PCS NITROGEN FERTILIZER, L.P. CLINTON PLANT - Executive Summary |
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EXECUTIVE SUMMARY RISK MANAGEMENT PLAN (RMP) FOR PCS NITROGEN CLINTON PLANT JUNE 1999 FINAL DRAFT RISK MANAGEMENT PLAN TABLE OF CONTENTS Page EXECUTIVE SUMMARY 4 1.0 Accidental Release Prevention and Response Policies 5 1.1 Policy on the use of hazardous substances 6 1.2 Preventing accidental releases of the hazardous substances 6 1.3 Minimizing impact from an accidental release 6 1.4 Community Participation 7 2.0 Stationary Source and Regulated Substances Handled 8 3.0 Worst Case Scenario and Alternate Release Scenario Analysis 9 3.1 Worst Case Scenario - Toxic Substances (Anhydrous Ammonia) 9 3.2 Alternate Case Scenario - Toxic Substances (Anhydrous Ammonia) 9 3.3 Worst Case Scenario - Toxic Substances (29% Ammonia - Water Solution) 10 3.4 Alternate Case Scenario - Toxic Substances (29% Ammonia - Water Solution) 10 3.5 Worst Case Scenario - Flammable Substances 10 3.6 Alternate Case Scenario - Flammable Substances 10 3.7 Defining Offsite Impacts - Populations 10 3.8 Defining Offsite Impacts - Environment 10 4.0 Accidental Release Prevention Program 11 4.1 Process Safety Information 11 4.2 Process Hazard Analysis 12 4.3 Operating Procedures 12 4.4 Training 13 4.5 Mechanical Integrity 13 4.6 Management of Change 13 4.7 Pre-Startup Review 14 4.8 Compliance Audit 14 4.9 Incident Investigation 14 4.10 Employee Participation 14 4.11 Hot Work Permits 15 4.12 Contractors 15 5.0 5-year Accident History 16 6.0 Emergency Response Program 17 7.0 Planned Changes to Improve Safety 18 8.0 Processes not covered by the Rule 19 9.0 Certification 20 10.0 Review and Update 21 Risk Management Plan Executive Summary Potash Corporation of Saskatchewan, Inc. (PCS) and its three operating subsidiaries (Potash Division, Phosphates Division and Nitrogen Division) form an integrated fertilizer and related industrial and feed products company. PCS Nitrogen Division operates one of its seven U.S. plants in Clinton, Iowa (PCS Nitrogen, Clinton). T he facility, located at 3103 21st Street, Camanche, Iowa, has 114 employees and produces nitrogen based products such as ammonium nitrate and ammonia. The majority of PCS Nitrogen Clinton's production supports North American agriculture. Nitrogen is a requirement for every living cell. It is part of the genetic blueprints RNA and DNA, and needed by all plants and animals for proper nutrition and maturation. 1.0 ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES PCS Nitrogen Clinton is committed to operating the plant in a manner that is safe for its workers, our community and the environment. As part of this commitment, PCS Nitrogen Clinton has established a system to help ensure safe operation of the processes at the Clinton Plant. One component of this system is a risk management program (RMP) that helps manage the risks at the plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Preventi on Requirement Risk Management Programs (the RMP rule); and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119). This document is intended to satisfy the RMP Plan requirements of the RMP rule and to provide the public with a description of the risk management program at the Clinton, Iowa plant. The risk management program and the Clinton plant consists of the following three elements: 7 A hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) incidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances) 7 A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes) 7 An emergency response program to help respond to accidental releases of regulated substances from covered proce sses Information further describing these elements is provided in this RMP Executive Summary. Although the risk management program at the PCS Nitrogen Clinton plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety and environmental program for the plant. The plant has a comprehensive safety program in place, establishing many levels of safeguards against a release of a regulated substance. It is our policy to adhere to all applicable federal, state and local regulation, industry standards and best practices. To effectively implement these policies, PCS Nitrogen Clinton has established inter-disciplinary teams headed by the Safety Manager for PSM and the Environmental Manager for RMP. 1.1 Policy on the use of hazardous or regulated substances: Before using a hazardous substance, less hazardous alternatives are considered. When a hazardous substance is used, PCS Nitrogen Clinton considers the potential f or this substance which could adversely affect the plant workers, the public and the environment through the management of change and the process hazard analysis processes and takes steps to prevent any such effects. 1.2 Preventing accidental releases of the hazardous substances: PCS Nitrogen Clinton implements controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used, the equipment is carefully designed, built, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, installation and operation of the equipment. Each project is thoroughly reviewed before approval. In addition, PCS Nitrogen Clinton requires the documentation of standard operating procedures and the training of affected employees with regard to these procedures as part of the management of change process. PCS Nitrogen Clinton's mechanical integrity program provides an on going process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances. The Clinton Plant also participates in auditing processes to measure and enhance its prevention program. 