LaRoche Industries, Baltimore - Executive Summary |
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1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES We at LaRoche Industried Inc. 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 Distribution of Anhydrous Ammonia to customers via trailers. We have 1 regulated substance present at our facility. This substance is Ammonia (anhydrous) which is sold to customers. The maximum inventory of Ammonia (anhydrous) at our facility is 160,000 lbs. 3. THE WORST CASE AND ALTERNATIVE RELEASE SCENARIOS. The worst case release scenario and the alternative release scenario, includes 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 RMP Comp program. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for our Program 3 RMP involves a catastrophic release from an 80 ton ammonia rail car. In this scenarion 160,000 pounds 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 4.4 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenarion for Ammonia (anhydrous) involves the release from a broken loading hose during an ammonia transfer operation. In this scenarion 100 pounds of ammonia is released into the atmosphere. The ammonia is assumed to be released to form a pool 1 cm deep 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 valves and emergency shutoff procedures and systems. At class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of .1 mile is obtained corresponding to a toxic endpoint of 0.14 mg/L. 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 RMP regulation. The following sections briefly describe the elements of the release prevention program that is in place at our Baltimore location. PROCESS SAFETY INFORMATION -- LaRoche Industries Inc. maintains a detailed record of safety information that de scribes the chemical hazards, operating parameters and equipment designs associated with our reloading process at the Baltimore facility. PROCESS HAZARD ANALYSIS -- Our facility conducts comprehensive studies to ensure that hazards associated with our processes are indentified and controlled efficiently. The methodology used to carry out these analysis is the HAZOP. 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 hazardous analysis are addressed in a timely manner. The most recent PHA/update was performed on 05/05/00. OPERATING PROCEDURES -- For the purposes of safely conducting activities within our covered procces, LaRoche Industries Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, normal shutdown and startup after a turaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. TRAINING -- LaRoche Industries Inc. 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 an more frequently as needed. MECHANICAL INTEGRITY -- LaRoche Industries Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, piping systems, pressure relief 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 procedures are in place at LaRoche Industries Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of mainenance procedures was performed on 02/17/2000. 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-START 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. These reviews are concucted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing into operation. COMPLIANCE AUDITS -- LaRoche Industries Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being impl emented. The most recent compliance oudit was conducted on 05/05/00. The 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 promptly investigates any incident hat has resulted in, or could reasonable result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrcective actions to prevent the release from re-occuring. All reports are retained for a minimum of 5 years. EMPLOYEE PARTICIPATION -- LaRoche Industries Inc. 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 resulting from process hazard analysis i n particular. CONTRACTORS -- On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance is carried out. LaRoche Industries Inc. has a strict policy of informing the contractors of known potential hazards related to the contraactor'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. has had an excellent record of preventing accidental releases. Due to our stringent release prevention policies, there has been no accidental release of ammonia from the Baltimore facility during the past 5 years. 6. EMERGENCY RESPONSE PLAN LaRoche Industries Inc. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergen cy response including adequate first aid and medical treatment, evacuations, notifications 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. The Baltimore County Fire Department (LEPC) is the local response agency 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 improvemtns to our accidental release prevention program. Ammonia rail car security is being evaluated in light of recent EPA publications. Modifications to the Baltimore training program are expected by the end of the year. |