Faustina Plant - Executive Summary

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EXECUTIVE SUMMARY - IMC-Agrico, Faustina Facility 
2425  LDEQ Facility ID Number 
1.    Accident Release Prevention and Emergency Response Policies 
The IMC-Agrico, Faustina Facility has a long standing commitment to worker and public safety. This commitment is demonstrated by resources invested in accident prevention, such as personnel training, emergency equipment, participation in St. James Parish emergency drills, meetings with other companies and the St. James Parish emergency operations center, and meetings with the Ascension Parish emergency response organizations. 
This commitment is also consistent with the corporation's environmental, health and safety policy which provides that: 
1)  All facilities will be designed, operated, and managed to protect the health and safety of the employees and the public;  
2)  All employees will be educated on the applicable environmental, health and safety standards, and procedures;  
3)  Sufficient human and financial resources will be allocated 
to sustain these goals;  
4)  Audits will be conducted regularly to verify compliance with this policy. 
These corporate policies also emphasize the importance of complying with OSHA's Process Safety Management standard, so that all employees and the surrounding community will be adequately protected from potential fire, explosion and /or toxic hazards associated with catastrophic releases. 
It is IMC-Agrico's policy to implement reasonable controls to prevent foreseeable releases of regulated and hazardous substances.  If an accidental release does occur, IMC-Agrico trained personnel will respond to control and contain the release.  IMC-Agrico has a comprehensive program for complying with safety and environmental regulations for all regulated and other hazardous substances handled. 
2.    Stationary Source(s) and Regulated Substance(s) Handled 
The IMC-Agrico, Faustina Facility produces granular monoammonium phosphate (GMAP), and diammonium phosphate (DAP) crop nutrients.  The raw mat 
erials used in this process include molten sulfur, phosphate rock, natural gas mixtures (flammable), air and steam.  In the ammonia plant, a catalytic reaction involving natural gas, steam and air is used to manufacture anhydrous ammonia with carbon dioxide as a by-product.  Some of the anhydrous ammonia produced is then separated and stored for use in the granulation plants.  In the sulfuric acid plants, molten sulfur is burned with air in an enclosed vessel to produce sulfur dioxide. The sulfur dioxide is then converted to sulfur trioxide and mixed with water to produce sulfuric acid.  In the Phosphoric Acid plant, sulfuric acid is reacted with phosphate rock to produce phosphoric acid.  In the granulation plants, phosphoric acid is reacted with the anhydrous ammonia to produce granular monoammonium phosphate and / or diammonium phosphate.  Chlorine is used for water treatment in the cooling towers associated with the sulfuric acid plants and the utilities area. 
Regulated toxic subs 
tances involved in these processes include: anhydrous ammonia, chlorine, sulfur dioxide and sulfur trioxide.  Anhydrous ammonia and chlorine are the only regulated toxic substances that exceed their threshold planning quantities at the Faustina facility.  As sulfur dioxide and sulfur trioxide are fully consumed as intermediates in the production process, they are not present in quantities in the process that exceed their applicable threshold planning quantities.  Regulated flammable substances involved in these processes that exceed threshold planning quantities include the flammable gas mixtures reacted and generated in the ammonia plant.  
Anhydrous ammonia is stored in a large refrigerated storage tank surrounded by a dike.  In addition to the anhydrous ammonia manufactured in the facility's ammonia plant, the Faustina facility also receives anhydrous ammonia via an underground commercial pipeline, as well as by ship and barge at the facility's river dock on occasion.  Chlorine is b 
rought into the facility in multiple cylinders by trucks.  These cylinders are then individually connected to the process. Natural gas is received at the facility by an underground commercial pipeline which is connected by piping to the ammonia plant. 
3.    Worst-Case Release Scenario(s) and Alternative Release Scenario(s) 
The worst case release scenario at the Faustina Facility is a toxic release involving the loss of the entire contents of the refrigerated  anhydrous ammonia storage vessel over a period of ten minutes into the dike surrounding the tank. The pool of liquid ammonia spilled into the dike then evaporates based on parameters stipulated in the RMP regulations.  Calculations were based on information in EPA's Offsite Consequence Analysis guidance document.  Those calculations established that the distance to the 0.14 mg/L toxic endpoint had offsite impacts.  However, this worst case release scenario is unlikely to occur based on the material properties of the liquefied anhy 
drous ammonia and the design of the refrigerated storage vessel.  A worst case scenario was also computed for a chlorine release, but the distance to the toxic endpoint was less than that for anhydrous ammonia. 
