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Dyno Nobel Louisiana Ammonia

Parent Companies:
EPA Facility ID:
100000231153
Other ID:
Facility DUNS:
0

Location:

Address:
10800 River Road
Waggaman, LA 70094
County:
JEFFERSON
Lat / Long:
29.965, -90.265 (Get map)
Method:
Address Matching - Block Face
Description:
Administrative Building
Horizonal accuracy:
2 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Dyno Nobel Louisiana Ammonia, LLC
Phone:
(504) 400-6035
Address:
10800 River Road
Waggaman, LA 70094
Foreign Address:

Person responsible for RMP implementation:

Name:
Chris Morgan
Title:
Plant Manager
Email:

Emergency contact:

Name:
James Wold
Title:
Regulatory Compliance Engineer
Phone:
(504) 400-6035
24-hour phone:
(504) 400-6035
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Full-Time Equivalent Employees:
60
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1340-00352-V3
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Inspecting Agency:
Never had one
Using Predictive Filing:
No

Processes:

Ammonia Production
RMP ID:
1000067026
CBI claimed:
No
Program Level:
3
NAICS:
Nitrogenous Fertilizer Manufacturing (325311)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
77,161,792
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Providence
Address:
1201 Main Street
Baton Rouge, LA 70802
Foreign Address:

Phone:
(225) 766-7400

Latest RMP Submission:

Date:
Dec. 10, 2015
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
1000053342

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 Ammonia Production)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
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 Ammonia Production)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Ammonia Production, Nitrogenous Fertilizer Manufacturing (325311)
Prevention Program ID:
1000055851
Safety Review Date
Aug. 3, 2015, since latest RMP submission
PHA Update Date
June 30, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Equipment failure
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Interlocks
  • Alarms
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
Procedure Review Date
Nov. 10, 2015, since latest RMP submission
Training Review Date
Aug. 3, 2015, since latest RMP submission
Maintenance Review Date
Nov. 1, 2015, since latest RMP submission
Maintenance Inspection Date
Nov. 12, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
July 3, 2012
Pre-startup Review Date
Aug. 7, 2015
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 6, 2010
Hot Work Review Date
Sept. 21, 2011
Contractor Safety Review Date
Sept. 21, 2011, since latest RMP submission
Contractor Safety Eval. Date
Sept. 21, 2011, since latest RMP submission

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:
Aug. 17, 2015
Local Response Agency:
Local Response Agency Phone:
(504) 431-7092
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

EXECUTIVE SUMMARY



Dyno is committed to operating in a manner that is safe for the plant workers, the public, and the environment. Dyno strives to protect and promote the health and safety of its employees, its neighbors, and others who may be affected by activities at the facility. Dyno also strives to limit adverse effects on the physical environment in which its activities are carried out. The facility has established systems to help ensure safe operation of the processes at this facility. One part of these systems is the risk management program which helps manage the risks at the facility and complies with the requirements of the EPA's Rule 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit an RMP describing the risk management program at the facility.



Accidental Release Prevention and Emergency Response Policies



Dyno's goal at its program 3 stationary source is accidental release prevention, while maintaining emergency response procedures to minimize consequences in the event of any such release. Dyno maintains a Process Safety Manual directing employees to process safety information in accordance with respective OSHA process safety management and EPA chemical accident prevention provisions. Dyno also maintains an Emergency Procedures Manual providing necessary information and guidelines to utilize in the event of an emergency situation resulting in accidental release of a regulated substance. Dyno's objective is to train affected employees and contractors in emergency response procedures, and requires that emergency response actions are supported by proper consideration for safety, health and welfare of employees, contractors, the surrounding community and property.



