Tenneco Packaging Specialty and Consumer Products - Executive Summary

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1.    Accidental Release Prevention and Emergency Response Policies 
We at Tenneco Packaging Specialty and Consumer Products, Inc. are strongly committed to employee, public and environmental safety.  This commitment is inherent in a comprehensive accidental release prevention program that covers areas such as design, installation, operation, and maintenance of the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances and to train employees regarding the safe operation of  processes involving regulated substances.  Although such an event is unlikely, employees are trained to react to unplanned releases of regulated substances.  In addition, the plant has coordinated with local and other emergency response organizations which provide highly trained emergency response personnel to help control and lessen the effects of any unplanned release. 
2.    The Stationary Source and the Regulated Substances  
The primary manufa 
cturing activity at this plant involves the production of plastic consumer products such as polystyrene foam plates, bowls, food containers, and foam insulation.  We have two substances present at our facility which are regulated by United States Environmental Protection Agency (USEPA) under the Risk Management Program.  These substances are CBI flammable substance and ethyl chloride; and are referenced in this document by the term "regulated substance".  The regulated substances at our facility are used as foaming agents in the production of the polystyrene foam.  These products are also often called "blowing agents" or "expansion agents" . 
The maximum inventory of CBI flammable substance possible at our facility is approximately 130,000 pounds. The maximum inventory of ethyl chloride possible is approximately 120,000 pounds.  Written operating procedures and high-level alarms prevent more than these amounts from being present in these tanks.   
3.    Worst Case Release Scenario(s) and 
Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
Under RMP, USEPA requires facilities to determine the effects of catastrophic releases of regulated substances.  In facilities which use flammable regulated substances, USEPA defines the worst case scenario for a catastrophic release to be 1 pound per square inch (psi) over-pressure as a result of an instantaneous release of the largest tank volume utilizing no active measures to control the release of the regulated substance under worst-case weather conditions.   USEPA defines alternative release scenarios as 1 psi over-pressure as a result of a timed release of a portion of the largest tank volume utilizing active measures to control the release of the regulated substance under neutral weather conditions.   
To evaluate the worst case scenario for the particular regulated substances and conditions at this facility, we used equations from Appe 
ndix D of the USEPA RMP Offsite Consequence Analysis Guidance and RMP Compute, a simplified EPA model based on the EPAs Offsite Consequence Analysis Guidance.  For analysis of alternative release scenarios, we also employed the equations provided by the USEPA in the RMP Offsite Consequence Analysis Guidance and RMP Compute.  The following paragraphs provide details of the chosen scenarios. 
The activities at the plant can be categorized by Program 3 of the RMP guidance.  The projected worst case release scenario would involve a catastrophic release from the CBI flammable substance storage.  The scenario involves the release of 130,000 pounds of CBI flammable substance. Passive mitigation systems such as dikes were not considered when evaluating this scenario.  The worst case release scenario assumes that the entire quantity of the CBI flammable substance storage tank is released as a vapor, an ignition source is present and 10 percent of the released quantity participates in a vapor c 
loud explosion.  Under worst case weather conditions, the maximum distance of 0.40 miles corresponds to an endpoint of 1 psi overpressure.   
The alternative release scenario involves a release from the CBI flammable substance storage tank assumed to result in a vapor cloud explosion.  The scenario involves the release of 130,000 pounds of CBI flammable substance. The release is controlled by active mitigation measures that include a deluge system, an automatic shut off valve.  Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.10 miles. 
4.  The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under EPAs 40 CFR Part 68.  This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition.  A number of processes at our facility are subject to the OS 
HA PSM standard under 29 CFR 1910.119.  We also have an air operating permit under Title V of the Clean Air Act. The following sections briefly describe the elements of the release prevention program that are in place at our stationary source. 
Process Safety Information 
Tenneco Packaging Specialty and Consumer Products, Inc.  maintains a detailed record of safety information that describes the chemical hazards, operating guidelines and equipment designs associated with the processes. 
