Martin Resources, Inc. - Executive Summary
EXECUTIVE SUMMARY |
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
At the Martin Resources, Inc. Plainview, Texas facility, we handle anhydrous ammonia, which is considered a hazardous toxic gas by the U.S. Environmental Protection Agency (EPA). It is necessary to observe certain safety precautions in handling anhydrous ammonia to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle anhydrous ammonia, the safety devices inherent in the design of this facility, the safe handling procedures that we use, and the training of our personnel.
We at Martin Resources, Inc. are strongly committed to employee, public, and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention pro
gram 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 anhydrous ammonia. If an accidental release should occur, the facility is prepared to work with the Plainview Fire Department to mitigate any release and minimize the impact of the release to people and the environment.
FACILITY DESCRIPTION AND REGULATED SUBSTANCES HANDLED
We at the Martin Resources, Inc. use anhydrous ammonia in the manufacturing of ammonium sulfate, fertilizer pellets, and liquid fertilizers. Anhydrous ammonia is delivered to our facility via rail car or truck transport and is stored in aboveground storage tanks at the facility prior to process use. The maximum amount of anhydrous ammonia at our facility is administratively limited to 89% of the facility's capacity.
The regulated substance handled at our facility is anhydrous am
monia. The maximum quantity of anhydrous ammonia that can be stored at this facility is 690,000 pounds in two 55,000-gallon, one 23,000-gallon, and one 12,000-gallon storage tanks.
THE WORST-CASE RELEASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIO, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO
The EPA defines worst-case release scenario for toxic gases as the failure of our largest storage tank when filled to the greatest amount allowed. The entire contents of the tank are assumed to be released as a gas over a ten-minute period. Passive mitigation measures (e.g., enclosures) may be taken into account. The toxic endpoint is the threshold for serious injury from exposure to a toxic substance in the air.
The worst-case release scenario as defined by the EPA is highly unlikely to occur. In reality, a vapor release would not occur; some quantity of anhydrous ammonia would remain in liquid form. During the evaluation, th
e scenario assumes none of the facility's mechanical controls or safety systems are operational, assumes no emergency response efforts take place, and assumes it occurs under the worst weather conditions.
To evaluate the worst-case release scenario, we have utilized RMP*Comp? the EPA recommended software. The toxic endpoint for anhydrous ammonia is 0.14 milligrams/liter (mg/L) or 200 parts per million (PPM). Based on 270,000 pounds of anhydrous ammonia released, the distance the affects of a vapor cloud is expected to have no serious harm to the general public is 8.9 miles from the location of the storage tank.
The EPA states an alternative release scenario as a release that is more likely to occur than the worst-case scenario and will reach an endpoint off-site. Active and passive mitigation systems may be considered for the alternative release scenario.
The alternative release scenario deemed most likely to occur at the facility is the failure of a flexible liquid transfer hose w
hile transferring anhydrous ammonia from a rail car to the storage tank. The flexible transfer hose is connected to iron piping. Excess flow valves at the storage tanks and rail car function to stop the flow of anhydrous ammonia out of the storage tank and rail car. Therefore, the anhydrous ammonia released would be limited to 600 pounds, the amount of anhydrous ammonia in the transfer hose and iron piping between the rail car and the facility's storage tanks.
The entire contents of the flexible transfer hose and iron piping will be released within the estimated time it would take facility personnel to identify a failure and implement actions to stop the release. RMP*Comp? estimates the distance to the point of dispersion to 200 PPM or to disperse enough to no longer pose a hazard to the public as 0.5-mile.
THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PREVENTION STEPS
Martin Resources, Inc. complies with the Occupational Safety and Health Administration (OSHA
)'s Process Safety Management (PSM) rules, EPA's Chemical Accident Prevention Risk Management Plan (RMP) rules and with all applicable state codes and regulations. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements under 40 CFR Part 68. Additionally, our facility has implemented the provisions of Safety Requirements for the Storage and Handling of Anhydrous Ammonia, K-61.1, published by the American National Standards Institute, Inc., and the standards of 29 CFR Part 1910.111, Storage and handling of anhydrous ammonia. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Martin Resources, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the anhydrous ammonia process.
Process Hazard Analysis
Our personnel conduct comprehen
sive studies to ensure that the hazards associated with our anhydrous ammonia process are identified and controlled efficiently. The methodology used to carry out these analyses is a What if/Checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at least once every five years. Any findings related to the hazard review are addressed in a timely manner.
For the purposes of safely conducting activities within our anhydrous ammonia process, Martin Resources, Inc. maintains written operation 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 is regularly reviewed and is readily accessible to operators involved in the process.
Martin Resources, Inc. has a comprehensive training program
to ensure employees are competent in the operations and procedures associated with the anhydrous ammonia process.
Martin Resources, Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes; 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. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at the facility 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
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Martin Resources, Inc. The reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment into operations.
Martin Resources, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
Martin Resources, Inc. promptly investigates any incident that resulted in, or could reasonably result in a catastrophic release of anhydrous ammonia. These investigations are undertaken to identify the situation leading to the incident as well as any corrective acti
ons to prevent the release from reoccurring. All investigation reports are retained for a minimum of five years.
It is our belief at Martin Resources, Inc., that process safety management and accident prevention are a team effort. Our company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.
Occasionally, Martin Resources, Inc. hires contractors to conduct specialized maintenance or construction activities. We have a strict policy of informing the contractors of known potential hazards related to the contractor's work and the process. Contractors are also informed of all the procedures for emergency response should an accidental release of a anhydrous ammonia occur.
FIVE-YEAR ACCIDENT HISTORY
The facility has had an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no acciden
tal release of anhydrous ammonia during this period that resulted in deaths, injuries, or significant property damage onsite, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
EMERGENCY RESPONSE PROGRAM
The facility has a written emergency action plan in accordance with the OSHA PSM rules. The emergency action plan includes appropriate mechanisms for notifying emergency responders when there is a need for response. The facility is listed in the community emergency response plan. This satisfies the requirements of the RMP rules.
PLANNED CHANGES TO IMPROVE SAFETY
Safety improvement is an on-going process at the facility. Periodic evaluations are performed to assess the maintenance of safe conditions. To better monitor our facility, we are planning to install a video system in the summer of 1999.