Agrium U.S. Inc. - Executive Summary |
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Borger Nitrogen Operations, Executive Summary 1. Accidental Release Prevention and Emergency Response Policies We at Agrium U.S. 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 regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Production of Anhydrous Ammonia and Urea Fertilizers. We have 2 regulated substances present at our facility. These substances include Ammonia (anhydrous) and Chlorine. Ammonia is produced and distributed for use as a nitrogen fertilizer. Chlorine is used for treating the cooling water within the process. . 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls 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 PHAST 5.20 model. For alternative release scenario analyses, we have employed the PHAST 5.20 model as well. 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 the Anhydrous Ammonia Plant. The scenario involves the release of 400,000 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 3.59 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario for Ammonia involves a release from Truck Loading in the Ammonia Plant process. The scena rio involves the release of 2,616 lb. of Ammonia in a gaseous form over 2 minutes. The release is also assumed to be controlled by active mitigation measures that include excess flow valves, emergency shutdown systems and dedicated loading personnel in the area during all loading operations. The loading personnel have been trained to take quick and appropriate actions, should a release occur. Emergecy shutdown systems are also located in other areas throughout the process. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.13 miles. The alternative release scenario for Chlorine involves a release from the Chlorine cylinder piping in the Anhydrous Ammonia Plant process. The scenario involves the release of 264.50 lb. of Chlorine in a gaseous form over 5 minutes. The release is also assumed to be controlled by active mitigation measures that include a Chlorine detection system, operational procedures and visual mo nitoring. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.07 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, as well as M.W. Kellogg specifications. The process at our facility is subject to the OSHA PSM standard under 29 CFR 1910.119 as well as EPCRA section 302 notification requirements. We also have an air operating permit ID 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 Agrium U.S. Inc. maintains a detailed record of safety information that describes the chemical hazards, opera ting 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 HAZOP methodology is used to carry out these analyses. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated as per the requirements of the OSHA PSM Standard. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 06/18/1998. Operating Procedures For the purposes of safely conducting activities within our covered processes, Agrium U.S. Inc. maintains written operating 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 i s regularly reviewed and is readily accessible to operators involved in the processes. Training Agrium U.S. Inc. 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 three years for operations personnel and more frequently as needed. Refresher training is provided annually for all loading personnel. Mechanical Integrity Agrium U.S. Inc. 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, these personnel are offered specialized training as needed. Any equipment d eficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Agrium U.S. 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 Agrium U.S. Inc.. The most recent review was performed on 10/15/1998. 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 Agrium U.S. Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 10/28/1997. 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 Agrium U.S. Inc. 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 Agrium U.S. Inc. 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 improvements. In addition, our employees have access to all information created as part of the facility's implemen tation 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. Agrium U.S. Inc. has a strict policy of informing the contractors of known potential hazards related 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 Agrium U.S. Inc. has had an excellent record of preventing accidental releases. Over the last 5 years, there has been one accidental release caused by human error that resulted in one on site injury. This release took place on 11/12/1994. The employee was taken to Golden Plains Community Hospital where he was treated for minor chemical burns and then released. No deaths or injuries occured offsite as a result of this accident. 6. Emergency Response Plan Agrium U.S. Inc. 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. 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. Hutchinson 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. Installation of a fire protection and perimeter monitoring systems are some of the major steps we want to investigate to improve safety at our facility. These changes are expected to be implemented by December 1999. |