El Dorado Nitrogen Company - Executive Summary |
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Executive Summary El Dorado Nitrogen is a1265 ton/day nitric acid plant that was commissioned in April 1999. Since it is a new facility there is very little historical data to report. 1.0 Accidental Release Prevention and Emergency Response Policies At El Dorado Nitrogen Company, we are committed to operating and maintaining all of our processes (especially those involving hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public, as well as protection of the environment. El Dorado Nitrogen Company maintains an open dialogue with primary emergency responders. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including the following: A description of our facility and use of substances exceeding threshold quantities, in a single process, which are r egulated by EPA's Risk Management Planning (RMP) Regulation. A summary of results from our assessment of the potential off-site consequences from possible accidental chemical releases. An overview of our accidental release prevention programs. A accident history for accidental releases of chemicals regulated by the RMP rule, since the plant was commissioned which indicates there were no incidents. An overview of the Emergency Response Program. The certifications that EPA requires us to provide, with regard to RMP. The detailed information (called data elements) about our Risk Management Program. 2.0 Stationary Source and Regulated Substances Our facility's primary activity involves the production of nitric acid. This product is used in the agricultural and specialty chemical manufacturing industries. In our processes, we use the following chemicals in the threshold quantities that EPA has identified on the RMP Toxic Substances List: TOXIC SUBSTANCES Anhydrous Ammonia As this document will help illustrate, our accidental release prevention programs and our emergency response planning efforts help us effectively manage any potential hazards posed by these substances. 3.0 KEY OFF-SITE CONSEQUENCE ANALYSIS SCENARIOS The following is a brief summary of the worst case and alternate release scenarios, including information about exposure distances, determined from EPA's Off-Site Consequence Analysis Guidance Tables. WORST CASE - AMMONIA: The worst case release scenario submitted for Program 3 toxic substances as a class involves the ammonia surge vessel. This vessel will be inspected on a scheduled basis utilizing an ultra-sonic testing method, which verifies the mechanical integrity of the tank. The vessel is carbon steel and designed for 360 psig MAWP. It is normally operated at 140 psig. The worst case was developed using Class F atmospheric stability (1.5 m/s wind speed conditions) and does not account for a ny active mitigation measures. Furthermore, we have not experienced an ammonia release from this vessel since initial startup. Related data is as follows: Release Rate - 1,380 lbs./min Duration of Release - 10 minutes Meteorology - 25 degrees C / 50% RH (Class F) Off-Site Consequence - 1.5 miles Toxic Endpoint - 0.14 mg/l ALTERNATE CASE - AMMONIA: This alternate case scenario involves a release from a pressure relief valve in an ammonia evaporator. Release Rate - 90.8 lbs./min Duration of Release - 26 minutes Meteorology - 25 degrees C / 50% RH (Class D) Off-Site Consequence - 0.1 miles Toxic Endpoint - 0.14 mg/l 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL - SPECIFIC PREVENTION STEPS El Dorado Nitrogen Company maintains a number of programs to help prevent accidental releases and ensure safe operation. Also, El Dorado Nitrogen Company parallels the RMP rule by complying with Process Safety Management (PSM) as required by OSHA in 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program that are in place at our stationary source. Process Safety Information El Dorado Nitrogen Company, Baytown, Texas, 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 process are identified and controlled efficiently. The m ethodology used to carry out these analyses is "HAZOP". These studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are validated at regular intervals. Findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purpose of safely conducting activities within our covered processes, El Dorado Nitrogen Company maintains written operating procedures. These procedures address various modes of operation such as initial start-up, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and start-up after a turn-around. The information is regularly reviewed and is readily accessible to operators involved in the process. Training El Dorado Nitrogen Company 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 for operator certification. Mechanical Integrity El Dorado Nitrogen Company carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Trained maintenance personnel and our maintenance manager conduct the process maintenance activities. 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 El Dorado Nitrogen Company to manage changes in process chemicals, technology, equipment, and procedures. Process Technicians, maintenance personnel, or any other employee whose job tasks are affected by a modification in process conditions are promptly trained, and are an integrated part of the change order process. Pre-startup Reviews Pre-start up safety reviews re lated to new processes and to modifications in established processes are conducted as a regular practice at El Dorado Nitrogen Company. These reviews are conducted to confirm that construction, equipment, and operating and maintenance procedures are suitable for safe start-up prior to placing equipment into operation. Compliance Audits El Dorado Nitrogen Company conducts audits on a regular basis to determing whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years by at least one person knowledgeable in the process and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation El Dorado Nitrogen Company promptly investigates any incident that has resulted in, or could reasonably result in, a release of a regulated substance. These investigations are undertaken to identify the root cause of the incident, as well as any corrective actions to prevent the release from recurring. All reports are retained for a minimum of 5 years. Employee Participation El Dorado Nitrogen Company 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. Contractor Training El Dorado Nitrogen Company uses contractors to conduct maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. We have a strict policy of informing the contractors of known potential hazards related to their work and the processes. A contractor work permit is issued prior to beginning work. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5.0 FIVE - YEAR ACCIDENT HISTORY El Dorado Nitrogen has had no RMP listed chemical releases since plant commissioned in April, 1999. 6.0 EMERGENCY RESPONSE PROGRAM El Dorado Nitrogen Company maintains an Emergency Response Plan, which is based on the EPA's Integrated Contingency Plan (ICP), consolidating all of the various Federal and State regulatory requirements for emergency response planning. The program provides the essential planning and training for effectively protecting the workers, the public, and the environment during emergency situations. Furthermore, coordination of the Plan with the Local Emergency Planning Committee (LEPC) is an integral part of the verification process. 7.0 PLANNED CHANGES TO IMPROVE SAFETY El Dorado Nitrogen Company is actively promoting public awareness and education programs concerning emergency response through the Baytown LEPC and Com munity Advisory Panel (CAP). This enhances the public's ability to respond in a given emergency situation. El Dorado Nitrogen Company continually strives to improve and upgrade operating procedures, replace or maintain equipment, and develop and implement safety improvement projects. 8.0 CERTIFICATION Based on the criteria in 40 CFR 68.185, I certify that to the best of my knowledge, information, and belief formed after reasonable inquiry, the Risk Management Plan information submitted is true, accurate, and complete. Signature: _____________________________________ Title: Plant Manager Date: _____________________________________ 9.0 RMP DATA ELEMENTS The following items present additional information about El Dorado Nitrogen Company's Risk Management Program that EPA has asked us to provide. Please reference the RMP Table of Contents for a specific page number for each respective data element listed as follows: Registration Off-Site Consequence Analysis Toxic: Worst Case Scenario - Anhydrous Ammonia Toxic: Alternate Release Scenario - Anhydrous Ammonia Five - Year Accident History Prevention Program - Program 3 Emergency Response Program |