Tessenderlo Kerley, Inc. - Artesia Facility - Executive Summary

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1.0    Artesia Facility Risk Management Plan:  Executive Summary 
 
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES 
 
The Artesia 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. 
 
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES 
 
The Tessenderlo Kerley Facility is located in an urban area in Artesia, New Mexico on the west side of the Navajo Refinery (Navajo).  The Facility receives hydrogen sulfide gas through three pipelines from the adjacent Navajo facility and processes it into ammonium s 
ulfide (AS) or sodium hydrosulfide.  AS contains ammonia, and as such, ammonia is a raw material stored on site. 
 
Ammonium Sulfide Production 
 
The hydrogen sulfide gas is sent to a liquid knockout pot to remove any entrained liquid from the gas.  The gas is then routed to a scrubber/reactor where it is contacted with ammonia, which strips out hydrogen sulfide.  Product from these actions are then transferred as ammonium sulfide to onsite storage. 
 
Sodium Hydrosulfide 
 
The hydrogen sulfide gas is sent to a liquid knockout pot to remove any entrained liquid from the gas.  After removing the entrained liquid, the hydrogen sulfide gas is routed through two reactors.  It is contacted with a mixture of water and sodium hydroxide producing sodium hydrosulfide.  The product is transferred to onsite storage. 
 
Ammonia Unloading and Storage 
 
Ammonia is used as a raw material in the Facility.  It is brought to the Facility in railcars.  The Facility utilizes a two-inch unloading hose at the railca 
r rack for the unloading of ammonia.  A one-inch vapor recovery hose is used to connect one-inch schedule 80 hard piping to the storage tank.  
 
The Facility was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity.  Based on process knowledge, Facility personnel identified no listed flammable substances and only one toxic regulated substance kept on site.  The chemical, its largest quantity on site, and associated threshold quantity are presented in Table 1. 
 
TABLE 1 
Largest Quantity of Regulated Substance 
 
Regulated Substance                 Largest Quantity On Site (lbs)                  Threshold Quantity (lbs) 
Ammonia (anhydrous)                         156,000                                                         10,000 
 
Worst-Case Scenarios 
 
The listed substance which is stored above threshold quantities at the Artesia Facility is anhydrous ammonia.  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 Artesia Facility contains a Program 3 process under the Accidental Release Prevention (ARP) program. 
 
Flammable Substances 
 
The Artesia Facility does not have any flammable substances above the threshold quantity; therefore, analysis of worst-case release scenarios for flammable substances is not required. 
 
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.  
 
The distance to the respective endpoint for the worst-case release of the above threshold quantity toxic substance using the EPA equations is presented in Table 2. Anhydrous ammonia is the worst-case toxic released with a 4.28-mile distance to the endpoint. 
 
Ta 
ble 2 
Distance to Endpoint for Toxic Worst-Case Scenario 
 
 
Chemical Name                                 Ammonia (anhydrous) 
Weight (lbs)                                           156,000 
Toxic Endpoint ERPG-2 (mg/L)                0.14 
Distance to Endpoint (miles)                   4.28 
 
 
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 endpoints 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 conditions may be considered for alternative release scenarios: 
 
7 Release rate dependent upon scenario; 
7 Use of typical meteorological conditions at the stationary source; 
7 Actual release height; and 
7 Consideration of active and passive mitigation systems. 
 
    Fla 
mmable Substances 
 
The Artesia Facility does not have any flammable substances above the threshold quantity; therefore, analysis of worst-case release scenarios for flammable substances is not required. 
 
Toxic Substances 
 
One alternative release scenario for the toxic substance is required to be conducted for the Facility under the Accidental Release Prevention program.  As with the worst-case scenario, the alternative release scenario for the toxic substance utilizes the ERPG-2 to determine toxic endpoint. 
 
A hypothetical, but likely to occur, release scenario has been identified for anhydrous ammonia.  The Facility will assume a complete break of a one-inch line at the ammonia storage tank. 
 
