Royster-Clark Nitrogen East Dubuque Facility - Executive Summary |
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Executive Summary Royster-Clark Nitrogen - East Dubuque, IL A. Introduction: The East Dubuque Royster-Clark Nitrogen facility manufactures nitrogen-based fertilizers, including ammonia, urea, and urea ammonium nitrate (UAN) solution. In addition, the facility manufactures granular urea fertilizer and a slow release fertilizer product. Industrial products manufactured at the East Dubuque facility include carbon dioxide, used for carbonation of soft drinks and for freeze drying vegetables, and nitric acid, used in the metal processing industry and the dairy industry for tank cleaning. B. Accidental Release Prevention and Record: The Royster-Clark Nitrogen East Dubuque facility has an excellent safety record with no deaths to plant personnel or contractors since it was constructed in 1965. In addition, the plant has operated without a lost time accident for over six months, and over three years prior to that incident. There ha ve been no RMP reportable releases of toxic chemicals in the last 5 years. C. Accidental Release Prevention Policies and Program: The Royster-Clark Nitrogen facility in East Dubuque has incorporated a safety vision that states, "We, the employees of Royster-Clark Nitrogen, utilize teamwork, communication, and education, with the full support of management, to achieve safety excellence." Royster-Clark Nitrogen employees utilize this vision statement as a reminder of the priority of achieving safety excellence. Employees are highly involved in creating and implementing safety programs and safety systems at the facility, with a focus on continuous improvement. Highlights of the Safety Program include: ? Extensive employee participation in the development, implementation, and review of safety systems and programs at the facility. All employees participate in an annual evaluation of the safety programs at the facility. ? A well developed extensive training program that ensures t hat employees are knowledgeable on the safety programs and their job duties. ? An excellent emergency response team is in place at the facility. Many of the employees on the emergency response team are also highly involved with the community volunteer fire and Hazmat teams. Several emergency response drills are held each year. In addition, the Royster-Clark Nitrogen emergency response team has responded to nearby incidents at the request of the community. ? Strong community relations are an important part of the facility's safety program. The facility has taken the lead in forming a Community Advisory Panel that assists in communications and awareness of the community on the safety and environmental safeguards of the facility. General Accident Release Prevention Program Steps: ? Royster-Clark Nitrogen encourages all employees to participate in all facets of process safety and accident prevention. Examples of employee participation include updating and compiling technical docum ents, networked computers that provide all employees instant access to up to date safety information, participation in Process Hazard Analyses, and continual employee training. ? Royster-Clark Nitrogen has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this system, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. ? Royster-Clark Nitrogen has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems. ? Training of plant personnel includes: (1) an overview of the process, (2) safety and health hazards, (3) emergency response plans, and (4) applicable safe work practices. ? Royster-Clark Nitrogen has a comprehensive system to manage changes to the processes. This system requires that process changes b e reviewed to ensure that adequate controls are in place to manage any new hazards, and verify that existing controls have not been compromised. Affected chemical hazard information, process operating limits, equipment information, and procedures are updated to incorporate these changes. In addition, all affected personnel receive training on the change. D. Worst Case Scenario: This facility operates anhydrous ammonia storage tanks. The tanks are equipped with multiple levels of safeguards including three safety relief valves and a flare system to prevent tank overpressure. In addition, there are two refrigeration compressor systems that maintain the pressure of the tanks and multiple instrumentation and control to monitor the process. This scenario results in offsite consequences. By law, the EPA requires the worst case scenario to be a catastrophic rupture of that tank with a compete loss of product over 10 minutes. EPA makes this statement about worst case scenarios: "Be cause the assumptions required for the worst-case analysis are very conservative, the results likely will be very conservative. These endpoints are concentrations below which it is believed nearly all individuals could be exposed for one half-hour to one hour without any serious health effects. In addition, the worst case analysis is carried out using very conservative assumptions about weather and release conditions. The distance to the endpoint estimated under worst-case conditions should not be considered a zone in which the public would likely be in danger; instead, it is intended to provide an estimate of the maximum possible area that might be affected in the unlikely event of catastrophic conditions. Distances greater than 10 kilometers (6.25 miles) are particularly uncertain. EPA intends the estimated distances to provide a basis for a discussion?rather than a basis for specific actions." Royster-Clark Nitrogen believes the chances for a catastrophic rupture are extremel y unlikely due to the routine testing, plant safety systems, daily inspections, and constant monitoring of the process. E. Anhydrous Ammonia Alternative Scenario: The alternative scenario chosen involves a release of anhydrous ammonia from loading a rail car. Multiple safeguards are in place to prevent this from occurring. These safeguards include: chocking of the railcars, isolating the rail cars, operating procedures, extensive training, and emergency response procedures. Royster-Clark Nitrogen is confident that this scenario is extremely unlikely to occur. This alternative scenario results in offsite consequences. F. Nitric Acid Alternative Release: This facility brings 98% concentrated nitric acid in by truck. The strong acid is immediately diluted as it is offloaded from the truck to 67%. No acid is stored above 70% strength. The loading operation was selected as the alternative scenario because this is the only time concentrated nitric acid is in the plant. Multip le safeguards are in place to eliminate the possibility of an incident. Royster-Clark Nitrogen is confident that this scenario is extremely unlikely to occur. This alternative scenario results in offsite consequences. G. Five Year Accident History: The Royster-Clark Nitrogen East Dubuque facility has not had an RMP reportable accident in the last five years. We are confident that the policies and programs in place at our facility will help us to maintain our record in the years ahead. H. Emergency Response: An excellent emergency response team is in place at the facility. Many of the employees on the emergency response team are also highly involved with the community volunteer fire and Hazmat teams. Several emergency response drills are held each year. The Royster-Clark Nitrogen emergency response team has responded to nearby incidents at the request of the county. Approximately thirty employees are currently on the facility's emergency response team. Training for thes e personnel is extensive. This training includes classroom instruction, hands on review of the equipment, and several drills each year. The facility's Emergency Action Plan covers accidental releases of plant chemicals, natural disasters, emergency response practices and procedures, and process safety topics. The plan is reviewed, at least annually, with all employees. I. Summary The plant safety record is the direct result of constant emphasis on continuous improvement. Royster-Clark Nitrogen is proud of its safety record and believes the policies and programs in place will ensure continued safety excellence. |