1.3 Minimizing impact from an accidental release: In the event of an accidental release, the Clinton plant aggressively seeks to control and contain the release in a manner that will be safe for workers and will prevent impact to the public and the environment. PCS Nitrogen Clinton provides response training to its personnel, designates an emergency response coordinator to oversee response activities, conducts regular drills to review response activities and coordinates response efforts with area industry and the local emergency response agencies. The company maintains a well-trained, professionally equipped Emergency Response team made up of employee volunteers. PCS Nitrogen trains its workers to respond to an accidental release, reducing th e consequences of a release if it occurs. In addition, PCS Nitrogen works with the area industry, the local fire department and Local Emergency Planning Committee (LEPC) to help prevent injuries and/or environmental damage. Response activities have been discussed with the Clinton County Local Emergency Planning Committee and the Gateway Industrial Mutual Aid Council. 1.4 Community Participation The Clinton plant actively participates in and is committed to its Citizens Advisory Panel. The purpose of this group is to share information about plant operations with members of the community and to discuss their concerns. The group covers topics of interest to the members including plant safety and environmental performance, emergency response programs, health issues and process safety performance. Through this outreach effort, as well as other community involvement, the plant stays abreast of community concerns and works to address them. HEALTH, SAFETY & ENVIRONMENTAL POLICY As e mployees of PCS Nitrogen, we have the responsibility to manage our operations to protect human health and the environment. Sound health, safety and environmental practices are an integral part of our everyday job requirements. In recognition of this responsibility, we will correct any unsound health, safety and environmental practices or conditions or call them to the attention of those who will do so, as soon as they are identified. Specifically we will: 7 CONDUCT our operations in compliance with all applicable health, safety and environmental laws and regulations. 7 CONTINUE to improve our health, safety and environmental performance through the PCS Nitrogen Quality Improvement Process. 7 CONDUCT periodic assessments of our operations to ensure compliance and identify risks. 7 IMPLEMENT progressive health, safety and environmental practices that apply risk management and loss control principles to our operations. 7 ESTABLISH health, safety and environmental performance goal s and assign responsibilities for developing and implementing related measurement systems. 7 PROVIDE education and training regarding applicable laws, regulations, policies and procedures to protect human health and the environment. 7 COOPERATE with our neighbors, industry trade groups, governmental agencies, and others to develop effective, reasonable rules and regulations to protect human health and the environment. PCS Nitrogen's success depends upon our positive health, safety and environmental attitude and actions to achieve continuous improvement. 2.0 STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The PCS Nitrogen Clinton plant is located on a rural 350-acre site. The stationary covered sources consist of anhydrous ammonia and 29% ammonia - water solution process areas and support facilities. The feedstocks used are natural gas and hydrogen. All feedstock arrives at the facility by pipeline. The Clinton plant handles two regulated toxic substances in sufficient quan tity to be covered by the RMP rule and fall under the Level 3 Program. Regulated Flammable Substance Process Quantity, lbs. RMP Threshold, lbs. Hydrogen 3,002 10,000 Natural gas (CH4) 2,174 10,000 Regulated Toxic Substance Process Quantity, lbs. RMP Threshold, lbs. Anhydrous Ammonia 100 million 10,000 Ammonia Solution (29%) 219,014 20,000 3.0 WORST CASE AND ALTERNATIVE RELEASE SCENARIOS The Clinton, Iowa plant performed off-site consequence analyses to estimate the potential for accidental release of regulated substances. The RMP rule requires that the off-site consequences of an EPA-defined "worst case scenario" (WCS) and a more feasible "alternative release scenario" (ARS) be developed. To evaluate the worst case and alternative case scenarios, PCS Clinton utilized the EPA's RMP*Comp Version 1.06 software program and SLAB (an EPA-approved air dispersion mathematical model). As recommended by the EPA, the U.S. Bureau of Census' Landview program was used to estimate the number of people living within proximity to the PCS Clinton plant. U.S. Geological Survey maps were used to identify the public and environmental receptors located near the plant. 3.1 Worst Case Scenario - Anhydrous Ammonia: The worst-case scenario (WCS) with toxic substances under RMP Level 3 Program would be the simultaneous and instantaneous loss of all the anhydrous ammonia stored in the two on-site storage tanks. These two interconnected tanks have capacities of 30,000 tons and 20,000 tons respectively. Under this extremely unlikely scenario, it would be necessary for all trained employees to fail to respond to the emergency and do nothing, all operational standards would have to be violated, and all safety systems and back up systems would have to simultaneously fail or be overwhelmed. The result would be that all the liquid ammonia would pour out into the 256,000 square-foot, 12-foot high containment area. The ammonia would form a shallow pool that would begin to evaporat e. The release rate to the air is estimated by the RMP*Comp software as the evaporation rate of the pool. The end point for serious health effects is a concentration of 0.14 milligrams per liter of air. Under worst case weather conditions, the maximum distance to the end point is 7.2 miles. Although PCS Clinton has numerous controls to prevent such releases and to react to their consequences, including deployment of the on-site Emergency Response Team, no administrative controls were taken into account in evaluating this scenario. 