Agrium US Inc, West Sacramento Nitrogen Operations - Executive Summary
1. Accidental Release Prevention and Emergency Response Policies |
Agrium U.S. Inc., West Sacramento Nitrogen Opertions handles anhydrous ammonia which is considered hazardous material and is a regulated substance under the California Accidental Release Program (CalARP) and is considered in this Risk Management Plan (RMP). The properties of anhydrous ammonia make it necessary to observe safety precautions in handling anhydrous ammonia 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 California rules and regulations. The prevention of accidental releases depends on adherence to the safe procedures used to handle anhydrous ammonia; the safety devices and systems designed and constructed into the facility; and the training of the pertinent personnel.
2. Stationary Source and Regulated Substances Handled
Agrium U.S. Inc. is situated on the ea
stern central edge of Yolo County, southwest of the main portion of the City of West Sacramento in the Port of Sacramento Industrial Park, on the Sacramento River Deep-Water Ship Channel. The facility functions as a chemical distribution center and a chemical manufacturing facility. The facility is a distribution center for anhydrous ammonia throughout California. The anhydrous ammonia is delivered to the site by ship and distributed from the site by truck and rail-car. The facility manufactures two fertilizers urea-ammonium nitrate solution (UAN-32) and ammonium nitrate solution (AN-20). In addition,the plant produces industrial grade 83% and 76% ammonium-nitrate solution. (AN-83/AN-76). The process operations at the facility that use anhydrous ammonia are:
1) Anhydrous ammonia is received by ship for storage and distribution by rail-car and truck.
2) Anhydrous ammonia is used to refrigerate the anhydrous ammonia in the atmospheric
storage tanks and the warm a
mmonia storage tank.
3) Anhydrous ammonia and air are used to produce nitric oxide which is combined with water to
produce 57%/53% nitric acid.
4) Anhydrous ammonia and 57%/53% nitric acid are used to produce 83%/76% ammonium nitrate.
5) Water and 83%/76% ammonium nitrate are used to produce the AN-20 with, anhydrous
ammonia used to control the pH of the AN-20 solution.
3a. Worst Case Release Scenario
The Worst Case release scenario for interconnected equipment must consider the largest quantity of a regulated substance handled on site in a single vessel at any time, taking into account administrative controls. 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 warm ammonia tank yields the greatest distance to the end-point and is designated as the Worst Case r
elease scenario. The distance to the end-point of 200 ppm for the Worst Case scenario for anhydrous ammonia is beyond the boundaries of the stationary source.
3b. Alternative Release Scenario
The Alternative Release scenario for anhydrous ammonia, as submitted, is the most frequent credible release scenario. This is the instantaneous release (taken as one minute) of 1,320 lb of 37 degrees Fahrenheit gaseous warm ammonia from a tank truck or rail-car relief valve operation due to overfilling, causing overpressurization of the tank truck or rail-car. The distance to the end-point of 200 ppm for the Alternative Release scenario for anhydrous ammonia is beyoind 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 exists to restrict to a minimum the amount of anhydrous 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 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 to restrict the amount of anhydrous ammonia released to a minimum if a release were to occur. The mitigation measures are based upon the design, inspection, testing, and maintenance of the processes and systems that use anhydrous ammonia and their related equipment and components.
4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps
The facility complies with applicable federal and state codes and regulations. There are safety meetings and safety training. The Process Safety Management (PSM) program is one part of a comprehensive loss control program implemented at the facility for the anhydrous ammonia processes and systems. The
implementation of PSM, safety related 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 two RMP criteria incidents involving the release of anhydrous ammonia within the past five years at the UWSP site.
On December 17, 1996 at 1900 hours, there was a release of 30 lb during 5 minutes due to not following procedure for venting a railroad tank car in preparation for maintenance activity.
On March 23, 1998 at 1800 hours, there was a release of 950 lb during 150 minutes from a flare due to restricted flow from ammonium carbonate buildup.
6. Emergency Response Program
The details of the Emergency Response Program for the anhydrous ammonia processes at the plant are contained within two documents. One is the Emergency Preparedness Action Plan which contains all of the emergency response program elements. It is intended to be a compliance, ref
erence and training guide. The other is the Emergency Response-Pull Out which is a field guide for response actions based on the chemical involved. It is intended to be used by the response personnel while responding to an emergency event. The Emergency Response Program incorporates procedures for alerting personnel at the facility to evacuate the facility and await the arrival of responders from the City of West Sacramento Fire Department at the evacuation assembly location, if a release occurs that causes the evacuation to be initiated. The Yolo County - Office of Emergency Services incorporates this response into the County Area Plan for the Regional Local Emergency Planning Committee. The program also includes procedures for notification of ouitside emergency responders, appropriate agencies and immediate neighbors in the event of a release. The plant has an emergency response team on site at all times, trained in accordance with the HAZWOPER regulation, 29 CFR 120. The plant c
onducts emergency internal drills and joint drills with the Fire Department.
7. Planned Changes To Improve Safety
There is one action item, with a risk ranking of 2, from the Covered Process Hazard Analysis Revalidation element of the Process Safety Management (PSM) program to be completed. This action item is to complete a feasibility study on installing a water quench system on the ammonia tank relief devices. An informal review of this item has been completed with no major issues identified. A formal study is expected to be completed by January 15, 2000. Current applicable codes and regulations are reviewed as part of PSM to determine if other commitments need to be made to achieve increased operational safety for the regulated anhydrous ammonia processes and systems. These commitments will be prevention and mitigation measures for accidental releases of the regulated substances.