The distance to the toxic endpoint for the alternative release is presented in Table 3.  The alternative release resulted in a 0.07-mile distance to the 0.14 mg/L ERPG-2 endpoint for anhydrous ammonia. 
 
TABLE 3 
Distance to Endpoint for Toxic Alternative Release Scenario 
 
 
Chemical Name          
                     Ammonia (anhydrous) 
Release Rate (lbs/min)                              60.86 
Toxic Endpoint ERPG-2 (mg/L)                   0.14  
Distance to Endpoint (miles)                       0.07 
 
GENERAL ACCIDENT RELEASE PROGRAM 
 
The following is a summary of the accident prevention program in place at the Artesia 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 process of reviewing the accident prevention program and is in various stages of implementing changes to improve work place 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 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, "near-miss" reporting, and special training programs (emergency response training, first aid, etc.).  
 
The Artesia Facility actively seeks employee involvement in the development and conduct of all accident prevention activities through the appropriate existing safety programs.  Accid 
ent 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 associa 
ted 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 a 
nd 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; 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 believe 
s 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 five years and will be conducted at this frequency until the process is no longer operating.  The recommended orde 
r of analysis will be based upon the following criteria: 1) age of process; 2) extent of process hazards; 3) number of affected employees; and 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. initial startup; 
2. normal operations;  
3. temporary operations;  
4. emergency shutdown;  
5. emergency operations;  
6. normal shutdown;  
7. startup following a turnaround; and 
8. start up after emergency shutdown.   
 
These procedures provide guidance for experienced operators and also provide the basis for training new operators.   
 
Operating procedures are to be periodically reviewed and annually certified as current and accurate.  The review is to assure that the p 
rocedures 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 pr 
ocess.  New employees are to receive basic training in process operations and procedures. In addition, all operators are to periodically 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. 
 
Contractors 
 
The Artesia 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 following: 
 
1. perform their work in a safe manner;  
2. have appropriate knowledge and skills;  
3. are aware of the h 
azards of their workplace; 
4. understand what they should do in the event of an emergency;  
5. understand and follow site specific safety rules; and  
6. 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; 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. 
 
Pr 
e-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 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 or adequate.  Prior to startup, the Facility determines that a PHA has been conducted, recommendations resolved, and training of employees involved in the process is verifie 
d 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 tests consistent with good engineering practices;  
4. correcting equipment deficiencies outside acceptable PSI limits; and 
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; and 
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 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 
 
Several actions are to be incorporated during construction of new processes or equipment to ensure these are 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 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 process piping and equipment is opened 
4. a permit and procedure to control spark-producing activities (i.e., hot w 
ork); and 
5. 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 procedure 
s 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 with appropriate knowledge and experience to thoroughly i 
nvestigate and analyze the incident.  The investigation team documents its findings in a report.  The report includes dates of the incident and 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 Artesia 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 response to the audit team's findings are tracked and docume 
nted 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 Artesia 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. 
 
Universal Prevention Activities 
 
The accident prevention program summarized previously is applied to the RMP-covered process at the Artesia 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 cons 
equences (mitigate) of 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 leaks. 
 
Release Containment/Control 
 
1. Pressure relief valves on applicable tanks. 
2. Excess flow check valves designed to plug the outlet if outflow reaches equivalent of flow due to pipe rupture. 
3. De-railers and chock blocks to prevent rail car movement. 
 
Release Mitigation 
 
1. Standard operating procedures that control, isolate, and terminate H2S leaks 
2. Personnel trained in emergency procedures. 
3. Water deluge system employed at origin of leak. 
4. Personal protective equipment (e.g., escape respirator, self-contained breathing apparatus, and supplied air breathing apparatus). 
 
Five Year Accident History 
 
The Artesia Facility has an excellent record of accident prevention over the past five years. There has been no incident involving a regulated substance. 
 
Emergency Procedure Informat 
ion 
 
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 includes informing and/or training affected personnel in the changes. 
 
The overall emergency procedure program for the Facility is coordinated with the Carlsbad, New Mexico Local Emergency Planning Committee (LEPC).  This coordination includes periodic meetings of the committee, which includes local emerge 
ncy 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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