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El Dorado Chemical Company

Parent Companies:
LSB Chemical Corporation
EPA Facility ID:
100000115207
Other ID:
ARD001700657
Facility DUNS:
103970307
Parent Company DUNS:
46860979

Location:

Address:
4500 North West Avenue
El Dorado, AR 71730
County:
UNION
Lat / Long:
33.159, -92.411 (Get map)
Method:
GPS - Unspecified
Description:
Administrative Building
Horizonal accuracy:
10 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
El Dorado Chemical Company
Phone:
(870) 863-1400
Address:
4500 North West Avenue P.O. Box 231
El Dorado, AR 71730
Foreign Address:

Person responsible for RMP implementation:

Name:
Gregory Withrow
Title:
General Manager

Emergency contact:

Name:
David Sartain
Title:
Environmental Manager
Phone:
(870) 863-1484
24-hour phone:
(870) 863-1400
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(405) 235-4546
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Union County LEPC
Full-Time Equivalent Employees:
165
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0573-AOP-R16
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Oct. 23, 2015
Inspecting Agency:
Liedos
Using Predictive Filing:
No

Processes:

Nitric acid production
RMP ID:
1000071451
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Nitrogenous Fertilizer Manufacturing (325311)
Chemical name
CAS#
Quantity (lbs.)
CBI
Nitric acid (conc 80% or greater)
7697-37-2
500,000
No
Public OCA Chemical
0
No
Nitric acid & AN product
RMP ID:
1000071452
CBI claimed:
No
Program Level:
3
NAICS:
Nitrogenous Fertilizer Manufacturing (325311)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
60,000,000
No
Public OCA Chemical
0
No
Mixed Acid
RMP ID:
1000071453
CBI claimed:
No
Program Level:
3
NAICS:
Nitrogenous Fertilizer Manufacturing (325311)
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]
8014-95-7
300,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
HSG Environmental Consultants, LLC
Address:
3011 Corporate Center Drive
Bryant, AR 72022
Foreign Address:

Phone:
(501) 653-0000

Latest RMP Submission:

Date:
July 13, 2016
Type:
Resubmission
Reason:
Revised PHA / Hazard Review due to process change (40 CFR 68.190(b)(5))
Registered:
Yes
RMP ID:
1000057143

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Nitric acid production)
CBI claimed:
No
Percent weight:
98.0
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Release duration (mins):
60.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Public OCA Chemical (in Nitric acid & AN product)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Public OCA Chemical (in Mixed Acid)
CBI claimed:
No
Percent weight:
65.0
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Release duration (mins):
60.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Nitric acid production)
CBI claimed:
No
Percent weight:
98.0
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Wind speed (meters per sec):
1.50
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Nitric acid & AN product)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Wind speed (meters per sec):
1.50
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Mixed Acid)
CBI claimed:
No
Percent weight:
65.0
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Wind speed (meters per sec):
1.50
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

May 15, 2012 at 03:57
ID:
1000044240
NAICS:
Nitrogenous Fertilizer Manufacturing (325311)
Duration:
1 hours and 32 minutes
Chemicals involved:
  • Nitric oxide [Nitrogen oxide (NO)]
  • Sulfur dioxide (anhydrous)
Release events:
Gas release
Fire
Explosion
Weather conditions at time of event
Wind speed:
1.0 miles/h N
Temperature:
55.00 ℉
Atmospheric stability:
F
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$50000000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$150000
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Changed process

