Micronutrients, Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Micronutrients, we are committed to operating and maintaining all of our processes in a safe and responsible manner. 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 use of Anhydrous Ammonia as regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * An overview of planned improvements at th e facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment STATIONARY SOURCE AND REGULATED SUBSTANCES Micronutrients Division of Heritage Technologies, L.L.C., located in Indianapolis, IN, manufactures Tri-Basic Copper Chloride(TBCC). TBCC is a low dust, free flowing insoluble powder used as a dietary source of copper for agricultural and pet food industries. Micronutrients employs a proprietary/patented process which utilzes copper bearing acidic and alkaline solutions to produce a copper based salt, TBCC, and an ammoniacal etchant solution used in printed circuit board manufacturing. Environmentally focused, this faciltiy maximizes the reuse concept of enviromental compliance. Current chemical engineering technology provides the foundation for the production process. Raw chemicals used in the process consist of anhydrous ammonia, carbion dioxide, hydrochloric acid, sodium hydrosulfide, incoming acidic/basic feedstock solutions and trace catalysts. Micronutrients is responsible for employee and environmental safety-- beginning to end. Micronutrients uses both safety equipment and facility engineering controls to prevent the release of anydrous ammonia and mitigate the impact of anhydrous ammonia should it occur. Several examples are the complete integration of Draeger Polytron II ammonia detectors through out the process facility, warning alarms and automatic relief/shutdown valves. Equipment inspections, incident invesigations, and routine audits round out the process safety. Micronutrients produces TBCC using a variety of chemicals and processing operations. The TBCC is used as a dietary supplement in animal feed. In our processes, we use Anhydrous Ammonia that EPA has identified as having the potential to cau se significant offsite consequences in the event of a substantial accidental release: Toxics Anhydrous Ammonia is stored in an above tank that holds 54,600 pounds. The ammonia is used in making the TBCC and formulated etchant. Micronutrients accidental release prevention program and contingency planning efforts help effectively manage the hazards that are posed to our employees, the public, and the environment by our use of Anhydrous Ammonia. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that Micronutrients provides information about the worst-case release scenario(s) and alternative release scenario(s) 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: Worst-case Release Scenario(s) - Regulated Toxic Chemicals Micronutrients stores Anhydrous Ammonia outside in an above ground tank that has a capcity of 54,600 pounds. The Worst-case Release Scenario would be a tank rupture. If the tank ruptured the Anydrous Ammonia plume would travel a distance of 2.6 miles from the facility. There were no administrative controls or mitigation measures considered for the Worst-case Release Scenario. Based on this information, there potentially would be offsite consequences to the public. Alternative Release Scenario(s) - Regulated Toxic Chemicals Micronutrients stores Anhydrous Ammonia outside in an above ground tank that has a capcity of 54,600 pounds. The Alternative Release Scenario would be a filling hose rupture. If the filling hose ruptured the Anydrous Ammonia plume would travel a distance of .2 miles from the facility. There are administrative controls and mitigation measures considered for the Alternative Release Scenario. The truck filling operator would shut the truck down and a water fogger would be used to mitigate the Anydrous Ammonia release. Based on this information, the re potenially would be offsite consequences to the public. Micronutrients is using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Micronutrients takes a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Micronutrients management systems address each of the key features of successful prevention programs including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of the Micronutrients prevention efforts, we have implemented the following Anhydrous Ammonia release prevention steps: 1. Employee training 2. Internal ammonia sensors with alarms 3. Pressure relief valves 4. Inspection and maintenance of equipment These individual elements of the Micronutrients prevention program work together to prevent accidental chemical releases. Micronutrients and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY Micronutrients will keep records for all significant accidental chemical releases that occur at our facility. To date, Micronutriens has not had a release of Anhydrous Ammonia off of the facilty property. EMERGENCY RESPONSE PROGRAM Micronutrients maintains a contingency 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 pu blic, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that Micronutrients plans to implement at the facility to help prevent and/or better respond to accidental chemical releases. 1. Installation of a water connection, hose, and fogger nozzle at the Anhydrous Ammonia tank location. 2. Requirement that 2 people will be present during all Anhydrous Ammonia tank filling activities. 3. Required installation of hydrostatic pressure relief valves throughout the plant Anhydrous Ammonia piping system. 4. Required installation of hydrostatic pressure relief valves throughout the plant Anhydrous Ammonia vent line system. 5. Required installation of redundant reverse flow check valve. All planned changes should be in place no later than August, 1999. |