(21) Boettcher - Executive Summary |
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EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies: The Boettcher Landing facility serves as a distribution point for agricultural fertilizers. Anhydrous ammonia is received by barge and rail and is transloaded to trucks for field delivery. The facility also supplies anhydrous ammonia by pipeline to the Wilbur-Ellis Company , which is located across the roadway. With proper care, this valuable fertilizer will be available to the agricultural community when needed at reasonable cost. Personnel safety and protection of the environment are of utmost importance. Safety for our co-workers, the community and environment depends on the proper design, installation, maintenance, and training of our personnel. It is our policy to comply with all applicable Federal and State regulations and codes. Our emergency response program is designed to comply with the requirements of several Federal and State codes and regulations. Listed below are the codes and regulations that are the basis of our emergency response program: FEDERAL: 7 The Code of Federal Regulations 29 CFR 1910.111 Storage and handling of anhydrous ammonia 7 The Code of Federal Regulations 33 CFR Part 127 Liquefied Natural Gas Waterfront Facilities STATE: 7 The State of Washington General Safety and Health Standards 296-24-510 Part F-2 Storage and handling of anhydrous ammonia Information used to develop the release prevention and emergency response program were from the following: US Department of Health, Education, and Welfare: 7 Working safely with anhydrous ammonia Manufacturing Chemists Association: 7 Chemical Safety Data Sheet SD-8 Properties and essential information for safe handling and use of anhydrous ammonia American Institute of Chemical Engineers: 7 Emergency response procedures for anhydrous ammonia vapor release Compressed Gas Association: 7 CGA G-2 Anhydrous ammonia The Fertilizer Institute: 7 Operational safety manual for anhydrous ammonia 7 Agricultural anhydrous ammonia operators manual 7 Agricultural ammonia safety 7 External visual inspection guidelines for anhydrous ammonia nurse tanks, applicator tanks, and appurtenances Also used was the information available from the various anhydrous ammonia producers. The emergency response plan includes procedures for immediate response, preliminary assessment, response, notification and agreements with local response agencies to aid in emergency responses. Audio and visual (strobe light) are utilized to alert river traffic and neighbors. Forms to document and report releases, for release notification, and for threatening phone calls are included in our plan. 2. Facility description and regulated substances handled: This facility is on property leased from the Port of Whitman by the McGregor Company. The facility is located on the north bank of the Snake River about 0.80 km (= mile) east of where Highway 127 crosses the Snake River and is in the Port of Whitman. T he area in general has fertilizer distribution facilities, grain storage, barge loading facilities, agriculture and recreation facility located about 1 mile down river and upwind. Barges deliver refrigerated ammonia from Unocal's Rivergate, Oregon and Kennewick, Washington storage terminals to Central Ferry. These barges carry refrigerated anhydrous ammonia. The ammonia is off-loaded over a 4 to 15 day period. If use of ammonia is slow due to weather requirements, the barge may require additional time to discharge. Barges will be located at the dock during both spring and fall seasons. Hours of operation are from 7:00 a.m. to 7:00 p.m. during the spring and fall season. It is estimated that each season will be 6-10 weeks in duration. This facility is designed to receive anhydrous ammonia by river barges. A marine arm is used to transfer product. The mooring area at this facility is capable of mooring only one vessel at a time. The facility provides receiving piping, an ammon ia heater, storage tanks and load out piping. All equipment including pumps, piping, valves, heaters, loading arms, storage tanks, meters, electrical and safety is designed to meet all Federal, State, County, and local codes as well as Unocal's and McGregors corporate standards for both safe and environmentally acceptable operations for storage and handling of anhydrous ammonia. Communication at the location requires coordination between the McGregor Company site; the Wilbur-Ellis Company site and the off-loading barge. This communication is accomplished by use of telephones and hand held mobile radios. During ammonia transfer, all operators are equipped with a radio with a spare available in the office for emergency use. A minimum of two persons will be on duty while ammonia is being transferred: a barge operator and a shore operator. When ammonia is being transferred to Wilbur-Ellis a minimum of three operators will be on duty. There will be an operator at each location. Whe n ammonia is not being transferred a minimum of one operator will be on duty at all times, while the barge is moored. Barge pumps deliver the -33.330C (-280F) refrigerated ammonia to a booster pump located shore side. The booster pump delivers the ammonia through a shell and tube heat exchanger which heats the ammonia to 1.670C (350F). From the heater, ammonia is delivered to the storage tanks, three (3) truck loading stations, a railcar-loading station and to Wilbur-Ellis. Ammonia delivered to Wilbur-Ellis Company is a mixture of cold and warm ammonia so that the resultant temperature is about -20.560C (-50F). The