LaRoche Industries Inc. - Seneca Works - Executive Summary

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General Executive Summary for 
LaRoche Industries Inc. Seneca Works - Morris, IL 
1.    Accidental Release Prevention and Emergency Response Policies 
We at LaRoche Industries Inc. - Seneca Works are strongly committed to employee, public and environmental safety.  This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 
2.    The Stationary Source and the Regulated Substances Handled 
Our facility's primary activities encompass the production of Nitric Acid, Industrial Grade Ammonium Nitrate, Ammonium Nitrate Solution, and Nitric Acid Blending.  We have 3 regulated substances present at our facility. These substances include 98% Nitric Acid, Ammonia (anhydrous) and Nitric oxide  [Nitrogen oxide (NOX)].  T 
he quantity of Nitric Oxide stored onsite is below the regulatory threshold, and therefore does not require risk management planning.   98% Nitric Acid is used in the acid blend operations to produce different grades of acid.  Ammonia is used to produce ammonium nitrate. 
The maximum inventory of Ammonia is 1,142,756.76 lbs, and the maximum inventory of 98% Nitric Acid is 289,688.00 lbs NA. 
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s)  
These scenarios include administrative controls and mitigation measures to limit the distances for each reported scenario.  To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Ammonia Storage.  In this scenario 160,000 lb. of Ammonia (anhydrous) 
is released.  The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to evaporate over 10 minutes.   At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 14 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. 
The alternative release scenario for Ammonia (anhydrous) involves a release from Ammonia Storage.  The scenario involves the release of 4,750.00 lb. of anhydrous ammonia.  Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to have evaporated after 10 minutes.  The release is also assumed to be controlled by excess flow valve(s).  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.62 miles. 
The alternative release scenario for 98% Nitric acid involves a release from Nitric Acid Blend.  The scenario involves the release of 1 
3,500 lb. of nitric acid over 90 minutes.  Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to have evaporated after 10 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.026 mg/L of 98% Nitric acid is 0.87 miles. 
4.    The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.    The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
Process Safety Information 
LaRoche Industries Inc. - Seneca Works maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Process Hazard Analysis 
Our facility conducts compre 
hensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is Checklist, What If/Checklist (combined), HAZOP and Fault Tree.  The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update was performed on 10/27/1998. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, LaRoche Industries Inc. - Seneca Works maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved in  
the processes. 
LaRoche Industries Inc. - Seneca Works has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes.  Refresher training is provided at least every year and more frequently as needed. 
Mechanical Integrity 
LaRoche Industries Inc. - Seneca Works carries out highly documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes among others: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written proced 
ures are in place at LaRoche Industries Inc. - Seneca Works to manage changes in process chemicals, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 10/28/1998.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at LaRoche Industries Inc. - Seneca Works.  The most recent review was performed on 06/24/1998.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
LaRoche Industries Inc. - Seneca Works conducts audits on a regular basis to determine whether the provisions s 
et out under the RMP rule are being implemented.  The most recent comliance audit was conducted on 09/14/1998.  These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
LaRoche Industries Inc. - Seneca Works promptly investigates any incident that has resulted in, or could reasonably result in a release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
Employee Participation 
LaRoche Industries Inc. - Seneca Works truly believes that process safety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to  
all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  LaRoche Industries Inc. - Seneca Works has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
5.    Five-Year Accident History 
LaRoche Industries Inc. - Seneca Works has had an excellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, no accidental RMP releases have occurred in the past five years. 
It should be noted that LaRoche did 
have emissions of nitric oxide gases (NOx) in August 1997, which did not violate the plant air permit but created a large visible orange plume.  Unusual weather conditions were the primary contributing factors to the intensity of the plume.  Under the RMP guidelines, we do not exceed the threshold quantity for  NOx, although we are including the release as part of our RMPlan. 
6.    Emergency Response Plan 
LaRoche Industries Inc. - Seneca Works carries a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced.  In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes 
that would require a modified emergency response. 
Grundy County ESDA is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
7.    Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program.  Our facility is continuously improving safety elements to meet and exceed standard industry practices and procedures.
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