Tomah Products, Incorporated - Executive Summary

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Risk Management Plan 
EPA Facility I.D. -  
The Tomah Products, Inc. Milton Plant is committed to operating in a manner that is safe for the Milton Plant workers, the public, and the environment.  As part of this commitment, the Milton Plant has established a system to help ensure safe operation of the processes at this facility.  One part of this system is a risk management program (RMP) that helps manage the risks at the Milton Plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMP) describing the risk management program at the Milton Plant.  This document is intended to satisfy the RMP requirements of the RMP rule and to provide the public with a description of the risk management program at Tomah's 
Milton Plant. 
The purpose of the Risk Management Program is two-fold. First of all, it evaluates the consequences of incidents that could occur or the quantity of a release required to have an off-site impact.  Secondly, it has a systematic prevention program which is designed to prevent these potential incidents from occurring.  
1.1    Accidental Release Prevention and Emergency Response Policies 
Tomah's Milton Plant is committed to the safety of the plant's workers and of the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances.  The Tomah, Milton Plant implements controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, our trained personnel will respond to minimize such releases. Tomah's Milton Plant evaluates each situation, evacuates workers as necessary, and coordinates with the local emergency planning committee (LEPC).  In the unlikely event that we w 
ould have a release, we have an internal and external emergency warning system to notify our workers and/or the community. 
1.2 The Tomah3 Products Inc., Milton Plant and Regulated Substances 
Tomah's  Milton Plant handles seven substances regulated by the RMP rule in sufficient quantities to be covered by the RMP rule: 
7 Acrylonitrile is used to prepare intermediate products that are then converted to finished amine products.  It is one of the basic building blocks which is incorporated into nearly all of our finished products. 
7 Ethylene Oxide (EO) and Propylene Oxide (PO) are used to produce specialty products called alkoxylated amines or tertiary amines.  These alkoxylated amines are used in industrial, institutional and agricultural products. 
7 Methyl chloride is used to prepare other specialty surfactants.  Methyl chloride quaternizes the alkoxylated products (it makes the products carry a positive charge).  These materials are used as emulsifiers and cleaning agents. 
7 Ammonia 
is used in the production of amines to minimize side reactions.   It is subsequently recovered in the ammonia recovery system, which forms ammonia water and ammonium phosphate.  
7 Ammonia water is formed when we recover the ammonia used in the process. 
7 Hydrogen is used to hydrogenate nitriles to amines that are used in iron mining, fuel additives and further reacted to other surfactants. 
As a result of the use of regulated substances at Tomah's Milton Plant, the following processes are covered by the RMP rule: 
Program Level     
Regulated Substances    Process Inventory, lbs. 
Acrylonitrile storage/processing    3    Acrylonitrile    190000 
Ethylene oxide storage/processing    3    Ethylene oxide    190000 
Propylene oxide storage/processing    3    Propylene oxide    45,000 
Methyl chloride storage/processing    3    Methyl chloride    230,000 
Hydrogen storage/processing    3    Hydrogen    10,500 
Ammonia storage/processing    3    Ammonia    10,000 
Ammonia water formation    3    Ammonia water > 20%    80000 
1.3  Offsite Consequence Anal 
Tomah's  Milton Plant performed an offsite consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance to affect the public or the environment.  The OCA consists of evaluating both worst-case scenarios (WCS) and alternative release scenarios (ARS).  The  Milton Plant does not expect a worst-case release scenario to ever occur. ARS represent a release that might occur during the lifetime of a facility like the Milton Plant.  ARS help Tomah and the LEPC improve the community emergency response plan. 
The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance).  The following effects could occur at the endpoint distance.  At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effects would be less. 
o    When considering the release of a toxic sub 
stance, most people at the endpoint distance would be able to walk away from the exposure without any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely.  Some people who are particularly susceptible to the substance released could be incapacitated. 
' When considering flammable substances, an over-pressurization of 1 psi is the endpoint.  This pressure may cause partial demolition of houses and shattered glass, and may cause injury to people. 
Worst-case Release Scenarios 
The worst-case release scenario for toxic substances is a catastrophic failure of the regulated substances storage tank.  The released material evaporates, forming a vapor cloud.  The maximum distance to the toxic endpoint is based on using the EPA look-up tables. This scenario assumes all controls, including the acrylonitrile secondary containment tank fail. 
The worst case scenario for release of a flammable substance means the total quantity of  
the flammable substance forms a vapor cloud within the upper and lower flammability limits and the cloud is assumed to detonate.  As a conservative assumption, 10 percent of the flammable vapor in the cloud is expected to participate in the explosion.  For Tomah Products this scenario involves the delivery truck containing 6,000 pounds hydrogen. 
