Kennewick Fertilizer Operations - Finley Area - Executive Summary |
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EXECUTIVE SUMMARY - KFO Finley Area 1. Accidental Release Prevention and Emergency Response Policies Agrium's "Kennewick Fertilizer Operations (KFO)" is comprised of three facilities known as the Kennewick, Hedges, and Finley Areas. The Finley Area handles anhydrous ammonia and aqua ammonia that are considered hazardous materials and are regulated substances under the Federal Accidental Release Program (ARP) and are considered in this Risk Management Plan (RMP). The properties of these chemicals make it necessary to observe safety precautions in handling them to prevent human exposure, and to reduce the threat to the facility's workers and nearby members of the community. It is the facility's policy to adhere to all applicable Federal and State of Washington rules and regulations. The prevention of accidental releases depends on adherence to the procedures used to handle anhydrous ammonia and aqua ammonia; the safety devices and systems designed and constructed into the facility; and the training of the pertinent personnel. The various programs and documents are found in the facility's comprehensive loss control system. 2. Description of the Stationary Source and Regulated Substances Handled The Finley Area produces anhydrous ammonia for feedstock to the Kennewick Area and for shipment off-site via railcars and tank-trucks. Ammonia is transferred to the Kennewick Area via pipeline. The manufacturing of ammonia uses basic principles of chemistry with readily available ingredients. Natural gas, water and air are the raw materials used to manufacture anhydrous ammonia at the Finley Area. Natural gas from the Northwest Pipeline provides fuel and feedstock. Water is supplied from the Columbia River for cooling and steam production and ambient air is used as a source of nitrogen. With the aid of catalysts, heat exchangers and compressors, the natural gas is reformed into hydrogen and combined with nitrogen to yield ammonia that is then liquefied and stored for transport via pipeline to the Kennewick Area. There are two Ammonia Plants at the Finley Area, #1 Plant and #2 Plant; however, in the compression and synthesis processes, their gas streams merge to form one gas stream. 3a. Worst-Case Release Scenario The Worst Case release scenario for interconnected equipment must consider the maximum contents of each vessel or pipeline that contains a regulated substance above the threshold quantity. Administrative controls may be taken into account when determining maximum quantity. In addition, smaller quantities of the regulated substance handled at higher process temperature or pressure must be considered if such a scenario would result in a greater distance to an end-point beyond the stationary source boundary. The Worst Case scenario did not consider any administrative control to limit the amount of regulated substance in any subject vessel. The ammonia storage sphere C-510A with anhydrous ammonia yields the greatest distance to the e nd-point and is designated as the Worst Case release scenario. The distance to the end-point of 200 ppm for the Worst Case scenario, determined by RMP*COMP, is beyond the boundaries of the stationary source. 3 b. Alternative Release Scenarios The Alternative Release scenario for anhydrous ammonia, as submitted, is the most credible release scenario with the greatest distance to endpoint. This is the continuous release of liquid anhydrous ammonia from a railcar loading arm due to sudden disconnection. This results in the release of gaseous ammonia at the rate of 3,550 lb/min for 1 minutes. The distance to the end-point of 200 ppm for the Alternative Release scenario for the anhydrous ammonia, determined by RMP*COMP, is beyond the boundaries of the stationary source. The Alternative Release scenario for anhydrous ammonia, as submitted, is the most credible release scenario with the greatest distance to endpoint. This is the continuous release of the 25% liquid aqua ammonia from PSV 1-059 on the shell side E-166 due to overpressure. This results in the release of gaseous ammonia from the 77?F aqua ammonia at the rate of 2,019 lb/min for 45 minutes. The distance to the end-point of 200 ppm for the Alternative Release scenario for aqua ammonia, determined by RMP*COMP, is beyond the boundaries of the stationary source. 3c. Administrative Controls Administrative controls are in place to prevent accidental releases. Additional administrative controls, to limit the distances for each reported scenario, exist to minimize the amount of anhydrous ammonia and aqua ammonia, if an accidental release were to occur. These administrative controls are inherent in the operational procedures for the equipment, processes and systems that use anhydrous ammonia and aqua ammonia, as well as part of the training provided to the operators of these processes and systems. 3d. Mitigation Measures Mitigation measures to limit the distances for each reported scenario exist that mi nimize the amount of anhydrous ammonia and aqua ammonia released to a minimum, if a release were to occur; and preferably to not have a release occur. The mitigation measures are based upon the design, inspection, testing, and maintenance of the processes, systems and related equipment and components that use anhydrous ammonia and aqua ammonia. 4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The facility complies with all applicable federal and state codes and regulations. There are safety meetings and safety training. The Process Safety Management (PSM) program is one part of the comprehensive loss control system implemented at the facility for the anhydrous ammonia and aqua ammonia processes and systems. The implementation of PSM, Administrative Procedures and Safe Work Practices represent the facility's main active commitments to an accidental release prevention program. 5. Five-year Accident History There have been no accidents at the subject stationary source to be reported in this RMP in the previous five-year history of the facility. 6. Emergency Response Program The details of the Emergency Response Program for the anhydrous ammonia and aqua ammonia processes at the facility are contained within two documents. One is the Emergency Preparedness Action Plan that contains all of the emergency response program elements. It is intended to be a compliance, reference and training guide. The other is the On Scene Incident Management Guide that is a field guide for response actions based on the chemical involved. This guide is for use by response personnel while responding to an emergency event. The Emergency Response Program incorporates public notification and alert systems and procedures for notifying personnel at the facility to shelter-in-place or to evacuate as required. Both the shelter-in-place and evacuation procedures have designated assembly areas and personnel accounting methods included. The facili ty has qualified emergency response teams trained in accordance with HAZWOPER 29 CFR 120. The facility conducts internal emergency drills and joint drills with the Fire Department. 7. Planned Changes to Improve Safety Current applicable codes and regulations are continually reviewed as part of the PSM program to determine if specific commitments need to be made to achieve increased operational safety for the regulated anhydrous ammonia and the aqua ammonia processes and systems. These commitments are prevention and mitigation measures for accidental releases of the regulated substances. |