facility provides an office, a truck weigh scale and storage for diesel to refuel the barges as necessary. Propane is used as fuel for the two (2) hot water heaters needed to warm the refrigerated anhydrous ammonia from -33.330C (-280F) to 1.670C (350F). The operation areas are well lighted and safety equipment is provided throughout the facility. The facility does n ot use hoses for anhydrous ammonia transfers. All ammonia transfers are through rigid piping and swivel joint arms. Therefore, the risk of a release into the Snake River is significantly reduced. In the event of a spill or discharge into the river, the ammonia would be extremely difficult to recover. Anhydrous ammonia is highly soluble in water. Due to this solubility, standard mechanical means of containment would be ineffective, and therefore impractical. Any large ammonia releases near the bullets will be contained in the depressed area to the west of the storage area. The regulated substances at this facility are anhydrous ammonia (refrigerated and pressure) and propane. The amount of anhydrous ammonia and propane stored at this facility exceed the threshold quantities established by Federal EPA. Refrigerated ammonia is stored on the barge and pressurized ammonia in two (2) pressure tanks. The propane is stored in five (5) pressure storage tanks. 3. The worst-case rel ease scenarios and the alternative release scenarios including administrative controls and mitigation measures for each scenario: (RMP Comp version 1.06 was used) Worst-case scenario, anhydrous ammonia Failure of the largest pressure tank when filled to maximum allowable level of 86% of the water capacity would release 130,000 pounds of ammonia. The distance to toxic endpoint of 0.14 mg/L for the worst-case ammonia scenario is 6.9 miles. Alternate scenario, anhydrous ammonia The failure of the loading arm while loading an ammonia transport. The excess flow valves would close, limiting the release to the content of the arm and the 2 minutes it would take to stop the transfer pump and close the emergency valves to a quantity of 3,600 pounds. The distance to toxic endpoint of 0.14 mg/L in this scenario is 0.8 miles. Worst-case scenario, propane Failure of the largest propane tank filled to maximum allowable level would release 4,000 pounds of propane. The distance to the en dpoint for vapor cloud explosion for the worst-case propane scenario is 0.1 mile. Alternate scenario, propane Propane vaporizer fails releasing 200 pounds of propane. Water heaters not functioning, operator would stop process and shut down. The distance to the endpoint for vapor cloud explosion for this scenario is 0.1 miles. 4. The general accidental release prevention program and specific prevention steps: This facility complies with EPAs Accidental Release Prevention Rule and all other Federal and state regulations and codes. The facility was designed and constructed in accordance to 29 CFR 1910.111, 33 CFR Part 127, ANSI K61.1 and State of Washingtons General Safety and Health Standards 296-24-510 Part F-2 and with NFPA-58. Key facility personnel have received training from the McGregor Company, Unocal Corporation, the Ammonia Safety & Training Institute (ASTI) and the Far West Fertilizer & Agrichemical Association. All ammonia drivers are receiving training and an nual refresher training on product specific safety and equipment training under the Far West Fertilizer & Agrichemical Associations Ammonia Carriers Program. The facility Operations Supervisor is a certified Red Cross instructor as well as a voluntary member of the Clarkston & Central Ferry Fire Departments, certified emergency medical technician, certified Basic Life Support (BLS) and HAZMAT Technician. 5. Five-year accident history: This facility has not experienced any accidents or reportable incidences in the past 5-years. 6. The emergency response program: Due to the remote location of this facility, a local emergency response team is not available and the general population is not large enough to form this team. Unocals response team from the Kennewick, WA facility is available to respond to major releases. We held a meeting at the facility with the Port of Central Ferry Fire Department, the Port of Whitman County, and Whitman County Department of Emergency Ser vices in February of 1995. Copies of the emergence response plan and facility operations manual are located at the offices of the Whitman County Department of Emergency Services, Colfax, WA; Colfax Fire Department, Colfax, WA; Regional Office of the Department of Ecology, Yakima, WA; US EPA Region X, Seattle, WA; Corps of Engineers, Seattle District, Seattle, WA; Corps of Engineers, Walla Walla District, Walla Walla, WA; Washington State Department of Fisheries, Olympia, WA; National Marine Fisheries Service, Portland, OR; Columbia River Inter-Tribal Fish Commission, Portland, OR; Port of Whitman, Colfax, WA; US Fish and Wildlife Service, Olympia, WA; US Coast Guard, Portland, OR; Unocal offices, Brea, CA and Kennewick, WA; and the McGregor offices, Colfax, WA as well as the Central Ferry facility. 7. Planned changes to improve safety: This facility was constructed in 1990 and 1991. It was operational for the spring fertilizer season of 1991. There are no major equipment modi fications or expansions planned. Facility is in compliance with current regulations and codes. Annual pressure testing per Coast Guard requirements will be conducted prior to the spring fertilizer season. Annual refresher training on safety, equipment operations and transfer operations for all returning personnel will be completed. |