Tessenderlo Kerley, Inc. - Finley Facility - Executive Summary

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1.0    Finley Facility Risk Management Plan: Executive Summary 
The Finley Facility (Facility) 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 the facility's processes.  The Tessenderlo Kerley, Inc. (Tessenderlo Kerley) policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to, control, and contain the release. 
The Tessenderlo Kerley Facility is located in south central Benton County southwest of Finley, Washington.  The plant occupies approximately five acres at the junction of Chemical Drive and the Northern Railroad tracks on the west bank of the Columbia River. 
The Fac 
ility produces and distributes agricultural and industrial chemicals (specifically mining and pulp and paper) for the northwest market.  Production at the Facility consists of the manufacture of fertilizers, pesticides, chemicals used for metal extraction in the mining industry, and chemicals used in the kraft paper industry.   
Products at the Facility include the manufacture or storage of several agricultural products: two ammonium polysulfide (APS) products, ammonium thiosulfate (ATS), and potassium thiosulfate.  In addition to these agricultural products, the Facility produces the pesticides Vapam and Enzone, as well as the metal extractant, Kermet.  Batch production of flowable sulfur and emulsified aqueous sulfur solution (used in the kraft paper industry) is also conducted at the facility. 
These chemicals utilize several regulated and non-regulated substances as raw materials. The large number of products and their raw materials require loading/unloading operations at the Facil 
ity, as well as the associated process and storage equipment.   
The Facility was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity.  Based on process knowledge, Tessenderlo Kerley identified two listed flammable substances and two regulated toxic substances kept on site. 
The regulated flammable substances stored on site at the Facility are dimethylamine and monomethylamine (methylamine).  The regulated toxic substances stored onsite are anhydrous ammonia and carbon disulfide.  The chemicals, largest quantities on site, and associated threshold quantity are presented in Table 1. 
Largest Quantity of Regulated Substances 
Regulated Substances                   Largest Quantity On Site (lbs)              Threshold Quantity (lbs) 
Dimethylamine                                            130,980                                                 10,000 
Methylamine                                               138,800                 
Ammonia (anhydrous)                               348,600                                                 10,000 
Carbon Disulfide                                        327,172                                                 20,000 
Worst-Case Scenarios 
Listed substances, which are stored above threshold quantities at the Finley Facility, are dimethylamine, methylamine, anhydrous ammonia, and carbon disulfide.  Based on worst-case analysis, the distance to the endpoint exceeds the distance to public receptors.  In addition, the Facility is subject to OSHA PSM.  Therefore, the process at the Finley Facility subject to the Accidental Release Prevention (ARP) program is classified as a Program 3 process under the program. 
Flammable Substances 
The endpoint for worst-case releases of flammable substances is 1 psi overpressure (i.e., 15.7 psi), resulting from a vapor cloud explosion.  The ARP Program requirement for flammables assumes an instantaneo 
us release and vapor cloud explosion.  A yield factor of 10 percent of the available energy released in the explosion shall be used to determine the distance to the explosion endpoint.  Since the worst-case release scenario for a flammable substance is based on the assumption that the entire quantity of the substance forms a vapor cloud, passive mitigation systems are not applicable.  
The distances to the endpoint of 1 psi overpressure for the worst-case releases of dimethylamine and methylamine, using the EPA equations, are presented in Table 2.   Dimethylamine is the worst-case flammable release with a 0.38-mile distance to the endpoint. 
Distances to Endpoints for Flammable Worst-Case Scenarios 
Chemical Name                                       Dimethylamine                      Methylamine 
Storage Capacity (gallons)                          24,170                                  25,420 
Weight(lbs)                                                 130,980                
Heat of Combustion (kilojoules/kg)              35,813                                   31,396 
Distance to 1 psi Overpressure (miles)          0.38                                     0.37 
Toxic Substances 
The endpoint for a worst-case release of a toxic substance is based on the Emergency Response Planning Guideline level 2 (ERPG-2) developed for each substance by the American Industrial Hygiene Association. The ARP Program requirement for toxics, in a worst-case scenario, assumes total quantity released in ten minutes from the single largest storage vessel containing the substance.   Passive mitigation, such as diked areas, may be taken into consideration.  Additionally, administrative controls that reduce actual storage capacity can be considered. 
The distances to the respective endpoints for the worst-case release of the above threshold quantity toxic substances using the EPA equations are presented in Table 3. Anhydrous ammonia is the worst-case toxic 
release for the Facility with a 4.41-mile distance to the endpoint. 