3.2 Alternate Case Scenario - Anhydrous Ammonia: A more realistic scenario would be the loss of electricity to the ammonia refrigeration system servicing the ammonia storage tanks. The tanks are actually like large insulated Thermosd bottles. The result over a period of weeks would be a slow boil-off and controlled venting of ammonia vapors. On a summer day, assuming an ambient temperature of 1000F, the 20,000-ton ammonia tank would lose product at a rate of 11.3 pounds per hour. The 30,000-ton tank would slowly lose ammonia at a rate of 19.9 pounds per hour. For this scenario, it was conservatively estimated that the power outage would last for one full week. (Such an extensive outage has never occurred.) The distance to the endpoint using EPA's RMP*Comp is 0.1 mile, which is the approximate distance from the tank to the PCS Nitrogen north side fence line. 3.3 Worst Case Scenario - Ammonia 29% Solution in Water: The worst case scenario would be the total loss within 10 minutes of all ammonia and water solution from the two co-located storage tanks. The distance to the endpoint using EPA's RMP*Comp is 4 miles. 3.4 Alternate Case Scenario - Ammonia 29% Solution in Water: The more reasonable scenario would be process piping releases from failures at flanges, joints, welds, valves or valve seals connected to one of the two 29% ammonia solution tanks. Active mitigation includes check valves, interlocks, and the vigilance of the process employees and security officers. The distance to the endpoint using EPA's RMP*Comp is 0.3 mile. 3.5 Worst Case Scenario - Flammable Substance: Due to the limited quantities of hydrogen or natural gas on-site, it is not required to develop a WCS for flammables. 3.6 Alternate Case Scenario - Flammable Substance: No alternate case scenario for flammables is required. 3.7 Defining Offsite Impacts - Populations: Using the U.S. Bureau of Census' Landview III CD-ROM database (Illinois and Iowa), it is predicted that approximately 26,189 people live within 7.2 mile radius of the worst case scenario for anhydrous ammonia. Approximately 5,036 people live within the 4-mile worst case scenario for 29% ammonia-water solution. For the more realistic alternate case scenarios, approximately 16 people live within 0.3 mile of the plant and 2 people live within 0.1 mile of the plant. 3.8 Defining Offsite Impacts - The Environment: The USGS maps indicate the absence of any sens itive environmental receptors, as defined by the EPA, within the scenario distances. There are, however, mixed areas of fields, woodlands, minor marshes and creeks in this region near the Mississippi River. 4.0 ACCIDENTAL RELEASE PREVENTION PROGRAM (' 68.155) The facility complies with the EPA's Accidental Release Prevention Rule (40 CFR part 68) and OSHA's Process Safety Management Rule (29 CFR 1910.119). Program level 3 is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment outside the plant's fence line. The Clinton plant's Program 3 prevention program consists of the following 12 elements. 4.1 Process Safety Information: The Clinton Plant maintains a variety of technical documents that are used to help ensure safe operation of the plant processes. These documents address (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant and (3) design basis and configuration of the equipment at the plant. PCS Nitrogen ensures that this process safety information is available to all employees, the LEPC, the local fire department, the area hospital and the county sheriff's office. Material safety data sheets (MSDS) document the physical properties of the hazardous materials handled at the plant, including regulated substances in covered processes. The information available for each hazardous substance typically includes: 7 Toxicity information and permissible exposure limits 7 Physical data (e.g., boiling point, melting point, flash point) 7 Reactivity and corrosivity data 7 Thermal and chemical stability data 7 Hazards of mixing substances in the process MSDS's for hazardous substances handled in the process are available throughout the facility so that the employees have ready reference to this information. In addition, key MSDSs are provided to the LEPC and the fire department for use in helping formulate emergency re sponse plans. The engineering design documents include the operating parameters and the design basis and configuration of the equipment in the covered process. The available information includes: 7 Operating parameters 7 Block flow or simplified process flow diagrams 7 Process chemistry 7 Maximum intended inventories 7 Safe upper and lower limits for parameters such as temperature, pressure or flow 7 Consequences of deviations from established operating limits 7 Design basis and configuration of equipment 7 Piping and instrumentation diagrams, including materials of construction 7 Electrical classification 7 Safety systems 7 Applicable design codes and standards 7 Design basis for relief and ventilation systems When