The IMC-Agrico, Faustina facility has no worst case or alternative case release scenarios for regulated flammable substances in a covered process that have offsite consequences.  Calculations performed in accordance with information in EPA's Offsite Consequence Analysis guidance document showed no scenarios that reached the offsite flammable endpoints of 1 psi overpressure for unconfined vapor cloud explosions, or radiant heat exposures of 50 kW/m2 for 40 seconds from fires involving accidental releases of these regulated flammable substances. 
A number of alternative release scenarios were evaluated at the Faustina facility for toxic releases of both anhydrous ammonia and chlorine.  Most of these scenarios did not result in offsite impacts.  The alternative release scenario re 
sulting in the farthest distance to the toxic endpoint for anhydrous ammonia involved the rupture of a pressurized anhydrous ammonia pipe with the equivalent of a one-inch diameter hole.   Again, information in EPA's Offsite Consequence Analysis document was used to predict the distance to the 0.14 mg/L toxic endpoint.  Using the standard alternative case parameters in the RMP rule, the distance to the toxic endpoint was determined to have offsite impacts.  As no credit was taken for active and passive mitigation measures, local weather conditions, and the topography was chosen as rural terrain, this alternative release scenario is conservative. 
The alternative release scenario resulting in the farthest distance to the toxic endpoint for chlorine was a valve failure on a chlorine storage cylinder.  The criteria contained in Pamphlet 74, entitled "Estimating the Area Affected by a Chlorine Release," from the Chlorine Institute was used to select the case.  The EPA's Offsite Consequence 
Analysis document was used to predict the distance to the 0.0087 mg/L toxic endpoint.  Using the standard alternative case parameters in the RMP Rule, the distance to the toxic endpoint was determined to have offsite impacts.  As no credit was taken for active mitigation measures, local weather conditions and the topography was chosen as rural terrain, this alternative release scenario is conservative. 
4.    General Accidental Release Prevention Program and Chemical Specific Prevention Steps 
Anhydrous ammonia, chlorine and flammable mixtures are regulated as a highly hazardous chemicals under OSHA's Process Safety Management (PSM) standard.  Based on the quantities of these substances present at the Faustina facility, the Faustina facility is subject to OSHA's PSM requirements, and therefore, the Faustina facility satisfies the eligibility requirements for a Program 3 Prevention Program under EPA's RMP.  The Faustina facility has fully implemented OSHA's PSM standard requirements and i 
s using this program as its RMP Prevention Program. A brief summary of the facility's PSM program is as follows: 
IMC-Agrico, Faustina facility encourages all employees to participate in all facets of process safety and accident prevention.  And has an employee participation plan that documents the many ways employees are involved in these processes. 
IMC-Agrico, Faustina facility also has a comprehensive program to help ensure that hazards associated with various processes are identified and controlled.  Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards through the use of process hazard analysis techniques. 
IMC-Agrico, Faustina facility periodically revalidates its process hazard analyses to incorporate regulatory changes, new developments (such as lower toxicity standards and technology improvements), and offsite consequences.  These revalidations occur every five years and the find 
ings along with their resolutions are kept for the life of the process.  The revalidation process is currently underway. 
IMC-Agrico, Faustina facility has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition.  The basic aspects of this program include: (1) Conducting training; (2) Developing written procedures; (3) Performing inspections and tests in accordance with recognized standards; and (4) Correcting identified deficiencies and applying quality assurance measures. 
IMC-Agrico, Faustina facility  also has procedures in place to ensure continuation of the entire PSM program, including: writing and periodically updating operating procedures; training operators and maintenance personnel; management of change programs; contractor safety programs; plus developing an audit schedule that meets OSHA PSM requirements. 
