Dyno Nobel, Inc. - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies Dyno Nobel, Inc. owns and operates an ammonium nitrate manufacturing facility in Louisiana, Missouri. At this facility, ammonia is used as a raw material to make nitric acid. Nitric acid is sold as a product and is also used as a raw material later in the ammonium nitrate process. Ammonia and nitric acid are considered hazardous by the EPA. Certain safety precautions in handling ammonia and nitric acid are necessary in order to prevent unnecessary human exposure, to reduce the threat to our employees' health, and to reduce the threat to nearby members of the community. These safety precautions are dependent upon the manner in which we handle ammonia and nitric acid combined with the safety devices inherent in the design of this facility and the training of our personnel. It is the policy of Dyno Nobel to comply with all applicable federal, state and local environmental and safety laws and regulations, and to conduct i ts business in an environmentally sound manner that avoids any unreasonable adverse impact on the environment or the neighboring community. In keeping with this policy, Dyno Nobel has developed and implemented a risk management program to ensure the safety of its employees and the neighboring community. The risk management program includes procedures (1) to identify potentially hazardous chemicals at the facility, (2) for maintaining a safe working environment that helps prevent the accidental release of hazardous chemicals, and (3) for minimizing the consequences of an accidental release should one occur. Stationary Source and Regulated Substances Handled This facility produces nitric acid, ammonium nitrate liquid, and ammonium nitrate prill. The major processes at this facility include storage of materials, weak nitric acid production, nitric acid concentration (NAC), nitric acid blending, production of ammonium nitrate in liquid and solid form, and product handling. RMP regu lated chemicals handled by this facility are anhydrous ammonia and both 83% and 98% nitric acid. Ammonia is delivered to this facility via an underground pipeline. It is stored in seven high-pressure storage tanks. Most of the ammonia is sent to the ammonia oxidation process for use as a raw material to produce 56% nitric acid. A portion of the 56%nitric acid is further concentrated to 98% nitric acid. The remainder of the 56% nitric acid is neutralized with ammonia to produce ammonium nitrate solution. Ninety-eight percent nitric acid is stored in four storage tanks. A containment dike surrounds these storage tanks. The amounts of both ammonia and 98% nitric acid stored on site exceed the RMP threshold quantities and both chemicals are subject to OSHA's Process Safety Management (PSM) regulations. For these reasons, both chemicals are subject to the RMP Program 3 requirements. Worst-Case and Alternate-Case Release Scenarios Worst-Case The worst-case release scenario, by def inition, is the maximum amount of ammonia or nitric acid that could be released from a storage tank over a period of 10 minutes. The off-site consequence of each of these scenarios was evaluated. It was determined that an ammonia release would have a greater impact than a nitric acid release. The maximum amount of anhydrous ammonia that could be released is 458,000 pounds, 80% of the capacity of one of the storage tanks. (The facility does not fill the tank past this point.) Under this scenario, the distance to the toxic endpoint using EPA's RMP* Comp model is estimated at 12 miles. Alternate-Cases The first alternate-case release scenario is defined as a release from a relief valve in the ammonia storage system. The ammonia release rate is estimated at 20 pounds per second. Under this scenario, the distance to the toxic endpoint using EPA's RMP* Comp model is estimated at 0.6 miles or 3168 feet. This release has the possibility of extending beyond the facility's plant bounda ry. The second alternate-case release scenario is defined as a spill of 98% nitric acid while loading a tank truck. A nitric acid release of 1900 pounds is estimated as an amount that could spill before the operator discovers the spill. This scenario is based on an incident that occurred in 1996. To determine the maximum impact, active mitigation measures were not considered in this scenario. Under this scenario, the distance to the toxic endpoint using EPA's RMP* Comp model is estimated at 0.2 miles or 1056 feet. This release has the possibility of extending beyond the facility's plant boundary. General Accidental Release Prevention Program and Specific Prevention Steps This facility is subject to both EPA's Accidental Release Prevention program and OSHA's Process Safety Management (PSM) program. Under both of these programs, the facility has outlined specific procedures that it follows to prevent or minimize the release of ammonia and nitric acid to the environment. Specif ically, the facility has performed process hazard analyses (PHA) of the anhydrous ammonia system and nitric acid process and will repeat this process at least every 5 years. The purpose of the PHA is to provide a systematic approach for identifying, evaluating, and controlling potential hazards associated with the ammonia system and nitric acid process. Should a significant change in the anhydrous ammonia or nitric acid systems be made, Dyno Nobel will perform a new PHA and will modify the RMP to reflect the change as appropriate. The off-site consequence analysis will be redone if deemed necessary. The facility has numerous administrative and engineering controls to prevent releases of hazardous chemicals. In addition, the facility regularly performs training of its employees to ensure that the procedures developed for the safe use and handling of the ammonia and nitric acid are adhered to at all times. Five Year Accident History This facility has had two releases of nitric ac id that caused property damage. In the first, a tank truck was damaged during loading. During the second event, a compressor was damaged. Other details are provided in section 6 above. Other small releases of ammonia and nitric acid have occurred over the past 5 years. These smaller releases did not however, result in any significant injuries or property damage, either on-site or off-site, and are not reported in section six of this RMP. Emergency Response Program This facility has an emergency response program, labeled as "Emergency Control and Crisis Communication Plan", a document that has been developed in coordination with the Pike County Local Emergency Planning Committee (LEPC) and has been incorporated into the LEPC's emergency planning and response procedures. The emergency response plan includes procedures for notification of the local fire authority and notification of any potentially affected neighbors. Various detection systems such as process monitoring and contr ol instrumentation with alarms are in place if a release should occur. This facility has an in-house emergency response team that has the equipment and training necessary to respond effectively to an accidental release of ammonia or nitric acid. Planned Changes to Improve Safety The facility has recently changed the anhydrous ammonia system and nitric acid process for safety or other reasons. Other controls will be installed on the ammonia tanks. Since the ammonia system and nitric acid process are regulated under OSHA's Process Safety Management Program, they will be subjected to regular process hazard analyses reviews for the purpose of identifying and implementing potential improvements. |