important information was not available from the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analyses (PHA) of the process. Many of the operating parameters are included in the operating pr ocedures to help with the safe operation of the process. These documents are used (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment. 4.2 Process Hazard Analysis The Clinton plant performs and periodically updates process hazard analysis (PHA's) of the covered process to help identify process hazards and generate recommendations that might improve the safe operation of the process. A team composed of personnel with engineering and process operating experience and a leader with process hazard analysis experience is assembled to analyze the hazards of the process. The plant primarily uses the HAZOP and "what-if-checklist" techniques to perform this analysis. The PHA team prepares a written report describing the results of the analysis, including a list of recommendations. Responsibility to resolve the recommendations is assigned to unit personnel and, as appropriate, changes to enhance the safety of the process are implemented. 4.3 Opera ting Process: Clinton plant engineers, operators, supervisors and the environmental and safety staffs work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: 7 Steps for safely conducting activities 7 Applicable process safety information, such as safe operating limits and consequences of process deviations 7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs 7 Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations 4.4 Training: The Clinton plant trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process and (3) a detailed review of the process operating procedure and safe work practices. Oral reviews and written tests are used to verify that an employee understands the training material before the employee can resume work in the process. The operators are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training. Recommendations from the operators are reviewed and changes to the training program are implemented as appropriate. Operators must be initially job certified and then recertified every three years on each of their job description line items. 4.5 Mechanical Integrity: The Clinton plant maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public or the environment. The mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes. The mechanical integrity program includes: 7 Specifications for inspection and testing of process equipment 7 Specifications for replacement parts and equipment 7 Procedures for inspecting, testing, and maintaining process equipment 7 Procedures for safe work practices such as Lockout/Tagout; Hot Work; Confined Space Entry; and Line Breaking 7 Training of maintenance personnel 7 Documentation of maintenance activities 4.6 Management of Change: The Clinton plant management of change program evaluates and approves all proposed changes to chemicals, equipme nt and procedures for a covered process to help ensure that the change does not negatively affect safe operations. Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. 4.7 Pre-startup Review: The Clinton plant performs a safety review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely. This review confirms that: 7 Construction and equipment are in accordance with design specifications 7 Adequate safety, operating, maintenance and emergency procedure are in place 7 Employee training has been completed 7 For a covered process, that management of change requirements have been completed 7 A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed 4.8 Compliance Audit: The Clinton plant audits the covered process to be certain that the prevention program is effectively addressing the safety issues of operating the plant. The plant assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and this team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to help ensure safe operations of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 4.9 Incident Investigation: The Clinton plant investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public or the environment so similar incidents can be prevented in the future. The plant trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated with 48 hours of the incident. The results of the investigation are documented, recommendations are resolved and appropriate process enhancements are implemented. 4.10 Employee Participation: The Clinton plant developed a written employee participation program for the covered process to help ensure that the safety concerns of the plant's workers are addressed. The plant encourages active participation of personnel in the prevention program activities at the plant. Employees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHA's and operating procedures. 4.11 Hot Work Permits: The Clinton plant established a hot work permit program to control spark or flame pr oducing activities that could result in fires or explosions in covered processes at the plant. The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The Shift Supervisor reviews the completed form before work can begin. Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation. 