American Fertilizer Company, Inc. - Executive Summary
Risk Management Plan (RMP) - Ammonia |
American Fertilizer Company, Inc.
1. Accidental Release Prevention and Emergency Response Policies
We at American Fertilizer Company, Inc. in Pueblo are strongly committed to employee, public, and
environmental safety. This commitment is an inherent part of 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. If such a release does
occur, our trained emergency response personnel are at hand to control and mitigate the effects of
the release. We also coordinate our response efforts with the Pueblo County Rural Fire Department,
which provides additi
onal emergency response expertise.
2. Stationary Source and Regulated Substances Handled
Our facility's primary activities include support services for crop production. We have anhydrous
ammonia stored in one 10,000-gallon tank and in two 5,000-gallon interconnected tanks at our
facility in Pueblo (Figure 1). The maximum amount stored is 17,000 gallons (87,482 pounds) at the
maximum fill capacity of 85 %.
3. Worst Case Release and Alternative Release Scenarios
We utilized RMP PRO for the worst case and alternate case scenarios of the required offsite
consequence analysis for our facility. The following details these scenarios.
The worst case release scenario involves a catastrophic release of the entire contents of the largest
anhydrous ammonia storage tank (43,741 pounds) in gaseous form over a 10-minute period. At
Class F atmospheric stability, 1.5 m/s wind speed, and a urban topography, the maximum distance
to a toxic endpoint of 0.14 mg/L is 3.2 miles (Figure 2). The
estimated population within a 3.2-mile
radius of this facility is 1,000.
The alternative release scenario involves a release from an anhydrous ammonia product line. The
scenario involves the release of 7616.42 pounds of ammonia in a gaseous form over a period of 30
minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14
mg/L of ammonia is 0.31 mile (Figure 3). The estimated population within a 0.31-mile radius of the
facility is 25.
4. General Accidental Release Prevention Program
Our facility has taken all the necessary steps to comply with the EPA's accidental release prevention
requirements as set forth in 40 CFR part 68. The following sections briefly describe the elements
of the release prevention program that is in place at our stationary source.
Process Safety Information
American Fertilizer Co. maintains a detailed record of safety information that describes the chemical
hazards, operating parameters, and equipment designs asso
ciated with all processes (Appendix D).
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are
identified and controlled effectively. Any findings from the hazard analysis are addressed in a
American Fertilizer Co. maintains written operating procedures to ensure that activities within our
covered processes are conducted safely. These procedures address various modes of operation; the
information is regularly reviewed and is readily accessible to operators involved in the processes
American Fertilizer Co. has a comprehensive training program in place to ensure that employees
who are operating processes are competent in the operating procedures associated with these
American Fertilizer Co. conducts documented maintenance checks on process equipment to ensure
proper operation. Maintenance checks are conducted by qualified
personnel with previous training
in maintenance practices. Examples of process equipment that would receive maintenance checks
include: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency
shutdown systems, controls, and pumps. Any equipment deficiencies identified by the maintenance
checks are corrected in a safe and timely manner (Appendix C).
Management of Change
Written procedures are in place at American Fertilizer Co. to manage changes in process chemicals,
technology, equipment, and procedures. Process operators, maintenance personnel or other
employees whose job tasks are affected by a modification in process conditions are promptly notified
of the modification and offered training to deal with it.
American Fertilizer Co. routinely conducts pre-startup safety reviews related to new processes and
modifications in established processes. These reviews are conducted to confirm that construction,
equipment, and operating and
maintenance procedures are suitable for safe startup prior to placing
equipment into operation.
American Fertilizer Co. conducts compliance audits on a regular basis to determine whether the
plan's provisions, set out under the 40 CFR part 68, are being implemented. Any non-compliance
issue discovered during the audit is promptly corrected.
American Fertilizer Co. 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 implementation of the RMP, particularly
information resulting from process hazard analyses.
5. Five-year Accident History
American Fertilizer Co. has had an excellent record of preventing accidental releases over the last
5 years. Due to our stringent release preventio
n policies, no accidental release has occurred during
6. Emergency Response Plan
American Fertilizer Co. maintains a written emergency response plan to deal with accidental releases
of hazardous materials. The plan addresses all aspects of emergency response including first aid and
medical treatment, evacuations, and notification of local emergency response agencies and the public