Cargill Fertilizer, Inc. - Executive Summary |
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In response to growing public concern over the potential danger from accidental releases of hazardous substances, the United States Environmental Protection Agency (EPA) was mandated by Section 112(r)(7) of the 1990 Clean Air Act Amendments (CAAA) to establish a regulatory program to prevent serious chemical accidents that may potentially affect public health and the environment. By adding Section 112(r), which was part of Congress' response to a series of past chemical accidents with major offsite consequences, the CAAA established a new role for the EPA in chemical accident prevention. The Risk Management Plan (RMP)was prepared to fulfill the requirements of Section 112(r) of the CAAA pursuant to USEPA regulations contained in 40 Code of Federal Regulations (CFR) Part 68, Sections 68.1-68.220, Accidental Release Prevention Provisions. These regulations require stationary sources with listed substances present in a process in greater than the threshold quantity to develop and implem ent a RMP that includes a hazard assessment, a prevention program, and an emergency response program. The RMP must be registered with the USEPA, submitted to appropriate agencies, and made available to the public. This RMP was prepared by O'Brien & Gere Engineers, Inc. (O'Brien & Gere) on behalf of Cargill Fertilizer, Inc.'s (Cargill) Riverview facility. Anhydrous ammonia (ammonia) which is a regulated hazardous substance, is handled at the Riverview fertilizer manufacturing facility. The hazardous properties of ammonia make it necessary to observe safety precautions in handling the substance to prevent unnecessary human exposure, to reduce the threat to facility personal and contractors, and to reduce the threat to the community. At the Riverview facility, ammonia is stored in greater than a threshold quantity of 10,000 lbs. Ammonia is used as a raw material in the Cargill facility. The ammonia is stored in tanks as a liquefied gas. The ammonia is then piped to the monoammon ium phosphate (MAP) and diammonium phosphate (DAP) plants. Liquefied or gaseous ammonia may pose a health risk if the compressors, containers, or lines transferring the ammonia develop leaks or rupture. The quantity released, release rate, weather conditions, and topography affects the speed and direction of spread of the ammonia. Ammonia is brought into the facility via the Tampa Bay Pipeline into one storage vessel (bullet). The capacity of each bullet is 200 tons. Administrative controls at the facility limit the quantity of ammonia stored in each bullet to 175 tons. Based on a review of the applicable regulations, Prevention Program 3 requirements apply to this facility. The main focus of the prevention program is to reduce the likelihood of a release by maintaining equipment and training staff and contractors. The written RMP was developed based upon a site visit by O'Brien & Gere on August 3, 1998. During the site visit, the ammonia storage system design, operating pr ocedures and information were reviewed. Personnel responsible for environmental activities, emergency planning and coordination, and system operation and maintenance were also interviewed. A review of the system accident history and the facility Emergency Contingency Plan was also conducted. If a release does occur, the emergency response program, which is already in place, will be a key component of post-release mitigation efforts. A hazard assessment consisting of one worst-case and one alternate case release scenario was completed and hazard zones and vulnerable zones were identified. The hazard assessment was conducted in accordance with 40 CFR 68 regulations, guidance provided by the USEPA RMP Offsite Consequence Analysis (OCA) document and air dispersion modeling using DEGADIS (an EPA approved hazard analysis computer model). The hazard assessment is detailed in Sections II and III of the Data Elements, and in Appendix A. An updated RMP, including an updated offsite conse quences analysis, prevention program and management system, will be submitted within five years of its initial submission or its most recent update. A compliance audit to certify compliance with the provisions of the RMP regulations will be conducted at least every three years. A management system is in place to address and implement recommendations that entail these hazards. |