El Dorado Chemical Company - Executive Summary |
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1.0 Accidental Release Prevention and Emergency Response Policies At El Dorado Chemical 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 Chemical Company maintains an open dialogue with local emergency responders and has provided them with a copy of its Emergency Response Plan, detailing important facility-specific information. 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 regulated 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 five-year accident history for accidental releases of chemicals regulated by the RMP rule. An overview of the Emergency Response Program. An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment. 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 ammonium nitrate, nitric acid, and sulfuric acid. These products are used extensively in the agricultural, mining, specialty chemical manufacturing, and forestry products industries. From a consumer's viewpoint, these products are used in the manufacture of paper, water treatment chemicals, computer chips, and even blue jean dye to name a few of our product applications. In our processes, we use or manufacture the following chemicals that EPA has identified on the RMP Toxic Substances List: TOXIC SUBSTANCES Anhydrous Ammonia Nitric Acid = or > 80% Chlorine 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 wo rst case release scenario submitted for Program 3 toxic substances as a class involves the cyrogenic (refrigerated) ammonia storage tank. This API 650 tank is inspected on a scheduled basis utilizing an ultra-sonic testing method, which verifies the mechanical integrity of the tank. The tank is double walled and contains 30 inches of insulation between the inner and outer shells, creating a safeguard or barrier that virtually eliminates the risk associated with a complete and or sudden rupture of the vessel. The worst case was developed using Class F atmospheric stability (1.5 m/s wind speed conditions) and does not account for any active mitigation measures. Furthermore, we have not experienced an ammonia release from this tank since purchasing the facility from Monsanto Corporation in 1983. Related data is as follows: Release Rate - 143,000 lbs/min Duration of Release - 10 minutes Mete orology - 25 degrees C / 50% RH (Class F) Off-Site Consequence - > 25.0 miles Nearest Public Receptor - 0.60 miles Toxic Endpoint - 0.14 mg/l Coordinates - Lat. 33-15-57 Log. 92-41-28 (From GPS) ALTERNATE CASE - AMMONIA: This alternate case scenario involves a release from the East Regular Nitric Acid Ammonia Surge Tank. Release Rate - 645 lbs/min Duration of Release - 6 minutes Meteorology - 25 degrees C / 50% RH (Class D) Off-Site Consequence - 0.71 miles Nearest Public Receptor - 0.60 miles Toxic Endpoint - 0.14 mg/l Coordinates - Lat. 33-15-57 Log. 92-41-30 (From GPS) NITRIC ACID ( = OR > 80%): This alternate case involves a release of nitric acid from the product storage area. Release Rate - 218 lbs/min Duration of Release - 20 minutes Meteorology - 25 degrees C / 50% RH (Class D) Off-Site Consequence - 0.91 miles Nearest Public Receptor - 0.60 miles Toxic Endpoint - 0.026 mg/l Coordinates - Lat. 33-15-57 Log. 92-41-29 (From GPS) CHLORINE: This alternate release involves a release of chlorine at a water-cooling tower. Release Rate - 98.5 lb s/min Duration of Release - 20 minutes Meteorology - 25 degrees C / 50% RH (Class D) Off-Site Consequence - 1.1 miles Nearest Public Receptor - 0.60 miles Toxic Endpoint - 0.0087 mg/l Coordinates - Lat. 33-15-57 Log. 92-41-58 (From GPS) 4.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL - SPECIFIC PREVENTION STEPS El Dorado Chemical Company maintains a number of programs to help prevent accidental releases and ensure safe operation. Also, El Dorado Chemical 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 sourc e. Process Safety Information El Dorado Chemical Company, El Dorado, Arkansas, 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 processes are identified and controlled efficiently. The methodology used to carry out these analyses is "HAZOP" and/or "what if" checklist. 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 Chemical Company maintains written operating procedures. These procedures address various modes of operation such as initial start-up, normal operations, temporar y 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 Chemical 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 continuously for operator certification. Mechanical Integrity El Dorado Chemical 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 mechanical integrity engineer conduct the process maintenance activities. Furthermore, these personnel are offered specialized 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 El Dorado Chemical Company to manage changes in process chemicals, technology, equipment, and procedures. Process operators, 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 related to new processes and to modifications in established processes are conducted as a regular practice at