Regulated substance    Distance in miles 
Acrylonitrile--Toxic    14 miles 
Hydrogen--Flammable    0.2 miles 
Alternative Release Scenarios 
When performing the ARS the EPA requires each facility to consider the results of PHA's and the 5-year accident history when selecting the ARS.  Additionallly, we performed  a search for all reportable releases of these chemicals over the past 5 years to evaluate the likelihood and quantities of chemicals likely to be released to the environment.  The EPA RMP regulation requires one ARS to be evaluated for each process.  Tomah Products has gone beyond this requirement to evaluate potenti 
al off-site impacts from many aspects associated with the use of these chemicals.  
The releases presented here have been evaluated for planning purposes.  The RMP regulation specifically requires facilities to analyze scenarios that have off-site impact.   The purpose of this requirement is to evaluate in advance the degree of impact certain release quantities would have on the community and what type of response-either shelter in place or evacuate is required to protect the community.  In addition, for some processes where more reasonable scenarios do not have an off-site impact, we have used scenario development to determine what magnitude of release is required to have an off-site impact. These releases, though they probably never will occur, help us to improve our systems in the event we need to respond to an emergency. 
For many of the scenarios presented here, an air dispersion model called Aloha was used.  This model was selected for the following purposes: The Rock County Loc 
al Emergency Planning Committee uses this model for planning purposes and during incidents.  The model estimates the concentrations of chemicals at selected distances outside and indoors which aids in the determination of whether evacuation or sheltering in place is an appropriate response. 
Alternate Release Scenario (ARS) for Ethylene Oxide and Ammonia 
Scenario:  Storage tank gasket or valve leak 
Quantity:  2,300 lb./hr Ethylene Oxide 
                     886 lb./hr Ammonia - This release rate based on the following: 
7 0.1 inch thick leak in a gasket seal or valve 
7 This is a very high estimate compared to release reports over the past 5 years.  The average release from a storage tank is 100-200 pounds.  This release rate was estimated to determine what type of 1 hour release would have an off site impact. 
' Duration:  1 hour 
'  Assumed that area sensor will detect ethylene oxide, alarm operators and automatic shut down systems will shut down processes. 
' A one hour time frame is  
estimated for the time to respond and repair the leak. 
Alternate Release Scenario (ARS) for Propylene Oxide, Methyl Chloride, Ammonia and Ethylene Oxide 
Scenario:  A leak occurs in a gasket on a reactor processing the material.   
Quantity:  3,500 # Methyl Chloride 
                      500 # Ammonia 
                      200 # Ethylene Oxide 
                       200 # Propylene Oxide- This release rate is based on the following: 
' Incidents on similar equipment in our industry 
' Estimated 3 inch by 0.1 inch gasket leak  
' Gasket leaks on equipment have the highest incident rate 
Duration:  10 minutes for ethylene oxide and propylene oxide 
                    1 hour for methyl chloride 
' Duration assumes that plant personnel will identify the cause of the release and shut down the flow and vent the reactor to the cryogenic condenser.  Processes using ethylene oxide and propylene oxide vent very quickly.  Processes using methyl chloride take approximately 1 hour to vent. 
Alternate Release Scenario (ARS) for Acrylonitrile, Methyl Chloride and Ethylene Oxide 
Scenario:  Either a plug forms or level gauges fail allowing the cryogenic condenser to fill with liquid.  When a reactor is vented to the system the liquid is pressurized through the stack.  This scenario assumes either a level gauge control valve or pressure differential control fails. 
Quantity:  1000 # Methyl Chloride 
                      200 # Ethylene Oxide 
                       500 # Acrylonitrile- This release rate based on the following: 
' Maximum capacity of condenser and maximum amount likely to be released. 
' Average composition of condensate 
' Assumption that one or more automatic controls fail  
Duration:  10 minutes  
' High pressure in the condenser will turn off the flow to the condenser, stopping the release.  Since the materials are liquefied, 10 minutes is the estimated time for vaporization. 
Alternate Release Scenario (ARS) for Acrylonitrile, Propylene Oxide 
ario:  A transfer hose or pump unloading the material leaks.  The material pools to the ground and evaporates over time.  No recovery or mitigation using water spray is assumed to model the release although it is part of our emergency response procedures. 
Quantity:  1,000 # Acrylonitrile 
                     500 # Propylene Oxide- This release rate based on the following: 
' Pump unloading rate 
' Leak involves a partial tear in an unloading hose 
7 This is a very high estimate compared to release reports over the past 5 years. This release rate was estimated to determine what type of release would have an off site impact. 
