LaRoche Industries, Inc. - Geneva Nitrogen Plant - Executive Summary |
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Executive Summary for the LaRoche - Geneva Nitrogen Plant 1. Accidental Release Prevention and Emergency Response Policies We at LaRoche Industries, Inc. - Geneva Nitrogen Plant 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. We also have a thorough emergency response plan in place in which our employees and local responders are familiar with through periodic training. Should a release occur that requires emergency response, the Utah county Emergency Coordinator and the Orem Fire Department stand ready to work with us to implement this plan and provide highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Manufacturing of Nitric Acid and Ammonium Nitrate. We have 2 regulated substances present at our facility. These substances include Ammonia (anhydrous) and Nitric oxide [Nitrogen oxide (NO)]. Ammonia (anhydrous) is used to manufacture both Nitric Acid (< 80 percent) and Ammonia Nitrate. Nitric oxide [Nitrogen oxide (NO)] is used to manufacture Nitric Acid (<80 percent). The maximum inventory of Ammonia (anhydrous) at our facility is 8,561,724 lb.(4,281 tons) while Nitric oxide [Nitrogen oxide (NO)] is present at our facility in a maximum quantity of 9 lb. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including 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 3 toxic substances as a class involves a catastrophic release from the Anhydrous Ammonia Storage and Transfer Process. In this scenario 4,200,000 lb. (2,100 tons) 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. The released quantity has not been limited by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario for Ammonia (anhydrous) involves a release from the Anhydrous Ammonia Storage and Transfer Process. The scenario involves the release of 420,000 lb. (210 tons) of Ammonia (anhydrous). Toxic liquid is assumed to be re leased to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 3.4 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. This facility was designed and constructed in accordance with the United States Steel Corporation Design Codes. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source for the Program 3 processes at our plant: 1) the Anhydrous Ammonia Storage and Transfer Process. Process Safety Information LaRoche Industries, Inc. - Geneva Nitrogen Plant maintains a detailed record of safety information that describes the chemi cal 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 processes are identified and controlled efficiently. The methodology used to carry out these analyses is Hazardous and Operability Study (HAZOP). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 05/18/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, LaRoche Industries, Inc. - Geneva Nitrogen Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operatio ns, 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. - Geneva Nitrogen Plant 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 three years and more frequently as needed. Mechanical Integrity LaRoche Industries, Inc. - Geneva Nitrogen Plant 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 special ized 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. - Geneva Nitrogen Plant to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 12/01/1998. 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-startup safety reviews (PSSR) related to new processes and to modifications in established processes are conducted as a regular practice at LaRoche Industries, Inc. - Geneva Nitrogen Plant. A PSSR for Geneva's covered process has not been conducted because the process has not been significantly modified since design. Any PSSRs conducted would confirm tha t construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits LaRoche Industries, Inc. - Geneva Nitrogen Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 09/25/1998. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation LaRoche Industries, Inc. - Geneva Nitrogen Plant 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 LaRoc he Industries, Inc. - Geneva Nitrogen Plant 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. - Geneva Nitrogen Plant 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 subst ance occur. 5. Five-year Accident History LaRoche Industries, Inc. - Geneva Nitrogen Plant 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. In the last five years, there were no accidents occurring at our plant meeting the RMP criteria. According to the RMP rule, an accidental release is defined as one that resulted in death, injuries, significant property damage, evacuations, shelter-in-place, or environmental damage. 6. Emergency Response Plan LaRoche Industries, Inc. - Geneva Nitrogen Plant 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. The plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. In addition, we conduct periodic emergency response drills to keep our employees and local responders familiar with the plan. 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. Installation of Ammonia detection sensors, implementation of safe work system are two of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by December 1, 1999. We are constantly working to improve our Environmental Health and Safety performance. |