El Paso Valley Cotton Association, Inc. - Executive Summary
EXECUTIVE SUMMARY |
Accidental Release, Prevention, and Emergency Response Policies
El Paso Valley Cotton Association, Inc. is committed to providing the optimum protection of employee and public safety and health. It is the policy of El Paso Valley Cotton Association to assure, so far as possible, that every employee has a safe and healthful place in which to work. El Paso Valley Cotton Association is dedicated to providing the resources necessary to fulfill these commitments. It is also the policy of the company to expect each employee, contract employee and visitor to live up to the responsibility of following all safety rules and committing to safety.
It is El Paso Valley Cotton Association's policy to ensure adequate emergency response capabilities exist to handle both on-site and off-site emergencies regarding RMP-covered chemicals. El Paso Valley Cotton Association executes this policy through employee training, and coordination with local emergency response agencies.
The El Paso Valley Cotton Association facility is located at 13205 Richfield Street in Clint, Texas. The facility is situated on Tract 9, Block 20, San Elizario Grant, El Paso County, Texas. Facility Latitude is 31-Degrees 35-Minutes 17- Seconds, Longitude 106-Degrees 13-Minutes 33-Seconds. El Paso Valley Cotton Association handles Anhydrous Ammonia at this facility. Anhydrous Ammonia is delivered, stored and transferred to small portable tanks for use by farmers as an agricultural nutrient.
El Paso Valley Cotton Association unloads Anhydrous Ammonia from both rail cars and transport trucks. The unloading process uses an air compressor to pressurize the unloading vessels and force the Anhydrous Ammonia through the transfer lines into the Anhydrous Ammonia storage tank. This process is repeated in the transfer of the Anhydrous Ammonia from the storage tank to the portable transport vessels (nurse tanks). The storage vessel has a maximum water capacity of 30,000 ga
llons which at a density of 5.15 pounds per gallon equates to 154,500 pounds of storage capacity for anhydrous ammonia. However, normal operating conditions are for the storage tank to maintain a volume of 85% or 131,325 pounds. El Paso Valley Cotton Association is also covered under the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) of Highly Hazardous Chemicals, 29 CFR 1910.119. Therefore, the facility is subject to Program 3 requirements as identified in the RMP.
Summary of Hazards
Anhydrous Ammonia (NH3) at normal temperatures and pressures, is a colorless gas made up of one part nitrogen and three parts hydrogen. It is lighter than air and has a sharp, pungent odor that serves as a warning of its presence. While Anhydrous Ammonia is a relatively toxic substance, it is not a cumulative poison. It is highly soluble in water and forms a solution known as ammonium hydroxide (NH4OH) or aqua Anhydrous Ammonia (commonly used as a household cle
Commercially, Anhydrous Ammonia is made by combining free nitrogen and hydrogen gases under high pressure and temperature in the presence of a catalyst. The process most commonly used is the Harber-Bosch method. Industrial Grade Anhydrous Ammonia serves as the most economically abundant and efficient agricultural nutrient for the produce industry. Its pungent odor serves as a self-alarming characteristic.
Anhydrous Ammonia, (anhydrous means without water), is the liquid form of pure Anhydrous Ammonia gas, technically water-free, and the substance is used universally as an agricultural nutrient. Other advantages are low initial cost and low pipe friction losses.
For transport purposes, Anhydrous Ammonia is classified as a non-flammable gas by the U.S. Department of Transportation (DOT). The nitrogen component of the substance is inert in the combustion reaction and accounts for the limited flammability of Anhydrous Ammonia. The flammable limits at atmospheric pressure
are 16% to 25% (by volume) of Anhydrous Ammonia in air. Ammonia's high lower limit of flammability and low heat of combustion substantially reduce its combustion-explosion and fire hazards.
Exposure to Anhydrous Ammonia causes intense irritation to the surface tissues of the eyes, nose, throat and lungs. Exposure to high concentrations of Anhydrous Ammonia may blind, burn, strangle or kill. The effect of Anhydrous Ammonia on the skin is that of a caustic burn, varying in severity with the concentration of Anhydrous Ammonia and the length of time exposed. Changes in respiratory and heart action are produced as reflex actions resulting from the irritation of the respiratory tract.