Duration:  1 hour  
' These materials are liquids and pool and evaporate. 
' Estimated time to identify and fix leak 
Alternate Release Scenario (ARS) for Ammonia Water 
Scenario:  A transfer hose leaks.  The material pools to the ground and evaporates over time.  No recovery or mitigation using water spray is assumed to model the release although it is part of ou 
r emergency response procedures. 
Quantity:  2,000 # 30% Ammonia Water 
- This release rate based on the following: 
' Pump unloading rate 
' Leak involves a partial tear in an unloading hose 
Duration:  12 minutes 
' These materials are liquids and pool and evaporate. 
Alternate Release Scenario (ARS) for Hydrogen 
Scenario:  A leak occurs in a flange or valve on a reactor or line containing hydrogen.  The leaking hydrogen is ignited by a welder in the area. 
Quantity:  41 lbs/min 
- This release rate based on the following: 
' Regulated line pressure 
' Reasonable size of leak area 
Duration:  10 Minutes 
' Estimated time to shut off the source of hydrogen and put out the fire. 
Using the scenarios, release rates and duration's as described above, the Milton Plant determined the end point distances for the ARS as follows: 
Regulated substance    Distance in miles/feet    Off Site Alarm 
Ethylene Oxide (EO)-Storage tank gasket leak    .23 miles    Shelter In Place 
Ammonia -Storage tank valve leak    .06 miles    Shelter In Place 
Ammonia-Reactor gasket leak    .03 miles    Shelter In Place 
Ethylene Oxide (EO)-Reactor gasket leak    .14 miles    Shelter In Place 
Propylene Oxide (PO)-Reactor gasket leak    .06 miles    Shelter In Place 
Methyl Chloride--Reactor gasket leak    .09 miles    Shelter In Place 
Propylene Oxide-Pump seal or hose leak    .08 miles    Shelter In Place 
Ethylene Oxide-Pump seal failure    .15 miles    Shelter In Place 
Acrylonitrile-Transfer pump leak    .01 miles    None 
Acrylonitrile-Transfer hose leak    .09 miles    Shelter In Place 
Acrylonitrile-Cryogenic Condenser Malfunction    .07 miles    Shelter In Place 
Ethylene Oxide-Cryogenic Condenser Malfunction    .17 miles    Shelter In Place 
Methyl Chloride-Cryogenic Condenser Malfunction    .12 miles    Shelter In Place 
Hydrogen    .06 miles    Shelter In Place 
The RMP requires census block data be used to determine the affected population for these scenarios.  Many of these scenarios only impact one or two adjacent businesses whose employees are not  
accounted for on census maps.  We have included the employees of these businesses in our population estimates. 
1.4  Accidental Release Prevention Program and Chemical-specific Prevention Steps 
The following is a summary of the general accident prevention program in place at the  Tomah  Milton Plant.  Because the process at the Milton Plant is regulated by the EPA RMP regulation and is also subject to the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. 
Employee Participation 
The Tomah  Milton Plant encourages employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation include: 
7 Participation in safety committees and safety audits 
7 Monthly safety meetings and training 
7 Development and review of operating and maintenance pro 
7 Hazard and Operability studies 
7 Direct consultation with supervisors or management 
Employees have access to all information created as part of the Tomah  Milton Plant accident prevention program.   
Process Safety Information 
The Tomah  Milton Plant keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, the technology of the process, 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) and other technical bulletins. The Milton Plant ensures that the process is maintained within these limits by using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown  
Process Hazard Analysis 
Tomah's Milton Plant has 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 Milton Plant primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations.  HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques.  The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary or that these measure would improve operability.  All action items in r 
esponse to PHA team findings are tracked until they are complete.  
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Milton Plant 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 results and findings from these updates are documented and retained.   Action items are tracked until they are complete. 
Operating Procedures 
The Tomah  Milton Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process.   Operating procedures include information on safe handling of our hazardous materials.  These procedures can be used as a reference by experienced 
operators and provide a basis for consistent training of new operators.  Procedures are periodically reviewed and annually certified as current and accurate.  Procedures are maintained current by revising them as necessary to reflect changes.   
To complement the written procedures for process operations, Tomah's  Milton Plant has implemented a company training program for all employees involved in operating a process.  New employees receive "front-end" training in the  Milton Plant operations.  This training heavily emphasizes the safety, health and environmental systems and procedures that pertain to the site and the employee's job.  After successfully completing this training, a new technician is paired with a senior technician to learn process-specific duties and tasks.  Additionally, a comprehensive, independent-study program is required.  This training program includes more specific details on safety and job-related tasks.  After technicians demonstrate (e.g., through 
tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently.   Finally, monthly training sessions are provided which cover all regulatory training and other general subjects.  All of this training is documented for each technician, including the means used to verify that the operator understood the training. 