Table 3 
Distances to Endpoints for Toxic Worst-Case Scenarios 
Chemical Name                                                                      Ammonia (anhydrous)     Carbon Disulfide 
Largest Single Storage Vessel  Operating Capacity (gals.)       11,282                            31,100 
Weight (lbs)                                                                                 58,100                          327,172 
Toxic Endpoint ERPG-2 (mg/L)                                                      0.14                                0.16 
Distance to ERPG-2 (miles)                                                           4.41                                1.84 
Alternative Releases Scenarios 
Alternative release scenarios are those that are more likely to occur than the worst-case release scenario.  Alternative release scenarios for toxic substances should be those that lead to concentrations above the endpoin 
ts beyond the facility's fence line.  Alternative release scenarios for flammable substances should have the potential to cause substantial damage, including on-site damage.  
The following other conditions may be considered for alternative release scenarios: 
7 Release rate dependent upon scenario; 
7 Consideration of active and passive mitigation systems;  
7 Actual release height; and 
7 Use of typical meteorological conditions at the stationary source. 
Flammable Substances 
A single alternative release scenario for all flammable substances is required under the ARP program.  A hypothetical, but likely to occur, release scenario has been identified for dimethylamine as follows.  The two-inch line from the truck unloading station to the dimethylamine tank is sheered.  There is a 5 minute response time before the leak is isolated and the release stopped.  The calculated amount (using the OCAG Document, Section 12.4) of vapor released, 1195 pounds, will vaporize and ignite in a vapor clo 
ud explosion with an endpoint of 1 psi overpressure. 
The distance to 1 psi overpressure for the alternative-case release of dimethylamine using the EPA equations are presented in Table 4.  The alternative-case release of dimethylamine resulted in a 0.05-mile distance to the 1 psi overpressure endpoint. 
Table 4 
Distance to Endpoint for Flammable Alternative Release Scenario 
Chemical Name                                               Dimethylamine 
Mass Released (lbs)                                           1,195 
Heat of Combustion (kilojoules/kg)                    35,813 
Distance to 1 psi Overpressure (miles)                0.05 
Toxic Substances 
One alternative release scenario for each toxic substance is required to be conducted for the Facility under the Accidental Release Prevention program.  As with the worst-case release scenario, the alternative release scenario for the toxic substances utilizes the ERPG-2 to determine toxic endpoint. 
Hypothetical, but likely to occur, r 
elease scenarios have been identified for anhydrous ammonia and carbon disulfide.   
Ammonia (anhydrous) 
The two-inch diameter header pipe (300 feet long) connecting the six anhydrous ammonia tanks sheers.  Each tank is supplied with an automatic excess flow shutoff valve.  The instant (one-second release duration) the line is sheered all the valves activate, preventing the entire tank contents from releasing. The alternative release scenario assumes that the total mass released will be equal to the amount that could theoretically be released from the tanks and piping for the one second release duration. A release rate of 319 pounds per minute (lbs/min.) was first developed.  This release rate represents an unmitigated release (no excess flow valves). An alternate release rate of 5.32 lbs/min. was developed which accounts for the mitigation of the excess flow valves and is presented in Table 5.  
Carbon disulfide 
The more likely scenario for carbon disulfide assumes that a >-inch li 
ne sheers and there is a response time of five minutes before the shutoff valve is manually closed.  Contents of the pipe are being released until the valve is closed.  The estimate of carbon disulfide released under the alternative scenario is 1108.5 pounds and with an evaporation release rate of 77.82 lbs/min.. 
The distances to the toxic endpoints for the alternative-case releases using an accidental release model are presented in Table 5.  The alternative-case releases resulted in a 0.05-mile distance to the 0.14 mg/L ERPG-2 endpoint for anhydrous ammonia and resulted in a 0.30-mile distance to the 0.16 mg/L ERPG-2 endpoint for carbon disulfide. 
Distances to Endpoints for Toxic Alternate Release Scenarios 
Chemical Name                                    Ammonia (anhydrous)                    Carbon Disulfide 
Mass Released (lbs)                                       5.32                                           1108.5 
Release Rate (lbs/min.)                               
    5.32                                            77.82 
Toxic Endpoint ERPG-2 (mg/L)                        0.14                                              0.16 
Distance to Endpoint (miles)                            0.05                                              0.3 
The following is a summary of the of the accident prevention program in place at the Finley Facility.  The processes at the plant that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (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 continuous process of reviewing the accident prevention program and as such is in various stages of implementing changes to improve work place saf 
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 consequences 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 Hazardous Materials Team (HazMat Teams), regularly scheduled safety meetings, tail-gate safety meetings, Hazard Communication, Safety Suggestion Forms, "near-miss" reporting, and special training programs (emergency response training, first aid, etc.).  
The Finley Facility actively seeks employee involvement in the  
development and conduct of all accident prevention 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 t 
hat 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 ensure 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 technique such as what if/checklist and failure mode and effect or the deductive fault tree technique.   
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; person 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 additional 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. Implementation of mitigation options in response to PHA findings is based on a relative risk matrix assigned by the PHA team.  The matrix is based on severity (criticality) and probability (frequency).  This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention.  All approved mitigation options in response to PHA team 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 frequency until the process is no longer operating.   
