American Fertilizer Company, Inc. - Executive Summary

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             Risk Management Plan (RMP) - Ammonia 
                      Executive Summary 
              American Fertilizer Company, Inc. 
                       Pueblo, Colorado 
 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 
timely manner. 
Operating Procedures 
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 
(Appendix B). 
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 
Mechanical Integrity 
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. 
Pre-startup Reviews 
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. 
Compliance Audits 
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. 
Employee Participation 
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 
this period. 
 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 
(Appendix A).
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