Martin Gas Sales, Inc. - Executive Summary |
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EXECUTIVE SUMMARY Martin Gas Sales, Inc. Tampa, Florida Accidental release prevention and emergency response policies At the Martin Gas Sales, Inc. Tampa, Florida facility, we handle ammonia, which is considered a hazardous toxic gas by the U.S. Environmental Protection Agency (EPA). It is necessary to observe certain safety precautions in handling ammonia 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 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 Gas Sales, Inc. are strongly committed to employee, public, and environmental safety. This commitment is demonstrated by our comprehensi ve 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 regulated substances. If an accidental release should occur, the facility is prepared to work with the Tampa Bay Regional Planning Council and other authorities, to mitigate any release and minimize the impact of the release to people and the environment. Facility description and regulated substances handled The Martin Gas Sales, Inc. Tampa, Florida facility uses anhydrous ammonia in the manufacturing of aqueous ammonia. Anhydrous ammonia is delivered to our facility via truck transport and is stored at the facility prior to process use. The maximum amount of anhydrous ammonia stored is administratively limited to 87% of the facility's capacity. Anhydrous ammonia is reacted with soft or deionized water (acc ording to customer specification) to manufacture a 30% concentration of aqueous ammonia. Aqueous ammonia is stored in a bulk storage tank pending delivery via truck transport. The maximum amount of aqueous ammonia stored is administratively limited to 85% of the facility's capacity. Aqueous ammonia is distributed for use as a liquid fertilizer. The regulated toxic substances handled at our Tampa facility are anhydrous and aqueous ammonia. The maximum quantity of anhydrous ammonia that can be stored at the facility is 210,000 pounds in one 30,000-gallon and one 15,000-gallon storage tanks. The maximum quantity of aqueous ammonia that can be stored at the facility is 170,000 pounds in one 45,000-gallon storage tank. 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 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 the release occurs under the worst weather conditions. To eval uate the worst-case release scenario, we have utilized RMP*Comp, EPA recommended software. The toxic endpoint for ammonia is 0.14 mg/l (200 PPM). Based on 140,000 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 170,000 pounds and a toxic endpoint distance of 1.0-miles. 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 Tampa facility is the failure of a flexible liquid transfer hose while transferring anhydrous ammonia from a truck transport to a storage tank. The flexible transfer ho se is connected to iron piping. The release would be limited to the amount of anhydrous ammonia in the transfer hose and iron piping. Excess flow valves at the storage tanks and truck transport function to stop the flow of anhydrous ammonia out of the storage tank and truck transport. Air activated emergency shut-off valves and manually operated block valves are present at the off-loading rack to contain anhydrous ammonia in the hard-piped portion of the delivery lines. The amount anhydrous ammonia released would be limited to 980 pounds, the amount of liquid anhydrous ammonia in the transfer hose between the truck transport and the facility's storage tanks. RMP*Comp modeled the distance endpoint for the release of 980 pounds of anhydrous ammonia as 0.2 mile. The aqueous ammonia alternative release scenario selected by Martin personnel for evaluation involves the failure of a flexible liquid transfer hose while transferring product from a truck transport to the storage tank. The release would be limited to the amount of aqueous ammonia in the flexible transfer hose and iron piping between the truck transport and the storage tank. Excess flow valves in the storage tank and the truck transport would immediately close if a transfer hose failed, thereby containing vessel contents and eliminating any contributions to the release. Air activated emergency shut-off valves and manually operated block valves are present at the off-loading rack to contain ammonia in the hard-piped portion of the product delivery lines. The maximum amount of aqueous ammonia contained in the transfer hose and piping is 390 pounds. 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 tha t 0.1-mile. The general accidental release prevention program and the specific prevention steps Our Tampa 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 provisions of Safety Requirements for the Storage and Handling of Anhydrous Ammonia, K-61.1, published by the American National Standards Institute, Inc., and 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 Gas Sales, Inc. maintains a detailed record of safety information that desc ribes the chemical hazards, operating parameters, and equipment designs associated with the ammonia process. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that the hazards associated with our ammonia process 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 once 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 process, Martin Gas Sales, 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 reg ularly reviewed and is readily accessible to operators involved in the process. Training Martin Gas Sales, Inc. has a comprehensive training program to ensure employees are competent in the operations and procedures associated with the ammonia process. Mechanical Integrity The Tampa 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 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. 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 Martin Gas Sales, Inc. 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 Gas Sales, 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 Tampa 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 Gas Sales, Inc. promptly investigates any incident that resulted in, or could reasonably result in a catastrophic re lease of ammonia. 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 Gas Sales, Inc., that process safety management and accident prevention are a team effort. Our company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. Contractors Occasionally, Martin Gas Sales, 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 process. Contractors are also informed of all the procedures for emergency response should an accidental release of ammonia occur. Five-year accident history The Martin Gas Sales, Inc. Tampa facility has an excell ent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no accidental release of ammonia 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 response program The Tampa facility has a written emergency response program, in accordance with OSHA standard, 29CFR 1910.120, 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 Tampa facility. Periodic evaluations are pr eformed to assess the maintenance of safe conditions. There are no additional specific ammonia safety recommendations for implementation at this time. |