7. Prevention: Program level 3

Nitric acid production, Nitrogenous Fertilizer Manufacturing (325311)
Prevention Program ID:
1000060479
Safety Review Date
Nov. 28, 2014
PHA Update Date
May 18, 2013
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Deluge System
  • Water Curtain
  • Enclosure
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 18, 2015
Training Review Date
Jan. 1, 2015
Maintenance Review Date
Dec. 17, 2014
Maintenance Inspection Date
Oct. 21, 2015
Equipment Tested
Yes
Management of Change Most Recent Date
April 24, 2016
Management of Change Review Date
Jan. 8, 2016
Pre-startup Review Date
April 4, 2016
Compliance Audit Date
Oct. 23, 2015
Compliance Audit Change Completion Date
June 30, 2016
Incident Investigation Date
March 14, 2016
Incident Invest. Change Completion Date
April 13, 2016
Participation Plan Review Date
Jan. 8, 2016
Hot Work Review Date
Jan. 6, 2016
Contractor Safety Review Date
Feb. 17, 2016
Contractor Safety Eval. Date
Jan. 1, 2016
Nitric acid & AN product, Nitrogenous Fertilizer Manufacturing (325311)
Prevention Program ID:
1000059736
Safety Review Date
Nov. 28, 2014
PHA Update Date
April 1, 2016
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Rupture Disks
  • Excess Flow Device
  • Quench System
Mitigation Systems
  • Deluge System
  • Water Curtain
  • Enclosure
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 9, 2016
Training Review Date
Jan. 1, 2015
Maintenance Review Date
Dec. 17, 2014
Maintenance Inspection Date
March 29, 2016
Equipment Tested
Yes
Management of Change Most Recent Date
April 15, 2016
Management of Change Review Date
Jan. 8, 2016
Pre-startup Review Date
Dec. 8, 2014
Compliance Audit Date
Oct. 23, 2015
Compliance Audit Change Completion Date
June 30, 2016
Incident Investigation Date
March 14, 2016
Incident Invest. Change Completion Date
April 13, 2016
Participation Plan Review Date
Jan. 8, 2016
Hot Work Review Date
Jan. 6, 2016
Contractor Safety Review Date
Feb. 17, 2016
Contractor Safety Eval. Date
Jan. 1, 2016
Mixed Acid, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000059737
Safety Review Date
Nov. 28, 2014
PHA Update Date
June 28, 2013
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Tornado
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Aug. 1, 2014
Training Review Date
Jan. 1, 2015
Maintenance Review Date
Dec. 17, 2014
Maintenance Inspection Date
March 15, 2016
Equipment Tested
Yes
Management of Change Most Recent Date
April 15, 2016
Management of Change Review Date
Jan. 8, 2016
Pre-startup Review Date
Dec. 8, 2014
Compliance Audit Date
Oct. 23, 2015
Compliance Audit Change Completion Date
June 30, 2016
Incident Investigation Date
March 14, 2016
Incident Invest. Change Completion Date
April 13, 2016
Participation Plan Review Date
Jan. 8, 2016
Hot Work Review Date
Jan. 6, 2016
Contractor Safety Review Date
Feb. 17, 2016
Contractor Safety Eval. Date
Jan. 1, 2016

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
March 23, 2016
Local Response Agency:
Local Response Agency Phone:
(870) 864-1901
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

EDCC is committed to operating and maintaining all of its processes in a safe and responsible manner. The facility uses a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of its employees and the public, as well as protection of the environment. EDCC 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 have been 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 the EPA's RMP Rule;

? A summary of the potential off-site consequences from possible accidental chemical releases;

? An overview of 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; and,

? 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.



3.1 Regulated Substances



EDCC'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 applications. The facility uses or manufactures the following chemicals that EPA has listed on the RMP Rule Toxic Substances list, and that are stored above threshold quantities:



Chemical Process Storage Temp (F) Storage pressure (psig) Density

(g/cm3) Ma
ximum Quantity (lbs)

Anhydrous Ammonia Ammonium Nitrate -28 0.5 0.90 60,000,000

Nitric acid (98%) Nitric Acid Amb Amb 1.51 500,000

Oleum Mixed Acid Amb Amb 1.85 300,000



The facility included chlorine in previous RMP versions as a regulated substance under the RMP Rule. However, in December 2009, chlorine was replaced with bromine chloride for use as a disinfectant in the facility's cooling towers. The facility keeps a maximum quantity of approximately 2,000 lbs of 15% bromine chloride on-site. The threshold quantity for bromine is 10,000 lbs.



As this RMP will illustrate, accidental release prevention programs and emergency response planning efforts enable the facility to effectively manage any potential hazards posed by these substances.

 



3.2 Accidental Release Prevention and Response Policies



EDCC maintains a number of programs to help prevent accidental releases and ensure safe operation. Also, EDCC 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 in place at the facility.



3.2.1 Process Safety Information



EDCC maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with all processes.



3.2.2 Process Hazard Analysis



The 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 the "HAZOP" and/or the "what if" checklist. These analyses are conducted by a team of qualified personnel with expertise in engineering and process operations and are validated at regular intervals. Findings related to the process hazard analysis are addressed in a timely manner.



3.2.3 Operating Procedures



For the purpose of safely conducting activities within covered processe
s, EDCC maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a turn-around. Operating procedures are regularly reviewed and are readily accessible to operators involved in the process. In addition, Daily/Shift Safe Work Permits (Procedure No. S-82) are required for any maintenance work completed at EDCC.



3.2.4 Training



EDCC 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.

 



3.2.5 Mechanical Integrity



EDCC 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 the facility's mechanical integrity engineer conduct the process maintenance activities. These personnel are offered specialized training, as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Daily/Shift Work Permits are required for maintenance/repairs required on equipment and processes at EDCC.



3.2.6 Management of Change



Written procedures are in place at EDCC 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 integral part of the change order process.



3.2.7 Pre-startup Reviews



Pre-startup safety reviews related to new processes and to modifications in estab
lished processes are conducted as a regular practice at EDCC. These reviews are conducted to confirm that construction, equipment, and operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.



3.2.8 Compliance Audit



EDCC conducts compliance audits on a regular basis to determine whether the provisions of the prevention program set out under Subpart D are being implemented. These audits are carried out at least every three years by at least one person knowledgeable in the process. Corrective actions required as a result of the audits are undertaken in a safe and timely manner.

