Kerr-McGee Chemical LLC (Henderson, NV) - Executive Summary
At Kerr-McGee Chemical LLC (KMCLLC), we are committed to operating and maintaining our processes in a safe and responsible manner. KMCLLC is committed to the guiding principles of CMA's Responsible Care. KMCLLC has prepared a policy stating this and will provide the resources necessary to meet the requirements of these guiding principles. 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 implemented, including: |
* A description of our facility and the use of substances regulated by EPA's RMP regulation
* An assessment of offsite consequences from potential accidental chemical releases
* A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
* An overview of our accidental release
* An overview of our emergency response program
* The certifications that EPA's RMP rule requires us to provide
* The detailed information (called data elements) about our risk management program
Our facility produces manganese dioxide, boron trichloride, elemental boron and ammonium perchlorate using a variety of chemicals and processing operations. In our processes, we use and/or store the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: ammonia, sulfur dioxide, hydrogen sulfide, boron trichloride and chlorine.
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.
Potential Off-Site Consequences of Accidental Releases
EPA's RMP rule requires that we provide information
about the potential worst-case release scenario and alternative release scenarios for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:
Liquid hydrogen sulfide is stored at the KMCLLC facility in a tank trailer. As required by RMP, the worst case scenario involves a trailer rupture and 28,000 pounds of hydrogen sulfide is released in 10 minutes. The worst case occurs at a time that there is little wind and the atmosphere is very stable. This means that little dispersion will occur. The model results show that the hydrogen sulfide cloud will travel approximately 9.3 miles before dispersing to a concentration less than the endpoint concentration in the RMP rule, Appendix A.
The hydrogen sulfide alternative case scenario involves a pressure relief valve. In this scenario, approximately 4,220 pounds
of hydrogen sulfide gas is released. More typical atmospheric conditions are present and the modeling analysis shows the hydrogen sulfide cloud will travel approximately 1.6 miles before the endpoint concentration is reached.
Ammonia is stored at the KMCLLC facility in horizontal tanks. The ammonia alternative case scenario involves a pressure relief valve. In this scenario, approximately 8,190 pounds of ammonia is released. More typical atmospheric conditions are present and the modeling analysis shows the ammonia cloud will travel approximately 0.5 miles before the endpoint concentration is reached.
Sulfur dioxide is stored at the KMCLLC facility in one ton cylinders. The sulfur dioxide alternative case scenario involves a leak from the storage vessel. In this scenario, approximately 2000 pounds of sulfur dioxide is released. More typical atmospheric conditions are present and the modeling analysis shows the sulfur dioxide cloud will travel approximately 0.6 miles bef
ore the endpoint concentration is reached.
Boron trichloride is stored at the KMCLLC facility in two-ton cylinders. The boron trichloride alternative case scenario involves a leak from the storage vessel. In this scenario, approximately 1,200 pounds of boron trichloride is released. More typical atmospheric conditions are present and the modeling analysis shows the boron trichloride cloud will travel approximately 0.25 miles before the endpoint concentration is reached.
Chlorine is stored at the KMCLLC facility in one ton cylinders. The chlorine alternative case scenario involves a leak from the storage vessel. In this scenario, approximately 2,000 pounds of chlorine is released. More typical atmospheric conditions are present and the modeling analysis shows the chlorine cloud will travel approximately 0.7 miles before the endpoint concentration is reached.
We are using this information to help us ensure that our emergency response plan and the community emer
gency response plan address all reasonable contingency cases.
The facility has taken numerous steps to prevent a release of any size. We have installed:
* Automatic air monitoring sensors and alerting systems
* Automatic actuating valves
* Manual isolation valves
* Remote actuated isolation valves
* Emergency shutdown systems
* Pressure relief systems
* Storage tank pressure indicators with alarms and interlocks
* Level indicators on storage tanks with high level alarms
* Scrubber systems
* Barometric legs
* Deluge systems consisting of water cannon fogger nozzles
* An accidental release prevention program (described below)
Five Year Accident History
We keep records for all significant accidental chemical releases that occur at our facility. The KMCLLC Henderson facility had no reportable chemical releases involving materials covered under EPA's RMP rule during the past five years.
