Martin Resources, Inc. - Executive Summary |
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EXECUTIVE SUMMARY Martin Resources, Inc. Rochelle, Georgia Accidental release prevention and emergency response policies At the Martin Resources, Inc. Rochelle, Georgia facility, we handle anhydrous and aqueous ammonia, which are considered hazardous toxic substances by the U.S. Environmental Protection Agency (EPA). We also handle propane, which the EPA considers a hazardous flammable gas. It is necessary to observe certain safety precautions in handling ammonia and propane to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle ammonia and propane combined with the safety devices inherent in the design of this facility combined with the safe handling procedures that we use and the training of our personnel. We at Martin Res ources, Inc. are strongly committed to employee, public, and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program 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 regulate substances. Unforeseeably, if such a release does occur, we are completely coordinated with Wilcox Emergency Management which provides highly trained emergency response personnel to control and mitigate the effects of the release. Facility description and regulated substances handled The Martin Resources, Inc. Rochelle, Georgia facility uses anhydrous ammonia in the manufacturing of aqueous ammonia. Anhydrous ammonia is delivered to the facility via rail car and is stored in aboveground storage tanks at the facility prior to process use. The anhydrous ammonia is react ed with water to manufacture aqueous ammonia. Aqueous ammonia is stored in a bulk storage tank pending delivery via truck transport. Aqueous ammonia is distributed for use as a liquid fertilizer. The regulated toxic substances handled at our Rochelle facility are anhydrous and aqueous ammonia. The maximum quantity of anhydrous ammonia that can be stored at the facility is 390,000 pounds in three 30,000-gallon storage tanks. The maximum quantity of aqueous ammonia that can be stored at the facility is 210,000 pounds in one 45,000-gallon storage tank. The regulated flammable substance handled at our Rochelle facility is propane. The maximum quantity of propane that can be stored at the facility is 220,000 pounds in two 30,000-gallon storage tanks. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario The EPA defines worst-case release scenario for toxic substances as the failure of our largest storage tank when filled to the greatest amount allowed. For toxic gases, the entire contents of the tank are assumed to be released as a gas over a ten-minute period. For toxic liquids, the entire contents of the tank are assumed to spill instantaneously to form a liquid pool. The rate of release to air is determined from the volatilization rate of the liquid pool. Passive mitigation measures (e.g. enclosures, dikes) may be taken into account. The toxic endpoint is the threshold for serious injury from exposure to a toxic substance in the air. The worst-case release scenario as defined by the EPA is highly unlikely to occur. In reality, a vapor release would not occur; some quantity of anhydrous ammonia would remain in liquid form. During the evaluation, the scenario assumes none of the facility's mechanical controls or safety systems are operational, assumes no emergency response efforts take place, and assumes it occurs under the wor st weather conditions. To evaluate the worst-case release scenario, we have utilized RMP*Comp, the EPA recommended software. The toxic endpoint for ammonia is 0.14 mg/L (200 PPM). Based on 130,000 pounds of anhydrous ammonia released, the distance the affects of a vapor cloud is expected to have no serious harm to the general public is 4.4-miles from the location of the storage tank. The worst-case release scenario for aqueous ammonia yielded a release of 210,000 pounds and a toxic endpoint distance of 1.1-miles. The EPA defines worst-case release scenario for flammable substances as the failure of our largest storage tank when filled to the greatest amount allowed. The entire contents of the tank are assumed to release as a vapor cloud, which finds an ignition source. Ten percent of the released quantity is assumed to participate in the resulting explosion. This worst-case scenario as defined by the EPA is also highly unlikely to occur. During the evaluation, the scenario assumes none of the facility's mechanical controls or safety systems are operational, assumes no emergency response efforts take place, and assumes it occurs under the worst weather conditions. Martin Resource, Inc. has incorporated a company policy that limits the maximum filling capacity of all propane storage tanks to 88% at 60:F. Therefore, our worst-case release scenario would result in a release of 110,000 pounds of propane from a 30,000-gallon storage tank. Based on 110,000 pounds of propane released, RMP*Comp calculated the distance the affects of a vapor cloud explosion is expected to have no serious harm to the general public is 0.4-mile from the location of the storage tank. The EPA states an alternative release scenario as a release that is more likely to occur than the worst-case scenario and will reach an endpoint off-site. Active and passive mitigation systems may be considered for the alternative release scenario. The alternative release scenario for anhydrous ammonia deemed most likely to occur at the Rochelle facility is the failure of a flexible liquid transfer hose while transferring anhydrous ammonia from a rail car to the storage tank. The 4-inch flexible transfer hose is connected to iron piping. Excess flow valves at the storage tanks and rail car function to stop the flow of anhydrous ammonia out of the storage tank and rail car. Therefore, the anhydrous ammonia released would be limited to 740 pounds, the amount of anhydrous ammonia in the transfer hose and