Cognis Corporation - Kankakee, IL, Mfg. Facility - Executive Summary
The Cognis Corporation, Kankakee, Illinois, facility considers protection of employees, the public and the environment to be its most important responsibility. A key element of its protection program is the development and implementation of plans to prevent accidental chemical releases. In addition, if an accidental release should occur, the facility is prepared to respond in an organized and effective manner.
The Cognis Corporation, Kankakee, Illinois, facility accident prevention and emergency response programs have been developed in accordance with federal and state regulations, industry standards, and coordination from Kankakee County emergency response organizations. Although the facility's programs have been highly successful - the facility has never had a significant chemical release - the facility continually seeks ways to improve its prevention and response programs.
This document, the Risk Management Plan (RMP) for the facility, was prepared to comply wit
h federal regulatory requirements regarding the prevention of accidental chemical releases (40 CFR Part 68 Accidental Release Prevention Requirements). The purpose of the regulation is to reduce the potential for an accidental chemical release and strengthen emergency response planning at the facility and within the community. The RMP describes the incident at the facility which would have the most catastrohpic effects ("the worst case") and several scenarios of lesser magnitude ("alternative cases"). Although it is highly unlikely for the worse case described in the report to occur, worst case information is provided to support conservative emergency response planning. In this way, the community is well prepared to respond to the lesser magnitude scenarios which are more likely to occur.
Areas that could be impacted by an accidental chemical release were identified using PHAST software. PHAST is a very sophisticated, EPA-recognized program specifically designed for accidental ch
emical release modeling. Cognis invested in this software to ensure that it had access to the most accurate emergency planning data available.
Cognis Corporation, which was previously part of Henkel Corporation and is now a wholly-owned subsidiary of the worldwide Henkel Group (headquartered in Dusseldorf, Germany), manufactures products that improve people's lives. Cognis produces chemical ingredients that are used in many industries, including personal care (such as soap and shampoo), nutrition, automotive, construction, paint and agriculture. The Henkel Group has more than 55,000 employees serving in more than 330 companies in 70 nations.
Respect for the environment is a central tenet of Cognis. Cognis facilities were instrumental in Henkel Corporation being cited by the U.S. Environmental Protection Agency as an Environmental Champion for its performance in the voluntary 33/50 pollution prevention program. Cognis voluntarily participates in the Chemical M
anufacturers Association Responsible Care initiative and is implementing its environmental, health and safety codes of practice on a worldwide basis.
-ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES-
It is the policy of the Cognis Corporation facility to prevent all releases of potentially harmful substances. Senior management is responsible for release prevention and response programs and the facility has invested extensive time and resources in this effort.
The facility has detailed procedures which ensure that safety is considered in the design, installation, operation and maintenance of each process. Facility personnel receive regular safety training and employee input is solicited on every aspect of safety improvement. Failure to follow safety policies is grounds for dismissal.
If a release were to occur, trained facility personnel would control and contain the release. The standard procedure is to technically evaluate each situation, identify potential on-site and
off-site impacts, evacuate workers as necessary, contain the release and contact the local fire department to control the release and reduce any consequences.
-DESCRIPTION OF STATIONARY SOURCE-
The Cognis Corporation, Kankakee, Illinois, facility is a chemical manufacturing facility located at South Kensington Road. This facility is one of the largest Cognis manufacturing sites in the United States. Orginally constructed in 1948, the facility is situated on 310 acres of area land. Of this, more than 75 acres have been developed. The plant operates 24-hours a day, seven days a week. On average employees have more than 13 years of service with the company.
The locally produced Cognis products are used in detergents, pharmaceuticals, adhesives, shampoos, inks, coatings, food additives, vinyl sidings and plastic pipe.
The Kankakee site serves as an important distribution center. Centrally located in the United States, it is within one day's transportation time of nearly half of
the country's industry. The facility also exports products worldwide.
The facility is subject to numerous environmental, health and safety regulations and is regularly inspected by agency representatives. The following activities are specifically regulated:
Air Emissions Regulated by various air permits issued by IEPA
Wastewater Discharge regulated by permited issued by the POTW
Hazardous Waste Generation Activity under ID# ILD005215769
Process Safety Subject to OSHA Process Safety Management Rule
Emergency Planning Subject to SARA 311/312 Reporting
Release Reporting Subject to SARA 313, ID# 60901HNKLCSKEN
-DESCRIPTION OF REGULATED SUBSTANCES-
The facility handles three substances regulated by the RMP rule in sufficient quantities to be covered by the RMP rule: anhydrous ammonia, ethylenediamine and hydrogen chloride. The RMP rules classifies these chemi
cals as toxic substances. No facility chemicals are classified as flammable substances.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) within the batch cards and operating procedures. The facility ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).
The facility also maintains numerous technical documents that provide information about the design and construction of process equipment. The information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written proce
dures 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. Operating personnel have access to the information described above.
-OPERATING PROCEDURES -
To ensure that personnel operate equipment in accordance with all safety precautions, the facility maintains detailed written operating procedures. The procedures describe the safety considerations unique to specific operating modes, e.g.
