Trico Products Corporation - Executive Summary |
|
The Trico Products accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. The Trico Products emergency response policy involves the preparation of a response plan that is tailored to each facility and to the emergency response services available in the community. The policy adheres to EPA Prevention Program procedures where applicable, and is in compliance with EPA Emergency Response Program requirements. The Trico Products facility is located at 1995 Billy Mitchell Boulevard, Brownsville, Cameron, Texas. The sintering furnace operation utilizes anhydrous ammonia in its processes. 43,500 pounds of anhydrous ammonia are located in a single tank on the north side of the property. The container has manual shutoff valves in case of an emergency. An emergency air supply and power are available. The facility is manned 24-hours a day. The anhydrous ammonia processes are checked routinely throughout the day. Self-contained-breathing-apparatus (SCBA) are stored strategically throughout the facility. The offsite consequence analysis for the Water treatment includes consideration of two different release scenarios for each of the parameters of concern (anhydrous ammonia): 1) A "Worst Case Release"; and 2) an "Alternative Scenario". The "Worst Case Release" is defined by EPA guidance which states that "the owner or operator shall assume that the ... maximum quantity in the largest vessel... is released as a gas over 10 minutes," due to an unspecified failure. The Alternative Scenario is defined as "more likely to occur than the worst-case release scenario." Atmospheric dispersion modeling has to be performed to determine the distance traveled by a parameter of concern before its concentration decreases to the "toxic endpoint". The toxic endpoints are defined by the EPA as 0.14 ppm for anhydrous ammonia. These values correspond to the Emergency Response Planning Guidelines Level 2 (ER PG-2) concentrations which are defined by the American Industrial Hygiene Association (AIHA) as: "The maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one-hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protection action." The estimated population potentially affected by the release is defined as the residential population within a circle with a radius corresponding to the toxic endpoint distance. The Worst Case Release Scenario at the Trico Products facility was defined by the following conditions: Failure of the single container resulting in the total release of 43,500 pounds of anhydrous ammonia; Release of the entire amount as a gas in 10 minutes; Use of the one-hour average ERPG-2 as the toxic endpoint; Consideration of the population residing within a full circle with radius corresponding to the toxic endpoint dist ance; and EPA mandated meteorological conditions, specifically an F atmospheric stability class, wind speed of 1.5 m/sec, and air temperature of 771F. Atmospheric dispersion modeling for the Worst Case Release scenario resulted in a ammonia endpoint distance of 2.3 miles and an estimated residential population potentially affected of 50,986. The calculations were performed with the CAMEO and RMPComp32 models as provided by USEPA and NOAA. The affected population was estimated through Tiger and Landview III information. The Alternative Release Scenario at the Trico Products facility was defined by the following conditions: Failure of transfer hose connected to the container resulting in the total release of 43,500 pounds of anhydrous ammonia; Release of the entire amount as a gas in 30 minutes; Use of the one-hour average ERPG-2 as the toxic endpoint; Consideration of the population residing within a full circle with radius corresponding to the toxic endpoint distance; and EPA manda ted meteorological conditions, specifically a D atmospheric stability class, wind speed of 3 m/sec, and an air temperature of 771F. Atmospheric dispersion modeling for the Alternative Release scenario resulted in a anhydrous ammonia toxic endpoint distance of 0.3 miles and an estimated residential population potentially affected of 867. The calculations were performed with the CAMEO and RMPComp32 models as provided by USEPA and NOAA. The affected population was estimated through Tiger and Landview III information. Placement of the anhydrous ammonia in separate holding tanks was strongly considered but not feasible due to the amount of pressure that has to be maintained in the processes. Enclosure of the tank in a separate building or covered was also considered but not feasible. The Trico Products accidental release prevention program is based on the following key elements. Strong adherence to Process Safety Management; High level of training of the operators; Preventive maintena nce program; Use of state of the art process and safety equipment; Use of accurate and effective operating procedures, written with the participation of the operators; Performance of a hazard review of equipment and procedures; Implementation of an audit and inspection program. Chemical specific prevention steps include availability of self contained breathing apparatus (SCBA) and Level A and B protective clothing, and awareness of the hazardous and toxic properties of anhydrous ammonia. No accidental releases of anhydrous ammonia have occurred in the past five years. The facility has an emergency response program which has been coordinated (reviewed) by the City of Brownsville's Fire and Police Departments. Both of these entities are members of the Cameron County Local Emergency Planning Committee (LEPC). The program includes an emergency response decision tree and a notification plan. Emergency response drills and drill evaluations, and emergency operation and response proc edures are reviewed annually. |