SENTURY REAGENTS - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
Sentury Reagents has been safely handling Anhydrous Ammonia since 1993. There have been no incidents regarding the release of Ammonia during this time. There have been no injuries or first aid cases among workers during this time as a result of exposure to Ammonia. The storage and handling of Anhydrous Ammonia is regulated by many agencies and regulations, these include State and Federal OSHA, State and Federal EPA, and the Department of Transportation. Sentury, its management and employees, are commited to the safe operation of its facility and the protection of the public and environment. The management has many years of experience in the safe handling and storage of Anhydrous Ammonia. The facility design meets all State and Federal requirements and is inspected by the management at regular prescribed intervals to insure safe operations.
FACILITY AND REGULATED SUBSTANCES HANDLED
The portion of our facility which
concerns the use of Anhydrous Ammonia consists of a 50,000 lb. storage vessel, ten feet of 2" liquid piping, 150 feet of 1" liquid piping and sixty five feet of 1" gas piping. The material is stored as a liquified gas under pressure. The pressure in the tank varies from 40 - 100 pounds per square inch depending on the storage temperature of the liquid. The processes involved are very simple involving the introduction of Anhydrous Ammonia as a gas or liquid to enclosed vessels. Once the material has entered the processes it is no longer Anhydrous Ammonia.
THE WORST CASE SCENARIOS
The worst case scenario assumes that the storage tank is at its maximum level allowed by regulation discharging in ten minutes. For this to happen a failure in the ten feet of 2" piping or a 2" hole in the storage tank on the very bottom of the storage tank must occur. It also assumes that the excess flow valve in the outlet line fails to operate. The storage tank has the capacity to store 58,325 lbs.
Ammonia, but by regulation only 85% of the capacity can be used. Exceeding this level is prevented by administrative means using trained operators, unloading check sheets and trained truck drivers. The piping and related systems are rated for over 2,000 lbs. per square inch and are inspected every thirty days for leaks and or deterioration. The tank is rated for in excess of 265 lbs. per square inch with dual relief valves to prevent over pressure. The tank undergoes visual inspection every 90 days and undergoes non-destructive testing by professional engineering companies every five years. Relief valves are replaced five years from the date of manufacture. All piping, valves and other components are regulated and are certified for use in Anhydrous Ammonia service.
ALTERNATIVE RELEASE SCENARIO
The alternative release scenario involves the malfunction of a relief valve causing it to fail open and pass the maximum design flow until the contents of the tank refrigerate to ambient
pressure. The scenario assumes that the tank contains 50% of the maximum contents at the time of failure. To prevent malfunction the valves are replaced on a regular schedule and the tank is operated at less than 40% of the pressure set point. No passive or active measures were considered in this scenario. This scenario was chosen as the alternative release scenario because the relief valves are the only opening to the atmosphere in the system. All other possible scenarios would have to involve a rupture of a 1" pipe which could be brought under control immediately by an operator. The 1" lines are not in service unless an operator is present.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTIVE STEPS
The process utilizing Anhydrous Ammonia which includes its storage and handling are covered under OSHA's PSM rule. This requires the facility to do the following, HAZOP of all process, regular mechanical inspections, operator training, management of chan
ge procedures, pre-start up safety review, hot work permitting, compliance audits, and emergency planning. The RMP regulations requiring this report expands the PSM regulations to include the qualification of worst case and alternative case releases.
The most important practices to prevention of release are the proper maintenance of piping and vessels, and proper operator training.
FIVE YEAR ACCIDENT HISTORY
There have been no accidental Ammonia releases since the material was brought on site in 1993.
THE EMERGENCY RESPONSE PROGRAM
We coordinate with the Leslie Fire Department for emergency response. All personnel are trained in the proper emergency response. There are no public notification and alert systems internal, these would be handled by the York County Emergency Response Group which receives a copy of this plan.
PLANNED CHANGES TO IMPROVE SAFETY
The facility will continue to audit these systems, and respond to near misses or releases with proper investigation and appr