- unit startup
- normal operations
- temporary operations
- emergency shutdown
- normal shutdown and
- initial startup of a new process
These procedures are used as a reference by experienced operators and provide a basis for consistent training for new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained current and accurate
by revising them as necessary to reflect changes made through the management of change (MOC) process.
To complement the written procedures for process operations, the facility has implemented a training program for all employees involved in operating a process. New employees receive basic training in facility operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate adequate knowledge to perform duties and tasks in a safe manner on their own, they can work independently. Refresher training for all operators is conducted every 3 years. Each training program includes a method of verifying that the operator understood the training.
The facility uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the facility has procedu
res in place to ensure that contractors:
- perform their work in a safe manner
- have the appropriate knowledge and skills
- are aware of the hazards in their workplace
- understand what they should do in the event of an emergency
- understand and follow site safety rules and
- inform facility personnel of any hazards that they find during their work
This is accomplished by providing contractors with:
- a process overview
- information about safety and health hazards
- emergency response plan requirements, and
- safe work practices prior to their beginning work.
In addition, the facility evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
-PRE-STARTUP SAFETY REVIEWS (PSSRs)-
The facility conducts a PSSR for any new process or process modification that requires a change in p
rocess safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are prepared before placing the equipment into service. This review provides one additional check to make sure construction is in accordance with design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that proces safety management and accident prevention program requirements are properly implemented.
The facility has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include:
- conducting training
- developing written procedur
- performing inspections and tests
- correcting indentified deficiencies and
- applying quality assurance measure
In combination, these activities form a system that maintains the mechanical integrity of the process equipment.
Maintenance personnel training includes an overview of the process, safety and health hazards, applicable maintenance procedures, emergency response plans and applicable safe work practices. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a MOC team will review the use of the equipment and determine what actions are necessary to ensure the safe operation
of the equipment.
Another integral part of the mechanical integrity program is quality assurance. The facility incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that the new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.
-SAFE WORK PRACTICES-
The Kankakee facility has long-standing safe work practices to ensure employee and process safety. Examples of these include:
- control of the entry/presence/exit of support personnel
- a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing
- a procedure for safe removal of hazardous materials before process piping or equipment is opened
- a permit and procedure to control spark-producting activities (i.e., hot work), and
- a permit and procedure to ensure that adequate precautions are in place before entry into a confined
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-
When making a change to a process, a facility must be careful that it does not inadvertently introduce any unanticipated hazards or disrupt any control or safety system. To prevent such mistakes, the Kankakee facility has a comprehensive system to manage changes to processes. This system requires that changes to process equipment, chemicals, technology and procedures be properly reviewed and authorized before being implemented. Affected 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 are provided any necessary training on the change.
The facility promptly investigates all incidents that resulted in, or could have resulted
in, a serious situation, e.g., a fire or explosion, a toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation results are sent to the facility manager for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are completed. The final resolution of each finding or recommendation is documented and the investigation results reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that te reports can be reviewed during future PHAs and PHA revalidations.
To help ensure that the accident prevention program is functioning properly, the Kankakee facility periodically conducts an audit to determine whet
her the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to the facility manager for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented and the two most recent reports are retained.
-CHEMICAL SPECIFIC PREVENTION STEPS-
In addition to the general accident prevention program described above, the Kankakee facility has installed specific safety features on many units to help:
- contain or control a release
- quickly detect a release and
- reduce the consequence of (mitigate) a release
The following types of safety features are usedin various processes:
- Chemical Detectors with alarms
- Process Alarms
ontainment and Control
- scrubber to neutralize chemical releases
- valves to permit isolation of the process (manual or automated)
- automated shutdown systems for specific process parameters (e.g., high level, high temperature)
- vessel to permit partial removal of the process inventory in the event of the release (e.g., dump tank)
- curbing or diking to contain liquid releases
- redundant equipment and instrumentation
- fire suppression and extinguishing systems
- deluge system for specific equipment
- trained emergency response personnel
- personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)
- blast-resistant buildings to help protect control systems and personnel
EMERGENCY RESPONSE PROGRAM INFORMATION
The Kankakee facility maintains a written emergency resonse program which is in place to protect worker and public safety as well as the environment. The program consists of pro
cedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is 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, and post-incident cleanup and decontamination requirements. In addition, the facility has procedures that address maintenance, inspection and testing of emergency response equipment, as well as instruction that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based upon modifications made to the facility processes or other plant facilities. The emergency response program changes includ
es informing and/or training affected personnel in the changes.
The overall emergency response program for the Kankakee facility has been submitted to the Local Emergency Planning Committee (LEPC). This organization coordiates emergency response in the Kankakee area. This includes periodic meetings of the committee with the local emergency response officials, local government officials and industry representatives. The facility has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. The facility conducts periodic emergency drills that involve emergency response organizations and the facility provides refresher training to local emergency responders regarding the hazards of regulated substances in the facility.
-PLANNED CHANGES TO IMPROVE SAFETY-
The Kankakee facility
constantly strives to improve the safety of the processes through periodic safety reviews, the incident investigation program and incorporating safety suggestions from the workers. The following types of changes are planned:
- upgrade process control systems to distributed control
- replace reactor and implement various repairs
- increase radio equipment
- add safety equipment at railcar loading stations
- upgrade epichlorohydrin feed system