LaRoche Industries Inc. - Executive Summary |
|
General Executive Summary for LaRoche Industries Inc. - Palmerton, PA Distribution Center 1. Accidental Release Prevention and Emergency Response Policies We at LaRoche Industries 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 and Aqueous Ammonia to customers via trailers (and very few cylinders) . We have 2 regulated substances present at our facility. These substances include Ammonia (anhydrous) and Ammonia (aqueous) both of which are sold to customers. The maximum inven tory of Ammonia (anhydrous) at our facility is 8160000.00 lb. while Ammonia (aqueous) is present at our facility in a maximum quantity of 106994.28 lb. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), 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 Anhydrous Ammonia Storage. In this scenario 160000 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 distanc e of 5.6 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario for Ammonia (conc 20% or greater) involves a release from Aqueous Ammonia Storage. The scenario involves the release of 3074 lb. of aqueous 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), deluge system(s) and emergency shutdown system(s). Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (conc 20% or greater) is 0.31 miles. The alternative release scenario for Ammonia (anhydrous) involves a release from Anhydrous Ammonia Storage. The scenario involves the release of 4422.47 lb. of anydrous 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), deluge system(s) and emergency shutdown system(s). Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.31 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. 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 comprehensive studies to ensure that hazards associated with our pro cesses 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 05/12/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, LaRoche Industries Inc. 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. 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 and 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, 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 procedures are in place at LaRoche Industries Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 01/15/1999. 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. 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. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 06/09/1998. These audits are carried out at least every 3 years and any corrective actions required as a re sult of the audits are undertaken in a safe and prompt manner. Incident Investigation LaRoche Industries Inc. promptly investigates any incident that has resulted in, or could reasonably 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 corrective actions to prevent the release from reoccurring. 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 created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in 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 of the contractor is carried out. LaRoche Industries Inc. 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. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, the number of accidental releases has been reduced to a minimum. There have been 2 accidental releases of regulated substances from our facility within the last 5 years. The first release took place on 03/25/1997 and involved 0.13 lb. of Ammonia (conc 20% or greater). No deaths or injuries occured offsite as a result of this accident. Onsite, there w ere no deaths or injuries. Another release, of 2 lb. of Ammonia (anhydrous), occurred on 04/01/1998. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths or injuries. 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 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. Carbon County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and veri fied. 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. Some of the major steps we are taking to improve safety at our facility include installation of ammonia sensors and a fogging system. |