Toll processing

What are some of the issues that can arise during the tolling process ... 

The flowchart on the next page shows an overview of steps for the pre-startup and startup phases of a typical tolling process. 

For every new tolling situation a process hazard analysis should be conducted using one of several acceptable methodologies in common use. The goal is to select a methodology appropriate to evaluate the hazards of the toll process in question. 

If a toll process falls under the U.S. PSM or RMP regulations, it is a requirement to document the identity of the employee, the date of the training, and the means used to verify that the employee understood the training. Even when not required by regulations, this documentation will enable the toller to demonstrate a commitment to maintaining competent operating personnel. 

The PSSR team will confirm that the following requirements have been met before materials are introduced into the new or modified toll process. 

A PHA has heen performed for new facilities. The management of change documentation packages and referenced documents should indicate when a process hazard analysis was performed for the modification or new facility. The PSSR Team should verify all of the PHA recommendations have been implemented or otherwise resolved before the toll process can be judged ready to operate. 

Compliance Audits If a new toll process causes a toller s first experience with OSHA PSM or EPA RMP compliance, this... 

Some toll processes lend themselves to test runs in the pre-startup phase. Actual materials for the toll may be used in the test or substitute materials, typically with low hazard potential, are often used to simulate the charging, reaction, and physical changes to be accomplished in the toll. Flow control, temperature control, pressure control, mixing and transferring efficiency can be measured. Mechanical integrity can be verified in regard to pumps, seals, vessels, heat exchangers, and safety devices. 

When a test run is performed using the actual materials for the toll, it is a prime opportunity for the toller and the client to document the capability of the equipment, instrumentation, and process steps. During such a test, frequency of sampling may be increased, additional analyses performed and yield capabilities checked to find the optimum setpoints and timing for the toll process. Health, safety and environmental staff may choose to provide close coverage of the test run to evaluate areas for improvement during the actual startup and long term operation. 

These startup precautions should determine if a startup advisor or team from the client should be present for the initial startup and shake down operations. This is especially helpful if part of the toll involves technology or chemicals new to the toller s staff. Having someone nearby who may have prepared the technology package and run a pilot of the toll process can be very useful to the startup crew. 

An example of an audit guide that focuses on environmental, health, and safety inspections during the toll-processing phase is included as Appendix B, Sample Toller HS E Assessment. This example should be customized to meet specific needs by adding quality concerns or other processing related items. 

Whether or not a toller site or a specific ongoing toll process is covered under a regulatory mandate to manage changes, there is always a question of when to involve the client in day-to-day management of change (MOC) activities. 

Regulatory issues may arise throughout the duration of a tolling process. The type of issues experienced is dependent upon the mechanical aspects of the process, chemical makeup and quantity of the specific raw materials, intermediates, products, emissions and wastes. 

Figure 6.1 is a flowchart that shows a typical progression for closing a tolling process. 

It is a good practice to ensure that both the toller and client have records of the complete incident and accident history for the toll. This information can be vital to the industry as a database of experience with the tolled process. Process safety concerns for future tolls of the product or related materials can benefit from this practice. 

Were there any incidents (explosions, fires, releases, etc.) on the toll process or which affected the toll process. ... 

Technology package Information typically provided to a toller by their client delineating specifications for the equipment, chemicals, processing and quality control for a toll. Process safety information is a subset of the technology package. 

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