El Dorado Chemical 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 Chemical Company conducts audits on a regular basis to determine whether the provisions set out under the RMP rule a re 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 Chemical Company promptlly 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 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 Chemical 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 implem entation of the RMP rule, including information resulting from process hazard analyses in particular. An employee coordinated Behavioral Science Technology Program (BST) also plays a key role in reducing accidents related to safety within the plant, utilizing observaiton which provides soon, certain, and positive feedback. Contractor Training On occasion, El Dorado Chemical 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. 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 The following is a brief summary of significant accidental chemi cal releases involving materials covered under EPA's RMP rule during the previous five years. Nitric Acid: A release of 98% nitric acid occured on February 10, 1998, due to strong winds. This act of nature blew the top section of a partially constructed tank into a nitric acid transfer pump's suction line causing the line to rupture. Although the release of the product was significant, it was contained and neutralized with sodium carbonate at the point of origin and diverted to the wastewater treatment system. Some fuming occurred from the addition of sodium carbonate for neutralization purposes and local authorities initiated an evacuation as a precautionary measure. The evacuation was soon cancelled, since the release was quickly and safely mitigated by El Dorado Chemical Company employees, who followed the guidelines in our Emergency Response Plan. Although an evacuation was initiated as a precautionary measure by local authorities, the release did not result in on-site or off -site deaths, injuries, significant property or environmental damage. Ammonia: During the past five years, El Dorado Chemical Company has not had an accidental ammonia release, which resulted in on-site or off-site deaths, injuries, significant property damage, environmental damage, off-site evacuation, or sheltering in place notifications. Chlorine: During the past five years, El Dorado Chemical Company has not had an accidental chlorine release, which resulted in on-site or off-site deaths, injuries, significant property damage, environmental damage, off-site evacuation, or sheltering in place notifications. 6.0 EMERGENCY RESPONSE PROGRAM El Dorado Chemical Company maintains an Emergency Response Plan, which is based on a similar format to 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 work ers, the public, and the environment during emergency situations. Furthermore, coordination of the Plan with the Union County Local Emergency Planning Committee (LEPC) is an integral part of the verificaiton process. As well, El Dorado Chemical Company purchased a computer-based emergency notification system, the "Communicator", for the city of El Dorado, which has the ability to notify Union County, Arkansas residents. This system was purchased at a cost of $42,000 and provides state of the art notification capabilities in the event of an industrial incident or severe weather situation. 7.0 PLANNED CHANGES TO IMPROVE SAFETY El Dorado Chemical Company is actively promoting public awareness and education programs concerning emergency response through the Union County LEPC and Community Advisory Panel (CAP). This enhances the public's ability to respond in a given emergency situation. El Dorado Chemical Company continually strives to improve and upgrade operating procedures, replac e or maintain equipment, and develop and implement safety improvement projects. A list of proposed future improvements is as follows: Pre-programmed "shelter-in-place" messages (for regulated substances) through the computerized emergency notification system known as the "Communicator" Continued emergency training for personnel working within hazardous areas of the facility Improved secondary containment for acid storage areas New wastewater neutralization system Reverse osmosis unit for boiler feed water system In conclusion, El Dorado Chemical Company realizes worthwhile improvements are necessary and these are just several of the steps we plan to take as a company in continuously improving our safety and emergency response capabilities. 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: Sr. Vice President of Manufacturing Date: _____________________________________ 9.0 RMP DATA ELEMENTS The following items present additional information about El Dorado Chemical 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 Toxics: Worst Case Scenario - Anhydrous Ammonia Toxics: Alternate Release Scenario - Anhydrous Ammonia Toxics: Alternate Release Scenario - Nitric Acid >=80% Toxics: Alternate Release Scenario - Chlorine Five - Year Accident History Prevention Program - Program 3 Emergency Response Program |