Accidental Release Prevention Program



Dyno has developed a management system to oversee implementation of the risk management program elements. Dyno assigns responsibility for imple
menting individual requirements of the program to identified persons exhibiting respective qualifications. Dyno's system includes:



* compiling process safety information to support completing process hazard analyses

* issuing written operating procedures that provide instructions for safely conducting activities in each covered process, and training employees involved in operating those processes

* a mechanical integrity program

* management of change procedures and pre-startup safety reviews

* compliance audits in order to evaluate compliance with provisions of the program

* incident investigation for incidents which resulted in, or could reasonably have resulted in, release of a regulated substance

* an established hot work permit program

* employee participation and training

* contractor pre-qualification, participation and training.



Dyno's prevention steps include engineering and administrative controls. Dyno's engineering designs include overpressure protection for pressurized vessels including a closed vent capture and control system, as well as capture and control technology for atmospheric operations. Redundant equipment and instrumentation is installed, where applicable. Dyno uses a DCS to control production in covered process units. Control buildings are engineered to be blast-resistant for protection of control systems and personnel. Administratively, Dyno engages in periodic inspection and maintenance practices consistent with industry standards, as well as OSHA and USEPA regulatory provisions. Dyno's covered process units also include fire suppression, containment and mitigation systems.



Employee Participation



Employee participation has always been a goal at Dyno. Keeping employees informed and involved creates a team unity atmosphere. Employees have participated on Process Hazards Analysis Teams and have access to all hazard and operability (HAZOP) information and recommendations. This information along with updated Operat
ion Manuals is available in assigned locations throughout the facility. Operation manuals are developed, updated and reviewed by Operations personnel and the Training Department. These Operation Manuals assist employees in refresher training and Operator Recertification Programs.



Safety meetings are held on a regular basis for Operations, Maintenance, Terminal, Administration and Contract personnel. Topics chosen are relevant to respective personnel assigned duties, and general and specific information is provided as informational instruments to enhance employee participation in facility-wide safety performance.



Process Safety Information



Dyno keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within Dyno are assigned responsibility for maintaining up-to-date process safety information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in safety data sheets. For specific process areas, Dyno has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the operation manuals for each process unit. Dyno promotes maintaining process parameters within limits by using process controls and monitoring instruments, operating procedures, trained personnel, and protective instrument systems (e.g., automated shutdown systems).



Dyno also maintains technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for esta
blishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to enhance safety features in respective processes.



Process Hazard Analysis



Dyno has a comprehensive process hazard analysis (PHA) program to recognize and control hazards associated with the various processes. Within this program, each existing covered process and future processes are systematically examined.



Dyno primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques available. The analyses are conducted using a team of personnel who exhibit operating, maintenance and process engineering experience and expertise. This team identifies and evaluates hazards of the process as well as recommends accident prevention and/or mitigation measures when the team believes such measures are warranted.



Dyno periodically updates its process hazard analyses of affected units. These periodic reviews will be conducted at least every five years and will be conducted at this frequency until the process is no longer operating.



Operating Procedures



Dyno maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and annually certified by the Manager of Safety as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made to the process. In addition, the Dyno operating procedures provide guidance on how to respond to events that result in exceeding safe operating limits for specific process or equipment parameters. The writt
en operating procedures are readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks.



Training



To complement the written procedures for process operations, Dyno has implemented a training program for all employees involved in operating a process. New employees receive basic training in Dyno operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures in order to maintain skills and knowledge at an acceptable level.



Contractors



Dyno uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, Dyno has procedures in place to provide that contractors

* perform their work in a safe manner

* have the appropriate knowledge and skills

* are aware of the hazards in their workplace

* understand what they should do in the event of an emergency

* understand and follow site safety rules

* inform Dyno personnel of any hazards that they find during their work.



This is accomplished by providing contractors with

* a process overview,

* information about safety and health hazards,

* emergency response plan requirements,

* safe work practices, and

* a work permit process (i.e., for hot work, confined space, etc.) prior to their beginning work.



In addition, Dyno evaluates contractor safety programs and performance during the selection of a contractor. Dyno personnel monitor contractor performance to evaluate the level at which contracto
rs are fulfilling their safety obligations.