The recommended order of analysis will be based upon the following criteria:  
7 age of process;  
7 extent of process hazards;  
7 number of affected employees; and  
7 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;  
7 initial startup;  
7 normal operations;  
7 temporary operations;  
7 emergency shutdown;  
7 emergency operations;  
7 normal shutdown;  
7 startup following a turnaround; and  
7 startup after emergency shutdown.   
These procedures provide guidance for experienced operators and also provide the basis for training new operato 
Operating procedures are to be 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 to be taken or followed in carrying out the stated procedures.  The specific instructions include the applicable safety precautions and appropriate information on safety implications. 
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 verify that the operator understood the training. 
The Finley 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 pl 
ace to ensure that contractors  
7 perform their work in a safe manner;  
7 have appropriate knowledge and skills;  
7 are aware of the hazards of their workplace;  
7 understand what they should do in the event of an emergency;  
7 understand and follow site specific safety rules; and  
7 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 (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; and (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 or facility modification that requires a change in process safety information.  The purpose of the PSSR is to ensure those 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 one additional check to make sure construction is in accordance with design 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 adequate.  A PSSR verifies that a PHA ha 
s been conducted, recommendations resolved, and training of employees involved in the process prior to a start-up. 
Mechanical Integrity 
Well established practices and procedures for maintaining process equipment should be kept.  The basic aspects of this program are to include  
7 training;  
7 developing written procedures;  
7 performing inspections and tests consistent with good engineering practices;  
7 correcting equipment deficiencies outside acceptable PSI limits; and  
7 applying quality assurance measures.   
In combination, these activities form a system that maintains the mechanical integrity of the process. 
Maintenance personnel receive training on  
7 an overview of the process;  
7 safety and health hazards;  
7 applicable maintenance procedures;  
7 emergency response plans; and 
7 applicable safe work practices. 
This training is to help ensure that they can perform their jobs in a safe manner. 
Another integral part of mechanical integrity program is quality assurance.  Qua 
lity assurance measures are to be 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 
During construction of new processes, all equipment to be installed is to be determined to be suitable 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 long standing safe work practices in place to help ensure worker and process safety.  Examples of these include  
7 control of the entry/presence/exit of support personnel;  
7 a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance; 
7 a procedure for safe removal of hazardous and toxic substances before process piping and equipment is opened;  
7 a permit and proce 
dure to control spark-producing activities (i.e., hot work); and  
7 a permit and procedure to ensure that adequate 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.  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, including contractors 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 involved the work of a contractor); and other persons wi 
th 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 incident and of investigation, description of incident, factors contributing to 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 Finley 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 findings in a report that is forwarded to plant management for resolution.  Corrective actions taken in res 
ponse 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 Prevention Steps 
The processes at the Finley Facility have hazards that must be managed to ensure continued safe operation.  The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. 
Universal Prevention Activities 
The accident prevention program summarized previously is applied to the RMP-covered process at the Finley 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) quickly 
detect a release, and (3) reduce the consequences of (mitigate) a release.  The following types of safety features are used in the RMP covered process: 
Release Detection 
1. Sensors with audible alarms are located to detect and warn of carbon disulfide leaks. 
Release Containment/Control 
1. Pressure relief valves on applicable tanks. 
2. Key manual valves are chained and padlocked in their critical (open/closed) position. 
3. Excess flow check valves designed to plug the outlet if outflow reaches equivalent of flow due to pipe rupture. 
4. Derailers and chock blocks to prevent rail car movement. 
Release Mitigation 
1. Standard operating procedures that control, isolate, and terminate leaks. 
2. Water reservoir below carbon disulfide tank will capture material leaking from tank and prevent evaporation. 
3. Personnel trained in emergency procedures. 
4. Water curtain and deluge system employed at origin of leak. 
5. Personal protective equipment (e.g., escape respirator, self-contained breat 
hing apparatus, and supplied air breathing apparatus). 
6. Ventilate contaminated areas. 
Five Year Accident History 
The Finley Facility has an excellent record of accident prevention over the past five years. There have been no incidents involving a regulated substance. 
Emergency Procedure Information 
The Facility maintains a written emergency procedure, which is in place to protect worker and public safety as well as the environment.  The procedures account for the possibility of a toxic substance being accidentally released, as well as for the possibility of a fire or explosion.  The procedures address notification of local emergency response agencies if a release occurs, and post incident cleanup and decontamination requirements.   
Employees receive training in emergency procedures. The emergency procedure is updated when necessary based on modifications made to Facility.  The emergency procedure changes are administered through the Management of Change (MOC) process, which incl 
udes informing and/or training affected personnel in the changes. 
The overall emergency procedure program for the Facility is coordinated with the Benton County, Washington Local Emergency Planning Committee (LEPC).  This coordination includes periodic meetings of the committee, which includes 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.
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