| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

I.     Accidental Release Prevention and Emergency Response Policies 
Below is our Safety, Health, and Environmental Policy 
As employees of PCS Nitrogen, we have the responsibility to manage our operations to protect human health and the environment. Sound health, safety, and environmental practices are an integral part of our everyday job requirements. 
In recognition of this responsibility, we will correct any unsound health, safety, and environmental practices or conditions, or call them to the attention of those who will do so, as soon as they are identified. Specifically we will: 
*   Conduct our operations in compliance with all applicable health, safety, and environmental laws and regulations. 
*   Continue to improve our health, safety, and environmental performance through the Augusta Quality Improvement Process (AQIP). 
*   Conduct periodic assessments of our operations to ensure compliance and reduce risks. 
*   Implement progressive health, safety, and environmental practices 
that apply risk management and loss control principles to our operations. 
*   Establish health, safety, and environmental performance goals and assign responsibilities for developing and implementing related measurement systems. 
*   Provide education and training regarding applicable laws, regulations,policies, and procedures to protect human health and the environment. 
*   Cooperate with our neighbors, industry trade groups, governmental agencies, and others to develop effective, resonable rules and regulations to protect human health and the environment. 
PCS Nitrogen's success depends on our positive health, safety, and environmental attitude and actions to achieve continuous improvement. 
II.    The PCS Nitrogen facility manufactures nitrogen fertilizer and industrial products from ammonia. We produce ammonia by reacting natural gas with steam to produce hydrogen, which in turn is mixed with air at high temperatures and subsequently reacted with nitrogen at high pressures to produ 
ce ammonia. 
Ammonia production is the first stage in the process of manufacturing nitrogen fertilizers and chemicals. It is also the building block for all value-added nitrogen products. Among the nitrogen products manufactured, Urea and Ammonium Nitrate are soilid fertilizers. Nitric acid is a feedstock for the production of Ammonium Nitrate. Nitrogen solutions are produced by combining the liquid forms of Urea and Ammonium Nitrate. 
Nitrogen chemicals are produced for a variety of industrial customers. They may be used as raw materials for intermediates in the manufacture of many industrial products. Nitrogen chemicals are used in the production of synthetic fibers for clothing, plastics for the house and car, refrigerants, and pigment in automobile paint. Ammonium Nitrate is used for mining, quarrying, and in road construction. Urea is used in plastics, pharmaceuticals, and dyes, as well as in resins and adhesives for the building industry. 
Methane, a regulated flammable substance 
, is used to produce hydrogen, a regulated flammable substance, which is then combined with nitrogen to form ammonia, a regulated toxic substance. Ammonia is used in agriculture and industry in its pure form. It is also used by PCS Nitrogen to produce a solution of water and Ammonia (conc. 20% or greater), a regulated toxic substance, also used in agriculture and industry. Chlorine, a regulated toxic substance, is used at the facility for water treatment. 
III.   The worst case release scenario for a regulated toxic substance from the PCS Nitrogen facility would be the failure of a pressurized ammonia storage tank, and the sudden release of it's contents.  The distance to the toxic endpoint (200 ppm)as determined by RMPComp version 1.06 would impact public receptors. By implementing administrative controls in the form of written operating procedures,we have reduced the tank's design capacity by 314,000 lbs. 
The alternative release scenario (ARS) for ammonia would be the failure of a p 
ipeline during the unloading of a railcar. This release would last for 25 minutes. The distance to the toxic endpoint (200 ppm) as determined by the SLAB model would impact public receptors.  
The ARS for ammonia (conc. greater than 20%) involves the overflow of a product tank. The release would last for a five minute period.The distance to the toxic endpoint (200 ppm) as determined by LPool and Gaussian Plume modeling would impact public receptors. 
The ARS for chlorine would be the release of the entire contents of a full chlorine cylinder through a sheared off liquid valve. The duration of the release would be 14.7 minutes and the distance to the toxic endpoint (3 ppm) as determined by the SLAB model would impact public receptors.         
The worst case scenario for a regulated flammable substance from the PCS Nitrogen facility would be the release of a flammable gas mixture from the CO2 Absorber and a subsequent vapor cloud explosion.The distance to the endpoint (overpressure of 1 
PSI) as determined by equations found in  EPA's OCA Guidance document would impact public receptors.  
The ARS for a regulated flammable substance would be the same scenario as for  worse case using the equations found in the OCA guidance document. This scenario does not  impact any public receptors. 
IV.  The PCS Nitrogen facility has had eight accidental releases of anhydrous ammonia in the past five years. The largest release was 7300 lbs. approximately four years ago. Most of these releases were vented through high stacks and none had any offsite impact. 
The PCS Nitrogen facility has not had any reportable accidental releases of ammonia (Greater than 20% concentration), chlorine, or flammable gas mixtures in the last five years.  
V. Prevention Program 
We prevent accidents by adhering to OSHA's PSM standard and by: 
Designing for Safety... 
*Process equipment designed per industry code 
*Automatic and manual shutoff devices are provided at critical locations 
*Process areas routin 
ely monitored by operators for leaks and spills 
*System designs incorporate multiple layers of protection/redundant safeguards 
Maintaining our Plant... 
*Maintenance personnel are trained and are skilled craftsmen 
*Critical equipment including tanks, relief devices, hoses, piping, instruments and shut down systems         tested and inspected to assure proper operation 
*Preventative Maintenance (PM) program conducted by qualified instrumentation, electrical and mechanical   technicians 
*Equipment is tested and rechecked by Operations after it is worked on by Maintenance 
Operating Safely... 
*Operators are trained and certified to operate the plant safely 
*Continuous computer, operator monitoring and surveillance 
*Written operating procedures and operational standards based on process risk analysis 
*Controlled entry to process areas and work permit system to control hazardous work in the areas 
Auditing our Operations... 
*Operator and Management safety inspections 
*Prestartup safety  
reviews prior to startup of new or modified equipment in the area 
*Process hazard analysis conducted on all equipment and processes 
*Design changes reviewed for proper design and complete documentation 
*Routine audits conducted to assure safe practices 
*Investigation of all accidents and incidents to determine root cause 
*Failure Mode and Effects analyses are performed on all pieces of equipment in the plant 
VI.   Emergency Response Program 
Training and preperation... 
*  Plant Emergency Response Plan 
*  Simulation drills conducted regulary 
*  Critiques of drills and actual events 
*  Emergency Response Team available 24 hours per day 
*  Emergency Response Team trained in Hazardous Materials, Fire fighting and rescue 
*  Certified Emergency Medical personnel on the Emergency Response Team 
*  Participate in simulation drills with community responders 
*  Off - Site Emergency Response to transportation emergencies 
If a Release Occurs... 
*  Fire monitors provide a water spray to cool ta 
nk and supress vapors 
*  Fence line monitoring and computer modeling 
*  Emergency Response Team can be activated 
*  Computer system provides real time weather conditions 
*  Preplanned release scenarios available to provide quick preliminary evaluation of impact 
*  Emergency response equipment located throughout the facility                                                                     
VII. Planned Changes to Improve Safety 
     Hazardous Materials training for the Emergency Response Team is scheduled for the last quarter of 1999 and will again be included in the training agenda for the year 2000.  PCS is in the process of building two training rail cars fitted with high pressure ammonia domes.  These rail cars will be used to provide additional training for the Emergency Response Team and other employees.  PCS is also planning to provide Chemical Smart Tags that contain chemical safety information printed for every product shipped.  These tags will be attached to each truck, ra 
il car, and container that is loaded with PCS products.
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