IMC-Agrico, Fausti 
na facility has incorporated a number of redundant safety features to prevent and / or minimize releases of regulated substances:  
The large refrigerated anhydrous ammonia storage vessel is actually double-walled.  The storage vessel is constantly monitored by operators for ammonia leaks and has continuous monitoring electronic leak detection equipment with control room alarm monitoring the annular space between the double wall for ammonia leaks.  Typically, the vessel operates significantly below maximum capacity.  In the event of a long term compressor outage, the anhydrous ammonia could be flared; sent to another ammonia producer in nearby Ascension Parish; or consumed in the granulation plants.  In the event of a vessel rupture, there is a dike completely surrounding the vessel sufficiently high to contain its entire contents with a margin of safety.  There is also an internal dike within the main dike that would keep smaller spills from spreading out to the maximum area of the di 
ke thus reducing spill evaporation.  A series of relief valves connected to a flare also protect the tank from overpressure. 
Other smaller pressurized anhydrous ammonia storage vessels in the ammonia plant have relief valves that are piped directly to a flare system or vented to atmosphere.  Other ammonia relief valves are placed such that a discharge is elevated and would be significantly diluted before reaching areas affecting people.  There are also automated shutdown systems for the anhydrous ammonia manufacturing plant at the site. 
Chlorine cylinders are provided by vendors who are required to maintain and inspect their mechanical integrity prior to shipping.  Visual inspections are also performed by Faustina facility personnel prior to accepting delivery of chlorine cylinders and prior to placing them in use. 
Measures to prevent the accidental release of the flammable gases in the ammonia plant and to minimize the effects of any accidental releases include: redundant instrumen 
ts, backup systems, and water deluge systems. 
5.    Five -Year Accident History 
The five-year accident history includes a review of all accidental releases of regulated substances held above threshold quantities in covered processes that resulted in on-site deaths, injuries, or significant property damage, or known off-site deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage.   In October of 1997, the Faustina facility experienced a fire in the ammonia plant that resulted in equipment damage, but no injuries or offsite impacts.  In October 1995, a release of anhydrous ammonia in the ammonia plant resulted in injury to an employee, but no offsite impacts. 
6.    Emergency Response Program 
IMC-Agrico, Faustina facility maintains a written emergency response program that is in place to protect worker and public safety as well as the environment.  The program consists of procedures for responding to releases of regulated and other substances, including 
the possibility of ammonia releases, chlorine releases, fire or explosion.   
IMC-Agrico, Faustina  facility is located in St. James Parish Louisiana and is also very close to Ascension Parish.  When an emergency situation arises requiring outside assistance, Faustina's overall emergency response program is coordinated with the St. James Parish Emergency Operations Center (St. James EOC).  Via this organization, Faustina works closely with other emergency response organizations including the sheriffs of both parishes, St. James and Ascension Parish emergency response personnel, Louisiana State Police and Prevost Memorial Hospital in Donaldsonville.  Faustina has 24 hour capability to communicate with these organizations.  Faustina uses an Incident Command System for emergency response.  
IMC-Agrico, Faustina facility is an active member of the St. James Parish mutual aid, Geismar Area Mutual Aid group of Ascension Parish and the Baton Rouge Mutual Aid Organization.  These groups inclu 
de parish government and major area industries. 
IMC-Agrico, Faustina facility has an emergency equipment  maintenance, inspection, and testing program.  In addition, Faustina employees receive training for the use of emergency response equipment, emergency response, medical assistance,  and the Incident Command System.  There is a significant number of appropriately trained personnel on each shift, and all employees receive a periodic training update.  The emergency response program is periodically audited.  Appropriate changes are made in response to audit recommendations and operating experience.   
IMC-Agrico, Faustina facility periodically tests its emergency response program.  The testing consists of onsite testing of emergency response equipment, in plant drills, and periodic mock emergency response scenarios coordinated by the St. James EOC.   The Faustina facility also includes TV and radio station telephone numbers in its emergency response plan. 
7.    Planned Changes to Improv 
e Safety 
The IMC-Agrico, Faustina facility  is working to timely resolve all action items generated as a result of internal audits and process hazard analysis.  The facility is also planning to perform nondestructive testing on a scheduled basis on the anhydrous ammonia storage vessel to verify mechanical soundness from potential cracks and other sources of corrosion.
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