Accidental Release Prevention Programs
We take a systematic, proactive approach to preventi
ng accidental releases of hazardous chemicals. Our management systems address key features of successful prevention programs including:
* Process safety information
* Process hazard analysis
* Operating procedures
* Mechanical integrity
* Management of change
* Pre-startup review
* Compliance audits
* Incident investigation
* Employee participation
* Hot work permit
We systematically control the creation, updating and retention of written documentation associated with our process chemicals, process technology and process equipment. This information is essential for supporting the other elements of our risk management program. We also use this information directly to ensure that our equipment is suitable for its intended use.
We maintain the process safety information for regulated substances in a covered process, including:
* Toxicity information
* Permissible exposure limits
* Physical data
* Reactivity data
* Corrosively data
* Thermal and chemical stab
We maintain process technology information, including:
* Block flow or simplified process flow diagram
* Process chemistry
* Maximum intended inventory
* Safe upper and lower limits for parameters such as temperature, pressure, flow or composition
* Evaluation of the consequences of deviations from established operating limits
Most of this information comes from the engineering design documents for the processes, but in some cases, we have developed such information through special projects. We also maintain the following information pertaining to equipment in our regulated processes (as well as for many of our non-regulated processes):
* Materials of construction
* Piping and instrument diagrams (P&IDs)
* Electrical classification
* Relief system design and design basis
* Ventilation system design
* Design codes and standards employed
* Material and energy balances for processes built after 6/21/99
* Safety systems (interlocks, detection or suppression systems)
ain, most of this information comes from the engineering design documents for the processes as well as 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.
We use process hazard analyses (PHAs) to systematically identify, evaluate and control process hazards. The most important products of our PHAs are recommendations for reducing the most significant risks of accidental chemical releases. We ensure that recommendations from our PHAs are resolved appropriately, and we ensure that information from our PHAs (including recommendation resolutions) is communicated to all potentially affected employees.
We conduct systematic PHAs of our regulated 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 process hazards, the numb
er of potentially affected 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 PHAs of new regulated processes before those processes are placed in service.
We primarily use a variety of techniques to perform PHAs, using techniques that are appropriate for specific applications. We conduct our PHAs consistent with the procedures presented in the American Institute of Chemical Engineer's (AIChE's) Guidelines for Hazard Evaluation Procedures - Second Edition with Worked Examples, or other generally accepted guidelines(such as Dupont's), and address the following:
* Hazards of the process
* Identification of any previous incident that had a potential for catastrophic consequences
* Engineering and administrative controls applicable to the hazards and their interrelationships
* Consequences of failure o
f engineering and administrative controls
* Stationary source (plant) siting
* Human factors
* Qualitative evaluation of a range of the possible safety and health effects of failure of controls
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. PHAs are summarized in a written report soon after the analysis meetings are completed. The PHA team and our managers review and resolve the PHA recommendations after receiving the report. We maintain an action plan tracking system including the resolution status of each recommendation, an individual responsible for resolving each reco
mmendation and a target completion date. We document the final resolution of each recommendation.
We use operating procedures to define how process-related job tasks assigned to our personnel should be performed to avoid incidents. We use these procedures to (1) train our employees before they perform tasks in the field, (2) serve as reference guides for personnel performing tasks, and (3) specify what to do if a process upset or operating emergency occurs.
Our process engineers, operators and shift supervisors work together to develop and maintain our operating procedures for all phases of operations including:
* Initial startup
* Normal operations
* Temporary operations
* 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 manner
* Emergency operations
* Normal shutdown
* Startup following a turnaround or aft
er 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 following information:
* Steps for safely conducting activities
* Safe operating limits
* Consequences of process deviations, as well as steps required to correct or avoid such deviations
* 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 hazards
* Safety systems and their functions
In addition to our process-specific procedures, we also develop and maint
ain more widely applicable safe work practices addressing issues such as lockout/tagout, confined space entry, opening process equipment or piping and control of access to processes. These safe work practices apply to our employees and our contractors.
