COASTAL ST. HELENS CHEMICAL - Executive Summary

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RISK MANAGEMENT PLAN 
Coastal St. Helens Chemical, St. Helens, Oregon 
 
EXECUTIVE SUMMARY 
 
Accidental Release Prevention and Emergency Response Policies. 
The Coastal St. Helens Chemical Facility has been in operation since 1966.  Since the beginning the employees and management have had accident prevention and training programs in place for the safety of the general public and employees of the facility.  These programs include detailed operator training, operating instructions, maintenance procedures, active employee safety committees, safety inspections and emergency procedures. The Facility has implemented the OSHA Process Safety Management system.  This tool has further enhanced our safety program for processes that could pose a hazard to the employees and the public.   
In the event that an accidental release were to occur, Coastal St. Helens Chemical has established an Emergency Action Plan in conjunction with the St Helens Rural Fire Dept to insure the effects will be minimized.  Ar 
rangements have also been made with Cowlitz Clean Sweep of Longview, WA. to provide additional resources to emergencies.  
 
Description of the Stationary Source and Regulated Substances. 
   The Coastal St. Helens Chemical facility produces nitrogen-based fertilizers.  Products shipped from the facility are Anhydrous Ammonia, Aqua Ammonia, Urea Prills, Urea-Ammonium Nitrate Solution and Carbon Dioxide.  These products are manufactured from natural gas, air and water.  For RMP planning purposes the whole site is considered the stationary source. 
   Anhydrous Ammonia is produced in a continuous process on site and stored for sale, converted to Aqua Ammonia, or further processing with Carbon Dioxide to manufacture Urea.  Another portion of the Anhydrous Ammonia is used to manufacture a water solution of Ammonium Nitrate, which is mixed with Urea to form a fertilizer solution. 
   The regulated substances handled on site in quantities larger than the threshold amounts are Anhydrous Ammonia and 30%  
Aqua Ammonia.  There are three active 625-ton Anhydrous Ammonia storage spheres on site and a 30% Aqua Storage tank with the capacity of 85,000 gallons. 
 
Scenarios 
   Worst-Case 
   The worst-case scenario is the catastrophic failure of a 625-ton storage sphere of Anhydrous Ammonia filled to the administrative level of 85%. The scenario assumes the release of 530 tons of Anhydrous Ammonia vapor over a ten-minute period. No mitigation was considered in this scenario.  The toxic end point from the resulting Ammonia vapor cloud would reach offsite endpoints and public receptors. 
 
   Alternate-Case Anhydrous Ammonia:  
   An alternate-case scenario is the failure of a pressure relief valve. A pressure relief valve fails in the open position and causes ammonia to vent at a rate of 730 pounds per minute.  The release is expected to be isolated within 30 minutes.  The release model indicates that distance to the toxic end point would be 0.5 miles.  This end point could reach a residential population of 
5.  Further mitigation can be achieved by using water mist from fire hoses to absorb Ammonia vapor out of the air. 
 
Alternate-Case 30% Aqua Ammonia: 
   An alternate-case scenario is the leaking of 30% Aqua Ammonia solution from a defective pump seal at the loading pump.  The leak is at the rate of 225 pounds per minute into a 130 by 80 foot diked area around the storage tank and pump.  The release is expected to be isolated within 60 minutes.  The release model indicates that the toxic end point of the Ammonia vapor cloud formed by the evaporating Ammonia would be 0.43 miles.  This end point could reach a residential population of 5.  Further mitigation can be achieved by using the sump pump in the dike to pump the leaking liquid into another tank and using water mist from fire hoses to absorb Ammonia vapor out of the air.  
 
General Accidental Release Prevention Program & Chemical Specific Prevention 
   A number of different approaches are used to prevent accidental releases from occurrin 
g at the site. 
   The process is designed for safety.  " Good Engineering Practices" is used in all design changes or additions.  A computer system is used for instrumentation and controls and is protected from power outages with a battery back up.  Vessels are equipped with various temperature, pressure and level alarms.  Remotely operated isolation valves are used.  Critical areas have secondary containment and curbing.  Fire monitors are strategically located around the process. 
   The operations program ensures fully and continuously trained operators.  Emergency shutdown systems and procedures are in use.  Prestart-up safety reviews are conducted for new and modified processes and equipment.  Management of change procedures are used.  The process equipment has safe upper and lower limits recorded.  Daily routine equipment and leak checks are carried out.  A work permit system is used for process unit installation and maintenance that covers entry control, lockout/tagout procedure, hot 
work, line taps, and confined space entry.   
   In maintaining our plant integrity, Coastal has a fully equipped maintenance department with well-trained and experienced maintenance personnel. Craft training and testing is used for certification.  A preventative maintenance program is in effect, which includes corrosion/erosion monitoring. A contractor qualification, selection and safety training procedure is in effect for all outside contractors working on site. 
In pulling the facility into a safe working team the safety department is active in total employee involvement of the safety program.  Weekly team safety meetings and monthly plant representative safety meetings are held.   Monthly safety inspection tours of the operating process are held, and monthly plant management safety meetings are held.   
In addition to the preceding accident prevention activities the facility uses the following types of safety features in the various processes for release control: 
   -Valves to permit iso 
lation of processes. 
   -Automatic shutdown systems. 
   -Duplicate pumps and compressors. 
   -Uninterruptible power supply for computer process control system. 
       -Backup firewater and boiler water pumps. 
       -Atmospheric relief devices. 
       -Curbing and diking. 
       -Backup instrument air compressor. 
 
Five-year Accident History 
   Anhydrous Ammonia: 
       There have been no releases of anhydrous ammonia that meet the EPA 
                  release criteria definition over the last five years. 
   Aqua Ammonia > 20%: 
       Over the last five years there was one release that met the EPA release  
                  criteria definition.  A release occurred in June of 1998 where occupants of  
                  several homes were advised by the fire department to shelter in place in their 
                  homes for a short time until the ammonia odor dissipated. 
 
Emergency Response Plan 
   Coastal has an Emergency Action Plan in place based upon 29 CFR 1910.38(a).  Coastal coordinates with the local fire department  
and helps prepare them to respond to emergencies at the facility.  There is an annual familiarization tour conducted through the site for the fire fighters.   Site specific training is also conducted with the firefighters.  In addition, Coastal has supplied the fire department with a monitor for determining ammonia concentrations in emergency situations. 
   Coastal is an active participant in Columbia Emergency Planning Association along with other industries and emergency agencies.  Through this association Coastal has assisted in community emergency planning and has lead tabletop training exercises involving ammonia emergencies. 
 
Planned Changes to Improve Safety 
7 Implementation of an emergency notification telephone call-down system to notify the public of releases requiring evacuation or sheltering. This is a shared project with other industries and the community. 
7 Replacing the process control computer system to come into Y2K compliance and improve plant operation. 
7 Redesign the  
inside of the First Absorber in the Urea plant to increase the stability of the process.
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