency planning committees and other emergency response officials,
providing all of the information they request for inclusion in community emergency response plans. Kao Specialties Americas LLC has
around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire
department). This provides a means
to notify the public of an incident, if necessary, as well as facilitating quick response to an
incident. In addition to periodic LEPC meetings, Kao Specialties Americas LLC conducts periodic emergency drills that involve the LEPC and
emergency response organizations, and provides annual refresher training to local emergency responders regarding the hazards
and regulated substances in the Kao Specialties Americas LLC plant.
The following are some examples of coordination activities:
- Membership in the LEPC and Industry Forum, providing positive feedback for emergency planning and response directly
between industry and emergency response agencies.
- Implemented and coordinated an Emergency Response Drill, simulating a leaking Ethylene Oxide rail car. This drill
involved responses from the LEPC, SERC, fire department, emergency medical technicians, and the Kao Specialties
Americas LLC HAZMAT Team. This drill, the largest in Guilford County for several years, demonstrated t
he cooperation and
quick response between all agencies.
PLANNED CHANGES TO IMPROVE SAFETY
The following is a list of improvements we are planning to implement at the facility to help prevent and/or better respond to
accidental chemical releases:
- Kao Specialties Americas LLC will implement all Process Hazard Analysis recommendations. These recommendations will be
implemented in a timely manner.
- All hazardous process, whether or not they are covered by the RMP regulations, shall be evaluated with the same strict
guidelines as those that are. This will ensure that all processes are managed in a safe and environmentally responsible
- Kao Specialties Americas LLC will work diligently to improve the operator training and certification program, ensuring that the
personnel who work on covered processes are trained to the maximum of their potential.