The Tomah  Milton Plant uses contractors to supplement its work force during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the Milton Plant has procedures in place to ensure that contractors:  
(1) perform their work in a safe manner,  
(2) have the appropriate knowledge and skills, 
(3)  are aware of the hazards in their workplace,  
(4)  understand what they should do in the event of an emergency, 
(5)  understand and follow site safety rules, and  
(6)  inform Milton Plant personnel of any hazards that they fin 
d during their work.  
This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work.  In addition, the Milton Plant evaluates contractor safety programs and performance during the selection of a contractor.  Contractors are trained at least annually and must pass a test to work at the Milton site. 
Pre-startup Safety Reviews (PSSRs) 
The Tomah  Milton Plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information.  The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service.  This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready.  
The PSSR review team uses checklists to verify all aspects of readiness. 
Mechanical Integrity 
The Tomah  Milton Plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps, and emergency shutdown systems in a safe operating condition.  The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures.  In combination, these activities form a system that maintains the mechanical integrity of the process equipment. 
Maintenance personnel receive training on (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 job in a safe manner.  Written procedures help ensure that work is performed in a cons 
istent manner and provide a basis for training.  Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels).  If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service.  If the deficiency cannot be corrected the equipment will be replaced or removed from service. 
Another integral part of the mechanical integrity program is quality assurance.  The Milton Plant incorporates quality assurance measures 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 
The Tomah  Milton Plant has long-standing safe work practices in place to help ensure worker and process safety.  Examples of these include (1) control of access to process areas, (2) a lockout/ 
tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space, and (6) over 40 other general safety procedures.  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 
Tomah's  Milton Plant has a comprehensive system to manage changes to processes.  This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented.  Changes are reviewed to (1) ensure that adequat 
e controls are in place to manage any new or existing 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 are provided with any necessary training on the change. 
Incident Investigation 
The Tomah  Milton Plant promptly investigates 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.  In fact, we investigate all incidents or potential incidents, however minor.  The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident.  The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results  
to Milton Plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete.  The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.  
Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the Tomah  Milton Plant 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 3 years.  Both hourly and management personnel participate as audit team members.  The audit team develops findings that are forwarded to the  Milton Plant management for 
resolution.  Corrective actions taken in response to the audit team's findings are tracked until they are complete.  The final resolution of each finding is documented, and the two most recent audit reports are retained.   
Chemical-specific Prevention Steps 
The processes at the Tomah  Milton Plant have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all Program 3 EPA RMP-covered processes at the Milton Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. 
In addition to the accident prevention program activities, the Milton Plant 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 process: 
Release Detection 
o    Process alarms 
e Containment/Control 
o    Cryogenic condenser to control and recover chemical releases 
o    Valves to permit isolation of the process (manual or automated) 
o    Automated shutdown systems for specific process parameters (e.g., high level, high temperature, high pressure, etc.) 
o    Curbing or diking to contain liquid releases 
o    Redundant equipment and instrumentation 
o    Safety relief devices 
Release Mitigation 
o    Fire extinguishing systems   
o    Trained emergency response personnel 
o    Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 
1.5  Five-Year Accident History 
Tomah Products has had three reportable releases over the past 5 years.  No releases of any regulated substances have occurred from the Tomah  Product's Milton Plant in the last 5 years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site. As a mater of co 
mpany policy, plant personnel were evacuated until the nature and scope of the incidents could be determined. 
1.6  Emergency Response Program 
Tomah  Milton Plant has established a written emergency response plan, , which is in place to protect worker and public safety as well as the environment . This plan has been communicated to local emergency response officials through the Local Emergency Preparedness Committee (LEPC) and the Milton Fire Department.  Regular dialogue is maintained between the Milton Plant and the LEPC. 
The Milton Plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department).  Also, the emergency warning sirens provide a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.  In addition to periodic LEPC meetings, the Milton Plant conducts periodic emergency drills that involve the LEPC and emergency response organization 
1.7  Planned Changes to Improve Safety 
The Tomah  Milton Plant constantly strives to improve the safety of  the Milton Plant processes through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers.  The Milton Plant resolves all findings from Process Hazard Analyses (PHAs), some of which result in modifications to the process.  In the spirit of continuous improvement, the following types of changes are planned during the next 5 years: 
o    Revised process instrumentation and/or controls in the process area 
o    Revisions to personnel training programs 
o    Revised written operating procedures  
7 Additional monitoring devices for early detection of releases
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