We have a formal review process to approve procedures and changes to procedures. We annually audit existing procedures and certify the procedures as current and accurate. In addition these procedures are reviewed every three years to ensure they reflect current operating practice. We keep our procedures in locations that are readily accessible to employees who may need the procedures.
We train our employees to safely perform their assigned tasks. Our training program includes initial training as well as training updates when major process/equipment changes are made. As part of our training, we include provisions for ensuring that employees understand the training (written tests, field demonstrations, etc.).
We provide our oper
ators with training, which includes a general overview of the process, properties of process chemicals, and safety and health hazards, as well as a detailed understanding of the process operating procedures and safe work practices. We provide 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 chemical-specific training. Our refresher training courses emphasize process overview information and safe work practices. Our operators are consulted at safety meetings on the frequency of refresher training, and their input is considered when preparing training schedules.
Employee training is accompanied by some form of evaluation to verify that our training is understood. We use a combination of physical demonstratio
n of skills, oral reviews using a one-on-one format, and written tests. Training is documented and includes the employee's name, date of training, and the means used to verify that the employee understood the training.
We maintain the mechanical integrity (MI) of our process equipment using an inspection and testing program and a quality assurance program, and we ensure that our equipment is designed and installed correctly so that it operates properly. We train our maintenance personnel in the hazards of the process, and we also provide additional training on procedures for maintaining the ongoing integrity of our process equipment so that job tasks are performed safely.
We consider 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. Examples include:
* Pressure vessels and storage tanks
* Piping systems including valves
* Relief and vent systems and devices
* Controls such as monitoring devices, sensors, alarms, and interlocks
Our MI program uses equipment surveillance and preventive maintenance activities to identify equipment that needs repair or replacement before failure occurs. We document inspection, test, and preventive maintenance activities including:
* Date of inspection, test, or preventive maintenance
* Person performing the activity
* Equipment identifier
* Description of the activity performed
* Results of the activity (including any deficiencies noted)
We have a program that addresses new facilities, equipment, maintenance materials, and spare parts. Our program seeks to verify proper fabrication of new equipment, proper installation of new or repaired/replaced equipment, and use of suitable maintenance materials and spare parts in the preventive maintenance and repair tasks.
We have a comprehensive training program covering MI issues. Our program uses the procedures described previously.
For example, mechanics, maintenance supervisors, and maintenance engineers are trained on hazards for RMP-covered processes and on safe work practices. Our maintenance personnel also receive training on safe maintenance procedures, preventive maintenance practices, and special skills requiring craft certification. Training, as described above, occurs before employees perform tasks in RMP-covered areas independently.
We evaluate and approve proposed changes (i.e., modifications that are not replacements in kind) to covered process chemicals, technology, equipment prior to implementation through our management of change (MOC) program. This program helps ensure that inadvertent or unintended changes are prevented, that any safety and health impacts are addressed, that affected procedures are updated, and that our employees and contract employees are informed of and trained in the approved changes. We use this close scrutiny of all changes to help ensure that changes do not adversely im
pact employees, public safety, or the environment.
We analyze each proposed change and confirm that:
* The technical basis for the change is appropriate
* The safety and health impacts of the change are understood and appropriate controls are in place
* The procedures are modified as appropriate for the change
* The permissible time period is established for temporary changes
* Appropriate personnel authorize the change
Our MOC procedure contains a step-by-step description of the confirmation process. When approved changes require updates to our process safety information and/or operating procedures, we revise these documents and train employees.
We perform a pre-startup review as a final check to ensure the safety of a new or modified covered process before it is placed in service. We perform pre-startup reviews (with the aid of a prepared checklist) on new or modified processes when the modification is significant enough to require a change in the process safety information.