Worst-Case Release Scenario
The worst-case scenario for the El Paso Valley Cotton Association facility is a release of 131,325 pounds of Anhydrous Ammonia from the system's largest vessel, the Anhydrous Ammonia storage tank, over a ten-minute period.
The toxic endpoint used is 200 parts per million
(0.14 milligrams per liter), as defined in the EPA's Risk Management Program Guidance for Ammonia. With a wind speed of 3.0 meters per second, and a Stability Class of F in a rural area, the endpoint was calculated to be 5.6 miles from the storage tank, using the RMP*Comp? modeling software. The public receptors within a circular area with this radial distance from the facility are schools, public parks, residential areas, and commercial buildings. The total population of this area was estimated to be 23,600, based on U.S. Census data obtained from USEPA Envirofacts Warehouse.
Alternate Case Release Scenario
The Alternate Case Release Scenario for the El Paso Valley Cotton Association facility was chosen to be a rupture in a liquid line. The specific line chosen was a two-inch diameter liquid feed line, which runs from the unloading station to the storage tank. The release duration was selected to be 15 minutes. The line has an average operating pressure of 200 psig. The pipi
ng run is approximately 80 feet in length and experiences an approximate 12-foot change in elevation from the unloading station to the storage tank. The toxic endpoint used was 200 parts per million (0.14 milligrams per liter), as defined in the EPA's Risk Management Program Guidance for Ammonia. Using a wind speed of 1.5 meters per second, and a Stability Class of D in an urban area, the endpoint was calculated to be 0.5 miles from the facility, using the RMP*Comp? modeling software. The public receptors within a circular area with this radial distance from the facility are schools, residential areas, and commercial buildings. The total population of this area was estimated to be 170, based on U.S. Census data obtained from USEPA Envirofacts Warehouse.
Pollution Prevention Program
Process Safety Information
Process Safety Information (PSI) relating to the covered processes is divided into three categories: chemical hazards, process technology, and process equipment. PSI relati
ng to the chemical hazards is included in MSDS's, that are kept in readily accessible locations for all employees. PSI relating to the process technology and the equipment in the process is being collected and filed in the Operations office area. El Paso Valley Cotton Association has reviewed the Process Safety Information on November 30, 2000.
Process Hazard Analysis
Process Hazard Analyses (PHA) will be conducted on each covered process every five years, or when the process changes. A PHA on the Anhydrous Ammonia transfer, storage and loading processes has not been conducted. A PHA will be conducted by a team of knowledgeable individuals representing, at a minimum: Operations, Maintenance, Engineering, and Safety. The PHA will address the hazards of the process, identification of previous incidents that had a likely potential for a catastrophic release, and engineering and administrative controls applicable to the hazards in the process. El Paso Valley Cotton Association conduct
ed the primary Process Hazards Analysis on November 29-30, 2000.
Written Operating Procedures for the Anhydrous Ammonia railcar unloading are currently in place. Procedures are currently under development for unloading of tank trucks and loading of Nurse Tanks. All Operating Procedures will include provisions for initial startup, normal operations, emergency operations, normal shutdown, and startup following a shutdown. The Operating Procedures will also address the operating limits and the consequences of deviation from those operating limits. Safety and health considerations are an integral component of the Operating Procedures. El Paso Valley Cotton Association expects to finalize the Operating Procedures not later than December 8, 2000.
El Paso Valley Cotton Association provides on-the-job and classroom training to employees responsible for operating the Anhydrous Ammonia unloading and transfer system. The trainees must demonstrate, to the sa
tisfaction of the supervisor, that they possess the skills and knowledge to perform the required duties prior to being assigned the responsibilities. Refresher training on the Operating Procedures will be provided at a minimum every three years. Hazard Communication and Chemical Training are provided to each employee. El Paso Valley Cotton Association expects to finalize the Training Procedures not later than December 15, 2000.
El Paso Valley Cotton Association is currently developing written instructions for inspection and testing of pressure vessels, storage tanks, piping systems (including valves), relief and vent system devices, emergency shutdown systems and controls that are part of Anhydrous Ammonia unloading and transfer system. Tests and inspections will follow applicable and acceptable codes and standards and will be performed at a frequency called for by the applicable and acceptable codes and standards, or more frequently if appropriate. Maintenan
ce employees will be trained on the acceptable work practices relating to the inspection and testing requirements. El Paso Valley Cotton Association expects to have written instructions for inspection and testing of the Anhydrous Ammonia equipment not later than November 10, 2000. El Paso Valley Cotton Association expects to provide refresher training to Maintenance employees on acceptable work practices relating to the inspection and test requirements not later than December 15, 2000.
