Royster-Clark Nitrogen, North Bend Plant - Executive Summary |
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See Attached File Executive Summary Royster-Clark Nitrogen - North Bend, OH A. Introduction: The Royster-Clark Nitrogen facility in North Bend, OH purchases anhydrous ammonia and brings it into the plant by barge line and rail car. Ammonia is burned over precious metal gauze and converted into nitric acid. Additional ammonia is reacted with nitric acid to make ammonium nitrate. The urea is brought in by truck or rail car and blended with ammonium nitrate to make a solution of urea and ammonium nitrate with 28% total nitrogen. The facility has storage and shipping capability for all of its final products. Sales from this facility are from nitric acid, anhydrous ammonia, aqua ammonia, ammonium nitrate, and fertilizer solutions, which are mixtures of ammonium nitrate and urea. B. Accidental Release Prevention and Record: The Royster-Clark Nitrogen North Bend facility has an excellent safety rec ord with no deaths or serious injuries to plant personnel or contractors since it was constructed in 1965. In addition, the plant has operated without a lost time accident for over 16 years, and over 1,228,000 man- hours. There have been no RMP reportable releases of toxic chemicals in the last 5 years. C. Accidental Release Prevention Policies and Program: As part of the management system for Process Safety Management, a plant wide computer system is utilized which incorporates maintenance and process safety. Computers located in strategic locations are used to access plant files for P&ID drawings, operating procedures, Management of Change (MOC) documents, and other pertinent documents. This system is used to provide our employees with the necessary tools and records for process safety requirements. It plays an integral part in the safety efforts of this plant. In addition, plant personnel and full time contractor personnel routinely participate in monthly safety meetings and the DuPont STOP safety audit program. Royster-Clark Nitrogen believes safety and concern for the environment must be second nature to all employees and full time contractor personnel. z Each plant employee or permanent contractor is trained to be familiar with the Emergency Response policies and procedures through safety reviews and plant safety meetings, The Emergency Response Plan is reviewed on an annual basis as part of the employee and full time contractor safety meetings to ensure refresher training. The corporate environmental policy is also reviewed at this time once a year. z The Royster-Clark Nitrogen North Bend facility management requires the Emergency Response Plan be followed in the event of an emergency. The emergency alarm system is tested twice each month and an emergency drill is held four times a year. z Local LEPC and Miami Township Fire Department personnel are furnished a copy of th e Emergency Response Plan each time it is revised. In addition they are furnished copies of the Tier II document showing the chemicals stored on site, location, and quantities stored. z Plant personnel participate in local emergency drills conducted by LEPC and Miami Township Fire Department personnel. z This plant participates in a local Community Advisory Panel composed of representatives from the plants on Brower Road, a group of community people including elected officials from the local communities, local school personnel, citizen representatives, and Miami Township Fire Department personnel. Plant personnel also attend the Greater Cincinnati Alliance for Chemical Safety meetings held monthly. General Accident Release Prevention Program Steps: Accident release prevention steps include the fourteen elements OSHA's Process Safety Management program, a management system, and corporate oversight of the facility. Royster-Clark Nitrogen works closely with industry and government groups and local emergency response personnel. z 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 documents, the availability of process safety information via networked computers to all employees, participation in Process Hazard Analyses, and periodic employee training. Royster-Clark Nitrogen has an employee participation plan that documents many other ways employees are involved in accident prevention and process safety. z 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. z 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. z 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. z Royster-Clark Nitrogen has a comprehensive system to manage changes to the processes. This system requires that process changes be 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 effected personnel receive training on the change. D. Worst Case Scenario: This facility operates an anhydrous ammonia storag e tank below capacity to provide vapor space to allow for liquid expansion. The tank is equipped with multiple levels of safeguards including three safety relief valves and a flare system to prevent tank overpressure. 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: "Because 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 be likely 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 extremely unlikely because of the routine testing, in plant safety systems, daily inspections, and constant monitoring. E. Anhydrous Ammonia Alternative Scenario: Several alternative release scenarios were evaluated by Royster-Clark Nitrogen. The most likely release scenario would involve a release of hot anhydrous ammonia from a pressure relief valve on the ammonia vaporizer bottle in the nitric acid pla nt. This part of the process involves anhydrous ammonia under elevated temperatures and pressures. This alternative scenario results in offsite consequences. As part of our Process Safety Management System, we have in place inspection and other measures intended to ensure the integrity of our process. Specifically, the process equipment is inspected on a regular basis. F. Aqua Ammonia Alternative Release Scenario: Several possible aqua ammonia release scenarios were evaluated but the diked loading operation was selected as the scenario since it involves use of hoses and truck connections. This alternative scenario results in offsite consequences. G. Nitric Acid Alternative Release: This facility brings 98% concentrated nitric acid in by truck. The strong acid is immediately diluted with product acid to 83-84%. No acid is stored above 85% strength. The loading operation was selected as the alternative scenario because this is the only time 85% or hi gher strength acid is in the plant. Standard unloading procedures and equipment checks are in place to reduce the possibility of an incident. This alternative scenario results in offsite consequences. H. Five Year Accident History: The Royster-Clark Nitrogen North Bend facility has not had an RMP reportable accident or an EPA reportable quantity release of anhydrous ammonia, aqua ammonia, or nitric acid in the last five years. We believe the policies and programs in place at our facility will help us to maintain our record in the years ahead. I. Emergency Response: This facility works closely with the local fire departments and LEPC. Personnel from the plant have participated in local emergency drills with the local fire departments and LEPC both on site and at neighboring plants. A total of seven employees is trained to a 40-Hour Incident Commander Level in HAZWOPER response and attends annual refresher courses. In addition, personnel from th is plant regularly attend Cincinnati area Alliance for Chemical Safety meetings and are active in this organization. The facility Emergency Action Plan covers accidental releases of plant chemicals, natural disasters, emergency response practices and procedures, and process safety topics. The plan is reviewed each year with all employees. J. Summary The plant safety record is the direct result of much emphasis on safety in the plant on the part of plant management, employees, contractors, and truck drivers. Royster-Clark Nitrogen is proud of its safety record and believes the policies and programs in place will ensure continued safety excellence. |