Our pre-startup review confirms that:
* Construction and equipment are in accordance with design specifications
* Safety, maintenance, operating, and emergency procedures are in place and are adequate
* PHAs have been performed on new covered processes and all recommendations have been resolved
* MOC requirements have been satisfied for modified covered processes
* Training has been completed (and documented) for affected employees
We audit our RMP-covered processes to be certain that our prevention programs are effective. Our compliance audit program seeks to confirm that RMP prevention program practices for the covered process are consistent with written programs, that the programs adequately address all requirements of the RMP regulations, and that management systems are in place to ensure continued compliance.
We conduct and certify compliance audits of the prevention programs for RMP-covered processes at least every three years. We integrate these audits into OSHA PSM compl
iance 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. The audit team collectively possesses the following skills and knowledge:
* Ability to understand the prevention program requirements of the RMP regulation (49 CFR Part 68)
* Capability to conduct interviews and collect audit data
* Capability to document audit results
* Knowledge of the process to be audited
Our audit team members receive training in RMP regulatory requirements, interview techniques, and methods for data collection before participating in an audit. They use a protocol that contains questions that systematically address RMP rule requirements. The team leader assigns each auditor specific RMP elements to cover. Information obtained through field observations, interviews, and document reviews is documented, and weaknesses are identified. At the conclusion of the audit, our audit team prepares a report th
at identifies any specific issues that need to be addressed.
We have a plant management committee that promptly reviews the audit findings, determines an appropriate response for each finding, assigns responsibility for corrective action implementation, and assigns a target completion date. The corrective actions are placed in a tracking system and progress is monitored until open issues are resolved. We retain the most recent audit report.
We perform incident investigations to help ensure that incidents with significant impacts are thoroughly investigated, root causes are identified and corrected, and relevant findings are communicated throughout our organization to help prevent a recurrence.
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:
* At least one person knowledgeable in the process or activity involved
* A contract employee if the incident or near miss incident involved the contractor's work or impacted a
* Others with appropriate knowledge and skills to thoroughly investigate and analyze the event
We train our investigation team leaders in investigation techniques. The investigation 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:
* Date and time of the event
* Date and time the investigation started
cription of the event
* Identification of contributing factors
* 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 routing a copy of the approved report to potentially affected employees (and contract employees) and by discussing the event at the next safety meeting. We retain incident reports for at least five years.
Our employee participation plan helps ensure that all employees have appropriate involvement in developing and implementing RMP.
We have a written employee 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 peri
odically update this document as changes occur. We consult with the employees and their representatives on ways to improve participation in the RMP. Periodically, in our safety meetings, we review results of PHAs and resolutions of their recommendations.
We use our hot work permit program to ensure that OSHA's fire prevention and protection precautions, specified in 29 CFR 1910.252(a), are in place before hot work (work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operation) begins on or near an RMP-covered process.
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 Hot 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 train all employees who may use or enforce a hot work permit activity. New employees are trained on the hot work permit procedure as pa
rt of the safe work practices orientation. Our Shift Supervisors audit completed Hot 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.
We have a contractor screening procedure to help ensure that we hire and use only contractors who accomplish the desired job tasks without compromising the safety and health of our plant employees, the public, or the environment. 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.
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 experience, regulatory 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. We provide a safety orientation to familiarize contractors with the type of operations and associated hazards in the areas in which they will be working. We show a videotape that describes (1) the plant's hazardous chemicals, including toxic, fire/explosion, physical, and chemical properties, (2) safe work practices in use at our facility, and (3) actions they must take in the event of a plant emergency. We provide copies of our Contractor Safety Manual, which contains plant safety rules/policies, safe work practices, a material hazards summary, and an outline of emergency actions for contractors. We provide MSDSs 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 that our contractors train each of their employees on our plant's safe work practices and that each of their employees follows our plant safety rules and safe work practices. We also require that the contractor report to our staff any hazards created or found by their employees at the job site.
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.
Emergency Response Plan
We maintain an Emergency Response Plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergenc
y situations. Furthermore, we coordinate our plan with the community emergency response plan.
Data Elements Overview
The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows:
* Offsite consequence analysis
* Five-year accident history
* Program 3 prevention program
* Emergency response program