LaRoche Industries, Inc. Crystal City Operations - Executive Summary

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Executive Summary for the LaRoche - Crystal City Operations 
1.    Accidental Release Prevention and Emergency Response Policies 
We at LaRoche Industries, Inc. Crystal City Operations 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 Jefferson County LEPC and Jefferson County Fire company 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 Ammonium Nitrate Fertilizer.  We have 2 regulated substances present at our facility.  These substances include Ammonia (anhydrous), Nitric acid and Nitric oxide  [Nitrogen oxide (NO)].  Ammonia (anhydrous) is used to manufacture Nitric Acid (<80 percent) and manufacture Ammonia nitrate solutions.  Nitric oxide  [Nitrogen oxide (NO)] is used to manufacture Nitric Acid (<80 percent). 
The maximum inventory of Ammonia (anhydrous) at our facility is 64,623,674 lb. (32,311.8 tons) while the maximum inventory of Nitric oxide  [Nitrogen oxide (NO)] at our facility is 500.00 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 t 
he 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 Ammonia Terminal Process.  In this scenario 60,000,000 lb. (30,000 ton) 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 Ammonia Terminal Process.  The scenario involves the release of 12,500 lb. (6.25 tons) of Ammonia (anhydrous).  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 15 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.81 miles (4,277 feet). 
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 API and ASME. 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 Ammonia Terminal Process and 2) the Ammonia Loading and Storage (Spheres) Process. 
Process Safety Information 
LaRoche Industries, Inc. Crystal City Operations maintains a detailed record of safety information that describes the chemical hazar 
ds, 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 Hazard 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 06/14/1999. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, LaRoche Industries, Inc. Crystal City Operations maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal s 
hutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved in the processes. 
LaRoche Industries, Inc. Crystal City Operations 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. Crystal City Operations 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 trainin 
g 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. Crystal City Operations to manage changes in process chemicals, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 09/15/1998.  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. Crystal City Operations.  A PSSR has never been conducted for either of the Crystal City Plant's covered processes because neither process has been significantly modified since original design.  These revi 
ews 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. Crystal City Operations 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 09/15/1998.  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. Crystal City Operations 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 year 
Employee Participation 
LaRoche Industries, Inc. Crystal City Operations 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. 
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. Crystal City Operations 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 acciden 
tal release of a regulated substance occur. 
5.    Five-year Accident History 
LaRoche Industries, Inc. Crystal City Operations 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 past 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. Crystal City Operations 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 deco 
ntamination 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.  Asbestos removal from part of the plant is one of the major steps we want to take to improve safety at our facility.  These changes are expected to be implemented by 12/31/99.  We are constantly working to improve our Environmental Health and Safety performance.
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