Process Hazard Analysis 
Our facility conducts extensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The approach used to carry out these analyses is a HAZOP/Modified What If process.  The studies are undertaken by a team of qualified personnel with expertise in engineering, process operations and safety and are revalidated at a regular interval of approximately every 5 years.  Any findings related to the hazard analysis are addressed in a timel 
y manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Tenneco Packaging Specialty and Consumer Products, Inc.  maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily available to operators involved in the processes. 
Tenneco Packaging Specialty and Consumer Products, Inc. utilizes a detailed training program to ensure that employees who are operating processes using regulated substances are skilled in the handling, operation, and maintenance procedures associated with these processes.  Refresher training is provided at least every 3 years and more frequently as needed. 
Mechanical Integrity 
Tenneco Packaging Specialty and Consumer Products, Inc.  carries out routine, periodic m 
aintenance inspections and preventive maintenance on process equipment to ensure proper operations.  Process equipment examined during inspections include but are not limited to pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with training in maintenance practices.  These personnel are provided specialized training as needed.  Any equipment deficiencies identified by maintenance inspections are corrected in a safe and timely manner. 
Management of Change 
Written procedures at Tenneco Packaging Specialty and Consumer Products, Inc. are in place to manage changes in process chemicals, technology, equipment and procedures.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of changes and provided training, as needed, to deal with these changes. 
startup Safety Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Tenneco Packaging Specialty and Consumer Products, Inc.  These reviews are conducted to confirm that equipment and procedures are complete and suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
Tenneco Packaging Specialty and Consumer Products, Inc.  conducts audits on a regular basis to determine whether the requirements set out under the RMP rule are being implemented.  These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
Tenneco Packaging Specialty and Consumer Products, Inc. promptly investigates any incident that results in, or could reasonably result in a catastrophic release of a regulated substance.  These investigations are undertaken to identify the situa 
tion leading to the incident as well as any corrective actions to prevent a potential release from reoccurring.  Reports are kept for a minimum of 5 years. 
Employee Participation 
Tenneco Packaging Specialty and Consumer Products, Inc. truly believes that process safety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  Many employees participate in safety initiatives within the plant.  In addition, our employees have access to all information created as part of our facilitys implementation of the RMP rule, including information resulting from process hazard analyses, in particular. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of the contractors safety performance and program is carried out.  Tenneco Packaging Specialty 
and Consumer Products, Inc.  has a strict policy of informing contractors of known potential hazards related to the contractors work and the processes.  Contractors are also informed of the procedures for emergency response should an accidental release of a regulated substance occur. 
Hot Work  
The facility maintains a hot work program and issues a hot work permit for hot work conducted on or near the covered process.  Hot work is performed by qualified personnel who complete each permit and fulfill its requirements prior to the start of a hot work operation.  These permits are kept on file until the conclusion of the hot work operation.                                                                                                                                                                                                                                                   
5.    Five-year Accident History 
Tenneco Packaging Specialty and Consumer Products, Inc. has an excellent record 
of preventing accidental releases over the last 5 years.  There has been no accidental release during this period. 
6.    Emergency Response Plan 
Tenneco Packaging Specialty and Consumer Products, Inc. has developed a written emergency response plan to deal with fires and releases of hazardous materials.  The plan includes all aspects of emergency response including prompt notification of local emergency response agencies and the public; emergency evacuations, if necessary; adequate first aid and medical treatment should any be necessary.  The plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. In addition, emergency response equipment (fire extinguishers, etc) is regularly inspected and serviced.  
7.    Planned Changes to Improve Safety 
Our facility has exemplary occupational safety and health programs which encompass employee involvement, recognition for safe work, partnership with OSHA and continuo 
us hazard identification activities.  To enhance our continuous improvement in occupational safety and health, we are implementing programs designed under OSHAs Star certification program.  Our application is scheduled to be submitted 12/31/1999
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