PCS Nitrogen Fertilizer, L.P. - Memphis Plant - Executive Summary |
|
Executive Summary PCS Nitrogen Fertilizer, L.P.-Memphis Plant Millington, TN 1. Accidental Release Prevention and Emergency Response Policies We at PCS Nitrogen Fertilizer, L.P. - Memphis Plant are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Memphis & Shelby County Emergency Management Agency which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facili ty's primary activities consist of manufacturing nitrogen-based chemicals (ammonia and urea) and carbon dioxide. We have 3 regulated substances present at our facility. These substances include Ammonia (anhydrous), Ammonia (aqueous, concentration 20% or greater) and Formaldehyde (solution). The regulated substances at our facility are involved in several uses. Ammonia (anhydrous) is a manufactured product, as well as a feedstock chemical in the urea production process. Ammonia (aqueous) is a by-product of the urea production process. Formaldehyde (solution) is an additive used as a conditioning agent in the prilling portion of the urea production process. The maximum inventory of Ammonia (anhydrous) at our facility is 33,345,700 lb. while Ammonia (aqueous) and Formaldehyde (solution) are present at our facility in quantities of 184,750 lb. and 477,400 lb., respectively. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative contr ols and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Anhydrous Ammonia Production, Shipping, and Storage. The scenario involves the release of 2,600,000 lb. of Ammonia in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 22 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. One alternative release scenario has been submitted for each toxic substance present in Program 2 and Program 3 processes cumulatively. The alternative release scenario for Ammonia (anhydrous) involves a release from Pressurized Ammoni a Storage Sphere #1 in the Anhydrous Ammonia Production, Shipping, and Storage process. The scenario involves the release of 9,660 lb. of Ammonia in a gaseous form over 15 minutes. The release is also assumed to be controlled by active mitigation measures that include water curtain(s) and emergency shutdown systems. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.43 miles. The alternative release scenario for Ammonia (aqueous) involves a release from Urea Production. The scenario involves the release of 3,750 lb. Liquid is assumed to be released to form a pool from which evaporation takes place. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.28 miles. The alternative release scenario for Formaldehyde (solution) involves a release from Urea Production. The scenario involves the release of 3,000 lb. Liquid is assumed to be released to form a pool from which eva poration takes place. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.012 mg/L of Formaldehyde (solution) is 0.28 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition, ASME, and local building codes. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. We also have applied for an operating permit under Title V of the Clean Air Act. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information PCS Nitrogen Fertilizer, L.P. - Memphis Plant mai ntains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our 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 typically the Hazard and Operability (HAZOP) study method. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five (5) years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, PCS Nitrogen Fertilizer, L.P. - Memphis Plant maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emer gency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training PCS Nitrogen Fertilizer, L.P. - Memphis Plant 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 at least every four (4) years and more frequently as needed. Mechanical Integrity PCS Nitrogen Fertilizer, L.P. - Memphis Plant carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, th ese personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at PCS Nitrogen Fertilizer, L.P. - Memphis Plant 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 made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at PCS Nitrogen Fertilizer, L.P. - Memphis Plant. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits PCS Nitrogen Fertilizer, L.P. - Memp his Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation PCS Nitrogen Fertilizer, L.P. - Memphis Plant 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 situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation PCS Nitrogen Fertilizer, L.P. - Memphis Plant truly 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 improveme nts. In addition, our 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 in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. PCS Nitrogen Fertilizer, L.P. - Memphis Plant has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History PCS Nitrogen Fertilizer, L.P. - Memphis Plant has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, the number of accidental releases ha s been reduced to a minimum. There have been 6 accidental releases of regulated substances from our facility within the last 5 years. The first release took place on 08/18/95 and involved 2,115 lb. of Ammonia. The incident was a result of equipment failure. There were no known impacts either onsite or offsite. Another release, of 329 lb. of Ammonia, occurred on 06/08/96 due to equipment failure. There were no known impacts either onsite or offsite. Another release, of 664 lb. of Ammonia, occurred on 07/03/96 due to equipment failure. There were no known impacts either onsite or offsite. Another release, of 455 lb. of Hydrogen, 361 lb. of Ammonia and 254 lb. of Methane, occurred on 10/24/97 due to equipment failure. There were no known impacts either onsite or offsite. Another release, of 4,456 lb. of Ammonia, occurred on 10/03/98 due to equipment failure. There were no known impacts either onsite or offsite. Another release, of 225 lb. of Ammonia, occurred on 06 /07/99 due to equipment failure. There were no known impacts either on site or offsite. 6. Emergency Response Plan PCS Nitrogen Fertilizer, L.P. - Memphis Plant carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Memphis/Shelby County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Continued development of the facility's M.U.S.T. behavior-based safety program, continued use of root cause incident investigation techniques, and installation of a new computerized maintenance management system are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by December 31, 1999. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Brent E. Heimann Signature: Title: Plant Manager Date signed: June 18, 1999 |