Pre-Startup Safety Reviews



The pre-startup safety review shall confirm that prior to the introduction of regulated substances to a process: construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and are adequate; process hazard analyses have been performed on new stationary sources and any recommendations have been resolved and implemented; modified stationary sources meet the requirements contained in management of change; and training of each involved employee has been completed.



Dyno conducts a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information. This review provides that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to corroborate that construction is in accordance with the design specifications and that all supporting systems are operationally ready. The review team uses checklists to verify all aspects of readiness. A review involves field verification of the construction and serves a quality assurance function.



Training for process maintenance activities: The owner/ operator shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner.



Mechanical Integrity



Dyno makes use of established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspecti
ons and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment.



Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures are used in order that work is performed in a consistent manner and provide a basis for training. Inspections and tests are completed to evaluate equipment functioning as compared to that intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.



Another integral part of the mechanical integrity program is quality assurance. Dyno incorporates quality assurance measures into equipment purchases and repairs. This practice assesses suitability of new equipment for its intended use and establishes that proper materials and spare parts are used when repairs are made.



Management of Change



Dyno has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process technology informa
tion, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change.



Incident Investigation



Dyno will investigate incidents that resulted in, or reasonably could result in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team, which can include contractors, will document its findings, develop recommendations to prevent a recurrence, and forward these results to Dyno management for resolution. Corrective actions will be taken in response to the investigation team's findings and recommendation will be tracked until they are complete. The final resolution of each finding or recommendation will be documented, and the investigation results will be reviewed with all employees (including contractors) who could be affected by the findings.



Compliance Audit



Dyno is a new site that has recently started operations; therefore, there are no relevant compliance audits to report at this time. Compliance audits will be conducted at least every 3 years to confirm the procedures and practices required by the chemical accident prevention program are being implemented.



Hot Work Permit



The facility's hot work procedure requires that detailed permitting activities take place before, during, and after any job that has the potential to provide a source of ignition. The permit is followed through to completion of the work and those permits are maintained on-site. The facility implements other work permits as necessary to assure safe work conditions are communicated to maintenance and contract personnel.



Safe Work Practices



Dyno has in place safe work practices to sustain worker and process safety. Examples of these i
nclude (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control welding and other spark-producing activities, and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to foster that operations and maintenance activities are performed safely.



Additional Safety Features



In addition to the accident prevention program activities, the facility has many safety features to help prevent the accidental releases of regulated substances in the facility. These safety features help to prevent potential accident scenarios that could be caused by equipment failures and human error. These features include but are not limited to:



* Operating parameter monitors with alarms

* Process relief systems

* Isolation valves (manual or automated)



Five-Year Accident History



Dyno is a new site that has recently started operations; therefore, there is no relevant accident history to report at this time. In accordance with the requirements of 40 CFR 68.42, information relating to any accidental release that results in death, injury, significant property damage, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage will be documented for the facility and provided in future RMP submittals.



Emergency Response Program



Dyno's emergency response program is set forth in its Emergency Procedures Manual. That manual is comprised of numerous relevant sections. Those sections deal with, but are not limited to:



* employee participation

* incident command management

* response teams

* emergency evacuation procedures

* fire respo
nse

* toxic gas release



The Emergency Procedures Manual states Dyno's management issued policy statement, which is briefly described in the Accidental Release Prevention and Emergency Response Policies section in this Executive Summary.



Dyno's mechanisms to improve safety include written procedure review, process hazard analysis, management of change, incident reporting and investigation, near miss reporting and investigation, and employee safety meetings and suggestion processes. Also, Dyno's pre-startup safety review includes, among other things, 'show stoppers' that prohibit any startup until those items are closed. Dyno assigns respective tasks resulting from each of these mechanisms to responsible persons, and closure is approved only after all recommendations and action items are documented complete.