Management of Change
El Paso Valley Cotton Association is currently developing a written Management of Change (MOC) procedure that will ensure that proposed changes to the Anhydrous Ammonia unloading and transfer system will address: the technical basis of the proposed change; the impact on safety and health; modifications to operating procedures; the time period of the change; and the authorization requirements for the proposed change. The procedure will also address employee training and updating
of Process Safety Information. El Paso Valley Cotton Association expects to finalize the Management of Change Procedures not later than December 15, 2000.
Pre-Startup Safety Review
El Paso Valley Cotton Association is currently developing a written Pre-Startup Safety Review (PSSR) procedure. The procedure will confirm that prior to introduction of Anhydrous Ammonia to new or modified equipment: construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency response procedures are in place; the MOC requirements have been met; a Process Hazards Analysis has been performed (if necessary); and that employees have been properly trained. El Paso Valley Cotton Association expects to finalize the Pre-Startup Safety Review Procedures not later than December 15, 2000.
El Paso Valley Cotton Association plans to conduct a compliance audit of both the PSM and RMP program at the Clint, Texas facility at least every five ye
ars. The initial audit of the PSM and RMP program in place at the Plant is planned for January 12, 2001. The audit will consist of a records review, evaluation of on-site conditions, and interviews with employees. The audit will be conducted by an independent consulting company.
Incident Investigations will be conducted for each incident that resulted in or could have reasonably resulted in a catastrophic release of a covered chemical. Investigation teams will be comprised of representatives from Safety, Maintenance, Production, and any other affected group (i.e. contractors). Investigations will be initiated within 48 hours of the incident, or sooner. Investigation reports will contain, at a minimum: date of incident, description of the incident, investigation team members, factors contributing to the incident, and the recommended corrective actions. Management will review open corrective action items on a regular basis to ensure they receive a high pr
iority for accomplishment.
The El Paso Valley Cotton Association actively encourages employee participation at all levels of development, implementation, and maintenance of the RMP program at the Clint, Texas facility.
Hot Work Permit
The El Paso Valley Cotton Association facility is revising the Hot Work Program. The permit system will cover such items as: appropriate fire protection, fire watch requirements, timeframe for work to be conducted, equipment to be worked on, the responsible individual for the work, and appropriate signatures/approval. El Paso Valley Cotton Association expects to have the Hot Work Program fully modified not later than November 30, 2000.
The El Paso Valley Cotton Association facility is fenced and locked after hours. Security is maintained by way of a main entrance to the facility. Contractors must stop at the office and cleared for entry. El Paso Valley Cotton Association is currently developing a contractor
approval procedure that will ensure that the contractor's safety record is considered prior to selection. Additionally, El Paso Valley Cotton Association is developing a program to ensure that all contractors receive appropriate training on the hazards of the Anhydrous Ammonia system prior to working at the facility. El Paso Valley Cotton Association expects to complete these programs not later than November 30, 2000.
Five-Year Accident History
El Paso Valley Cotton Association has had no releases of RMP-covered chemicals which resulted in on-site deaths, injuries, or significant property damage or known off-site deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place. In preparation of this RMP El Paso Valley Cotton Association reviewed files of previous incidents at the facility.
Emergency Response Program
The El Paso Valley Cotton Association facility is considered to be a Non-Responding Facility under 40 CFR Part 68.90. El Paso Valley
Cotton Association is currently developing a comprehensive Emergency Response Plan, to include coordination with the appropriate local agencies. El Paso Valley Cotton Association expects to have a completed Emergency Response Plan, and have local agency coordination not later than December 15, 2000.
Planned Changes to Improve Safety
A PHA was conducted on the Anhydrous Ammonia system the week of October 27, 2000. El Paso Valley Cotton Association will use this PHA to develop a comprehensive PSM program that will meet the requirements of RMP. El Paso Valley Cotton Association commits to having the above described policies and procedures implemented and all administrative controls in place for both RMP and PSM no later than January 26, 2001.