 



3.2.9 Incident Investigation



EDCC 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 root cause of the incident, as well as any corrective actions needed to prevent the release from recurring. All reports are retained for a minimum of five years.



3.2.10 Employee Participation



EDCC 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. 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.



3.2.11 Hot Work Permits



EDCC has in place a standard hot work procedure which establishes a system to ensure adequate controls are maintained to detect and eliminate hazardous conditions associated with fire or "hot work". The system dictates the coordination of hot work, pre-permit preparations, fire watch requirements, air monitoring, personnel protection equipment, special precautions, and other department responsibilities.



3.2.12 Contractors



On occasion, EDCC hires contractors to conduct spe
cialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of the safety performance of the contractor is carried out. The facility has a strict policy of informing the contractors of known potential hazards related to their work and the processes. A Daily/Shift Safe 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.



3.3 Chemical Specific Release Prevention Steps



EDCC has instituted the following measures to prevent accidental releases from the following regulated substances used or produced at the facility:



3.3.1 Nitric Acid and Ammonia



Several process controls are in place to prevent and/or mitigate accidental releases of nitric acid or ammonia. These controls include vents, relief valves, check valves, manual and automatic shut-offs, interlocks, alarms, keyed bypass system, emergency back-up power, back-up pumps, rupture disks, excess flow devices, and quench systems. Passive mitigation includes earthen dikes that route spills to neutralization and the wastewater treatment system, a deluge system, water curtains, and enclosures. pH probes and alarms are located throughout the plant's storm water system to alert staff of accidental spills or releases.





3.3.2 Oleum



Process controls are in place to prevent and/or mitigate accidental release of oleum to the environment. The tank is installed with a vacuum breaker, sumps that pump lost solution back to the process and a scrubber with an induced draft blower to collect all vents and remove any vaporized sulfur trioxide by dissolving it in water to form sulfuric acid. The sulfuric acid is returned to the process. A concrete dike surrounds the tank and is sufficient to contain the entire release of vessel contents.



3.4 Five-Year Accident History



The following is a brief summary of significant accidental c
hemical releases involving materials covered under EPA's RMP Rule during the previous five years.



3.4.1 Nitric Acid



On May 15, 2012 an explosion at the DSN Nitric Acid Plant (DSN Plant, NAICS 325311) occurred. The explosion did not result in a chemical release. On-site impacts included total destruction of the DSN Plant as well as structural damage to surrounding processes. Off-site impacts included minor structural damage to residences and businesses. No deaths or injuries resulted from the incident. Procedures following the explosion were executed in accordance with the emergency response plan. The local Office of Emergency Services, as well as, emergency medical assistance, local fire departments, and the county police department were notified for assistance.



The DSN Plant has been replaced with a new Nitric Acid Concentration (NACSAC®) Plant. The NACSAC® Plant will concentrate weak nitric acid (56% - 65% strength) to strong nitric acid (greater than 98% strength) by extracting water from the weak nitric acid with sulfuric acid. Since the previously used strong acid process, which required the addition of oxygen, will not be reintroduced, the potential for this explosion scenario to be repeated is eliminated.



3.4.2 Ammonia



During the past five years, EDCC has not had an accidental ammonia release, resulting in on-site or off-site site consequences, including deaths, injuries, significant property damage, environmental damage, off-site evacuation, or sheltering in place.



3.4.3 Oleum



During the past five years, EDCC has not had an accidental oleum release resulting in on-site or off-site consequences, including deaths, injuries, significant property damage, environmental damage, off-site evacuation, or sheltering in place.





3.5 Emergency Response Programs



EDCC maintains an Emergency Response Plan, which is based on a similar format to 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. The Plan includes the following components:



? Procedures for informing the public and emergency responders of accidental releases,

? Documentation of proper first aid/emergency medical treatment that may be necessary to treat exposure,

? Emergency response procedures,

? Procedures for using, inspecting, testing, and maintaining response equipment,

? Employee training; and,

? Response plan review and update procedures.



Coordination of the Plan with the Union County Local Emergency Planning Committee (LEPC) is an integral part of the verification process.



3.6 Planned Changes to Improve Safety



EDCC is actively promoting public awareness and education programs concerning emergency response through the Union County Local Emergency Planning Committee and Community Advisory Panel. This education process enhances the public's ability to respond in a given emergency situation. EDCC continually strives to improve and upgrade operating procedures, replace or maintain equipment, and develop and implement safety improvement projects. A list of proposed future improvements is as follows:



? Continue the partnership and education process with local fire departments to ensure fire department personnel are knowledgeable of site specific processes, materials and products and, as necessary, assist them in updating a site specific fire plan; and,

? Provide continued EMT training to employees and on-site confined space rescue team; and



EDCC realizes the improvements listed above are necessary for improving safety and emergency response capabilities.