iron piping between the rail car and the storage tanks. The entire contents of the flexible transfer hose and iron piping will be released within the estimated time it would take for facility personnel to identify a failure and implement actions to stop the release. RMP*Comp estimates the distance to the point of dispersion to 200 PPM or to disperse enough to no longer pose a hazard to the public as 0.2-mile. The alternative release scenario for aqueous ammonia deemed mos t likely to occur at the Rochelle facility is the failure of a flexible transfer hose while transferring aqueous ammonia from the storage tank to a truck transport. The 3-inch flexible transfer hose is connected to iron piping. Excess flow valves at the storage tanks and truck transport function to stop the flow of aqueous ammonia out of the storage tank and truck transport. Therefore, the aqueous ammonia released would be limited to 350 pounds, the amount of aqueous ammonia in the transfer hose and iron piping. The entire contents of the flexible transfer hose and iron piping will be released within the estimated time it would take for facility personnel to identify a failure and implement actions to stop the release. RMP*Comp estimates the distance to the point of dispersion to 200 PPM or to disperse enough to no longer pose a hazard to the public is less than 0.1-mile. The alternative release scenario deemed most likely to occur for propane is the failure of a flexible transf er hose. The transfer hose connects to iron piping. Excess flow valves at the storage tank and truck transport function to stop the flow of propane out of the storage tank and truck transport. Therefore, the propane released would be limited to 150 pounds of propane, the amount in the transfer hose and iron piping. In this alternative release scenario, the entire contents of the transfer hose and piping would be released before facility personnel could implement actions to stop the release. RMP*Comp estimates the distance endpoint for the release of 150 pounds of propane to no longer pose a hazard to the public as 0.03-mile. The general accidental release prevention program and the specific prevention steps Our Rochelle facility complies with the Occupational Safety and Health Administration (OSHA)'s Process Safety Management (PSM) rule, EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements under 40 CFR part 68 of the EPA. Additionally, our facility has implemented the standards of the OSHA 29 CFR 1910.111, Storage and handling of anhydrous ammonia. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Martin Resources, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the ammonia and propane processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that the hazards associated with our ammonia and propane processes are identified and controlled efficiently. The methodology used to carry out these analyses is a "What-If" checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at least on ce every five years. Any findings related to the hazard review are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our ammonia and propane processes, Martin Resources, Inc. maintains written operation procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency 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 Martin Resources, Inc. has a comprehensive training program to ensure employees are competent in the operations and procedures associated with the processes. Mechanical Integrity The Rochelle facility carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes; pressure vessels, storage tanks, piping sy stems, relief and vent systems, emergency shutdown systems, controls, and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. 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 the Rochelle, Georgia facility 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 Martin Resources, Inc. The reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment into operations. Compliance Audit The Rochelle facility 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 three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Martin Resources, Inc. promptly investigates any incident that resulted in, or could reasonably result in a catastrophic release of anhydrous ammonia, aqueous ammonia, or propane. 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 investigation reports are retained for a minimum of five years. Employee Participation It is our belief at Martin Resources, Inc., that process safety management and accident prevention are a team effort. Our employees are strongly encouraged to express t heir views concerning accident prevention issues and to recommend improvements. Contractors Occasionally, Martin Resources, Inc. hire contractors to conduct specialized maintenance or construction activities. We have 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 ammonia or propane occur. Five-year accident history The Martin Resources, Inc. Rochelle, Georgia facility has an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no accidental release of anhydrous ammonia, aqueous ammonia, or propane during this period that resulted in deaths, injuries, or significant property damage onsite, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency re sponse program The Rochelle facility has a written emergency response program, in accordance with OSHA standard, 29CFR 1910.119, including pre-emergency planning and employee training, to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notifications of local emergency response agencies and the public, as well as post-incident decontamination of affect areas. Planned changes to improve safety Safety improvement is an on-going process at the Rochelle facility. Periodic evaluations are preformed to assess the maintenance of safe conditions. There are no additional specific ammonia or propane safety recommendations for implementation at this time. |