The Ensign-Bickford Company - Spanish Fork, UT - Executive Summary
EXECUTIVE SUMMARY |
The Ensign-Bickford Company - Spanish Fork, UT
1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
At The Ensign-Bickford Company, Spanish Fork, Utah, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:
7 A description of our facility and use of substances regulated by EPA's RMP regulation
7 A summary of results from our assessment of the potential offsite consequences that could be associated with accidental chemical releases
7 An overview of our accidental release prevention programs
7 A five-year accident history for accidental r
eleases of chemicals regulated by EPA's RMP rule
7 An overview of our emergency response program
7 An overview of planned enhancements at the facility to further prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment
7 The certifications that EPA's RMP rule requires us to provide
7 The detailed information (called data elements) about our risk management program
2 STATIONARY SOURCE AND REGULATED SUBSTANCES
Our facility produces pentaerythritoltetranitrate (PETN) and pentolite cast boosters using various chemicals and processing operations. Concentrated nitric acid is used in the manufacture of PETN. TNT is melted and PETN is dissolved in the TNT to form pentolite which is poured into molds to make cast boosters.
In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release:
c Acid (concentration 3 80%)
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.
3 KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information from our study of the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:
Worst-Case Release Scenario - Regulated Toxic Chemicals
We have reviewed our process and have determined our potential worst-case release scenario to be represented by a catostrophic failure of a full railcar storing concentrated nitric acid. The maximum quantity delivered by railcar to our facility is 240,000 pounds. The worst-case scen
ario assumes, for purposes of this RMP study, that the entire contents of the vessel is instantly released to the ground followed by volitization into the air. The worst-case release dispersion is required to be evaluated at wind speeds of 1.5 meters per second (3.3 miles/hour) and atmospheric stability class F. Only passive mitigation measures (i.e. those measures that function without human, mechanical, or other energy input) may be considered to operate to minimize the effects of the release. Given the constraints of the worst-case scenario model, the estimated exposure distance, as determined using the EPA's RMP Offsite Consequence Analysis Guidance, is 17 miles.
The Ensign-Bickford Company utilizes both active and passive mitigation systems to limit the potential for a catostrophic event such as this to occur. Our active mitigation systems, which were not used in determining the outcome of the worst-case scenario, include routine inspections of storage vessels containing
concentrated nitric acid to inspect for evidence of structural defects before a release occurs; managerial and inventory controls that limit the frequency of deliveries of concentrated nitric acid and the length of time full railcars are sited at the facility; trained in-house emergency response teams, equipped with personal protective equipment, that respond to a release and neutralize the released acid; yearly response drills coordinated with local emergency response personnel (including city fire department and HAZMAT Team); and on-site equipment that can be employed to create dams, dikes and berms that contain the potential spread of material and improve neutralization and recovery efforts.
Alternative Release Scenario - Regulated Toxic Chemicals
The RMP Rule also requires a facility to evaluate alternative release scenarios. These scenarios involve a study of an event which would be more likely to occur than the worst-case scenario, and must produce an endpoint off-site. These
scenarios may include: transfer hose releases due to splits or sudden hose uncoupling; failures at flanges joints, or welds; vessel over flow and spill or overpressurization; and shipping container mishandling or breakage.
We have evaluated our processes and determined that a transfer hose release from a faulty gasket flange at the rail car is a reasonable alternative scenario for evaluation. For purposes of this study, a total of 95 gallons of concentrated nitric acid (~ 1,200 lbs) is released before the source of the release is stopped. The estimated exposure distance associated with this alternative release scenario, as determined using the EPA's RMP Offsite Consequence Analysis Guidance, is 0.18 miles.
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases.
Worst-Case Release Scenario- Regulated Flammable Chemicals
Alternative Release Scenario - Re
gulated Flammable Chemicals
The Ensign-Bickford Company does not store any RMP regulated flammable chemicals over threshold quantities.
4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We maintain a number of programs to help prevent accidental releases and ensure safe operation. The accident prevention programs in place include:
+ Process Safety Management
- Written Process Specifications
- Process Hazard Analysis
- Employee Participation
- Compliance Audits
+ LEPC Coordinated Emergency Response Drills
+ Active and Passive Mitigation Systems
These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting o
ur own high standards for accident prevention.
5 FIVE-YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at our facility. The Ensign-Bickford Company has had four accidental releases of nitric acid in the past five years; the largest release was 95 gallons, the other three were 10 gallons or less. None of the accidents have resulted in either:
7 Deaths, injuries, or significant property damage on-site, or
7 Deaths, injuries, evacuations, shelterings-in-place, property damage, or environmental damage offsite.
For each of these incidents, we have conducted formal incident investigations to identify and correct the root causes of the events and taken appropriate actions to minimize the potential for repeat incidents.
6 EMERGENCY RESPONSE PROGRAM
We maintain a site-specific Emergency Action Plan, which consolidates the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the
essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan, provide LEPC emergency response training that is specific to our facility, conduct emergency response drills which include off-site responders and invite local emergency responders (Spanish Fork City Fire Department) to yearly HAZWOPER training.
7 PLANNED CHANGES TO IMPROVE SAFETY
The Ensign-Bickford Company regularly reviews, and audits the processes to minimize the potential for accidental chemical releases, with modifications being made as needed. The following are some of the enhancements that we are considering to implement at the facility to help prevent and/or better respond to accidental chemical releases:
7 Improved access and storage of neutralizing agents
7 Improved visual controls and signage of PPE required areas
The undersigned certifies th
at, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true accurate, and complete.
9 RMP DATA ELEMENTS
The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows:
7 Offsite Consequence Analysis
7 Five-year Accident History
7 Prevention Program
7 Emergency Response