The Ensign-Bickford Company - Graham, KY - Executive Summary
EXECUTIVE SUMMARY |
The Ensign-Bickford Company - Graham, KY
1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
At The Ensign-Bickford Company, Graham, KY, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning 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:
7 A description of our facility and use of substances regulated by EPA's RMP regulation
7 A summary of results from our assessment of the potential offsite consequences that could be associated with accidental chemical releases
7 An overview of our accidental release prevention programs
7 A five-year accident history for accidental releases of che
micals regulated by EPA's RMP rule
7 An overview of our emergency response program
7 An overview of planned enhancements at the facility to further prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment
7 The certifications that EPA's RMP rule requires us to provide
7 The detailed information (called data elements) about our risk management program
2 STATIONARY SOURCE AND REGULATED SUBSTANCES
Our facility consists of four distinct operations: the nitration plant, the detonating cord plant, the plastic bonded explosives (PBX) plant, and the multiple reaction facility (MRF). Our nitration facility produces pentaerythritoltetranitrate (PETN). The detonating cord plant produces cords containing PETN, cyclotrimethylene trinitramine (RDX) and other secondary high explosives. The PBX plant produces plastic bonded explosive products in various configurations (sheet, cord, cutting tapes, etc.) for both commercial and mili
tary applications. The MRF is designed to manufacture or process a wide variety of materials, generally in low-to-moderate quantities.
In our processes, we may have on site the following chemicals, in quantities greater than the RMP threshold amount, that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release:
Nitric Acid (concentration greater than 80%)
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.
3 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information from our study of 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 an
d mitigation measures to limit the exposure distances for each scenario:
Worst-Case Release Scenario - Regulated Toxic Chemicals
We have reviewed our process and have determined our worst-case release scenario is represented by a catastrophic failure caused by a detonation which releases the entire contents of the nitric acid (concentration > 80%) storage tank (located near the processing area). The maximum volume of nitric acid (concentration > 80%) storage tank is 9,500 gallons, however the maximum quantity that could potentially be stored in this tank is 6,650 gallons. This maximum inventory is administered by administrative controls and high level alarms. The quantity of nitric acid that would be released under this scenario is 83,000 pounds. The worst-case scenario assumes, for purposes of this study, the entire contents of the vessel is instantly released followed by volitization into the air. The worst-case release dispersion is required to be evaluated at wind speeds of
1.5 meters per second (3.3 miles per hour) and at an atmospheric stability class F. Only passive mitigation measures (i.e. those measures that function without human, mechanical, or other energy input), such as dikes, may be considered to operate to minimize the effects of the release. Given the constraints of the worst-case scenario, the estimated exposure distance, as determined using EPA's RMP Offsite Conssequence Analysis Guidance, is 7.9 miles.
The Ensign-Bickford Company utilizes both active and passive mitigation systems to limit the potential for a catastrophic event such as this to occur. Our active mitigation systems, which were not used in determining the worst-case scenario, include routine inspections of storage vessels for evidence of structural defects before a release occurs; managerial and inventory controls that limit the frequency of deliveries of concentrated nitric acid; trained in-house emergency response teams equipped with personal protective equipment that
can respond to a release and neutralize the released acid; and on-site equipment that can be employed to create dams, dikes and berms that can contain the potential spread of released material and improve neutralization and recovery efforts.
Alternative Release Scenario - Regulated Toxic Chemicals
The RMP Rule also requires a facility to evaluate alternative release scenarios. These scenarios involve a study of an event, which would be more likely to occur than the worst-case scenario, and must produce an endpoint off-site. These scenarios may include: transfer hose releases due to splits or sudden hose uncoupling; failures at flanges joints, or welds; vessel over flow and spill or overpressurization; and shipping container mishandling or breakage. Although several alternative release scenarios were evaluated, none of the scenarios could produce an off-site endpoint. Due to the distance to the nearest public receptor (approximately 4000 feet) an alternative scenario which produce
d an off-site endpoint would have to release atleast 1,000 gallons. A release of 1,000 or more is more likely to be a catastrophic release than a reasonable alternative release scenario.
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases.
Worst-Case Release Scenario- Regulated Flammable Chemicals
Alternative Release Scenario - Regulated Flammable Chemicals
The Ensign-Bickford Company does not store any RMP regulated flammable chemicals over threshold quantities.
4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We maintain a number of programs to help prevent accidental releases and provide safe operation. The accident prevention programs in place include:
+ Process Safety Management
- Written Process SpecificationsProcess Hazard Analysis
- Employee Participati
- Compliance Audits
+ Active and Passive Mitigation Systems
These individual elements of our prevention program work together to prevent accidental chemical releases. Our company 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.
5 FIVE-YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at our facility. The Ensign-Bickford Company has had 0 accidental releases of nitric acid in volumes greater than 5 gallons over the past five years. None of the accidents have resulted in either:
7 Deaths, injuries, or significant property damage on-site, or
7 Deaths, injuries, evacuations, shelterings-in-place, property damage, or environmental damage offsite.
6 EMERGENCY RESPONSE PROGRAM
We maintain a site-specific Emergency Action Plan, which c
onsolidates 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 public, and the environment during emergency situations. Furthermore, we have established coordination for emergency response and provided copies of our plan to local and county fire departments, medical facilities, police and public works.
7 PLANNED FACILITY ENHANCEMENTS
The Ensign-Bickford Company regularly reviews, and audits its RMP covered process to minimize the potential for accidental chemical releases, with modifications being made as needed. The following are some of the physical and organizational enhancements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases:
7 Increasing the dike capacity to completely contain contents of nitric acid process storage tank
7 A review of emergency response equipment,
including personal protective equipment, and neutralization materials, to improve response time to potential nitric acid releases.
The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true accurate, and complete.
9 RMP DATA ELEMENTS
The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows:
7 Offsite Consequence Analysis
7 Five-year Accident History
7 Prevention Program
7 Emergency Response