4.12 Contractors: The Clinton plant established a program to help ensure that contractor activities at the plant are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that the plant only hires contractors who can safely perform the desired job tasks. The plant explains to the contract supervisors the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant' s emergency response procedures. The plant requires that the contractor supervisors train each of their employees who will work at the plant before that worker can begin work at the plant site. The plant initially, then annually, reviews contractors' training documents and work performance to help ensure that safe practices are followed. A list of "Safety Approved" contractors is maintained by the Safety Department. 5.0 FIVE-YEAR ACCIDENT HISTORY (' 68.155E) The Clinton plant has an excellent record of accident prevention over the last 5 years. No accident reporting as defined in the RMP rule is required. Although not required, but in a spirit of full disclosure, PCS Nitrogen Clinton acknowledges a one-time reportable quantity (RQ) release on February 12, 1995 of 14,934 pounds of ammonia. The situation was quickly brought under control and there were absolutely no casualties or off-site impacts. 6.0 EMERGENCY RESPONSE PROGRAM INFORMATION (' 68.155F) The PCS Nitrogen Clinto n plant emergency response plan has been developed to meet the emergency planning, response and notification requirements of the following regulations: 7 OSHA 29 CFR 1910.38 (a) - Employee Emergency Action Plans 7 OSHA 20 CFR 1910.119 (n) - Process Safety Management of Highly Hazardous Chemicals 7 OSHA 29 CFR 1910.120 (p) and (q) - Hazardous Waste Operations and Emergency Response (HAZWOPER) 7 OSHA 29 CFR 1910, Subpart L - Fire Protection 7 EPA 40 CFR Part 302.6 - Notification Requirements 7 EPA 40 CFR Pat 355.30 - Facility Coordinator and Emergency Response Plan 7 EPA 40 CFR Part 355.40 - Emergency Planning ad Release Notifications 7 EPA 40 CFR Part 112 - Spill Prevention, Control and Countermeasures Plan 7 EPA 40 CFR Part 68 - Risk Management Programs for Chemical Accidental Release Prevention 7 EPCRA section 302 - List of Extremely Hazardous Substances 7 EPA 40 CFR Part 70 - Title V Air Permit Program The emergency response strategy for the Clinton plant is to prevent and/or contr ol emergency situations via the use of engineering, design and fixed and mobile fire protection systems. Fire protection systems are designed to National Fire Protection Association (NFPA) guidelines. The plant has Emergency Response Team responders on each shift, available 24 hours per day, to respond and initiate actions to contain, control and if possible mitigate the release. The team has access to on site emergency equipment, which is appropriate for the anticipated emergency situations and capabilities of PCS Nitrogen Clinton personnel. The employee HAZMAT team meets at least monthly. Quarterly drills are conducted to assess and evaluate the emergency response effort at the Clinton plant. On occasion these drills include participation of various public emergency response organizations such as fire departments, Hazmat teams, police departments, Clinton County Emergency Management Agency, sheriff's department, and the appropriate LEPC organizations. The Clinton Plant is an a ctive participant in the community planning process with the Clinton County Local Emergency Planning Committee. A copy of the plant's Emergency Response Plan has been forwarded to the Office of Emergency Preparedness as per the requirements of 40 CFR 355. 7.0 PLANNED CHANGES TO IMPROVE SAFETY (' 68.155G) The Clinton plant constantly strives to improve the safety of the processes at the facility through the corporate auditing process, the suggestion process and incident investigation process. 8.0 PROCESSES NOT COVERED BY THE RULE The PCS Nitrogen Clinton plant has determined that the following processes are not covered by the Rule at the facility: 7 Waste Water Treatment Plant 7 Utilities Unit 7 Ammonium Nitrate Prill Unit 7 Carbon Dioxide Liquification Unit 7 Nitric Acid Production Unit 7 Urea Unit 7 Urea - Ammonium Nitrate Solutions Unit The above units do not manufacture or use any regulated chemicals above the threshold quantity list chemicals. 9.0 CERTIFICATION 9.1 Pro gram 3 Process Certification Based on the criteria in 40 CFR 68.10, to the best of the signer's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. __________________________________ _______________ J T Purnell, Plant Manager Date 10.0 REVIEW AND UPDATE The RMP Coordinator at the PCS Nitrogen Clinton plant shall review and update the RMP as specified in 40 CFR 68.190 (b) and submit it in a method and format to a central point specified by the EPA prior to June 21, 1999. The RMP Coordinator is the Environmental Manager. The RMP Coordinator at the PCS Nitrogen Clinton plant shall review and update the offsite consequence analysis at least once every five (5) years. If changes in processes, quantities stored or handled, or any other aspect of the stationary source might reasonably be expected to increase or decrease the worst-case distance to the endpoint also revise and update the RMP as follows : 7 Within five years of its initial submission or most recent update, 7 No later than three years after a newly regulated substance is first listed by EPA, 7 Not later that the date on which a new regulated substance is first present in an already covered process above a threshold quantity, 7 No later than the date on which a regulated substance is first present above a threshold quantity in a new process, 7 Within six months of a change that requires a revised PHA or hazard review, 7 With six months of a change that alters the Program level that applied to any covered process, 7 If the site is no longer subject to this part, the RMP Coordinator will submit a revised registration to EPA within six months indicating that the site is no longer covered. |