HAWKINSVILLE FERTILIZER, INC. - Executive Summary |
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EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At the Hawkinsville Fertilizer, Inc., Hawkinsville, Georgia facility, we handle anhydrous ammonia, which is considered a hazardous toxic substance by the U. S. Environmental Protection Agency (EPA). We also handle propane, which the EPA considers a hazardous flammable gas. It is necessary to observe certain safety precautions in handling ammonia and propane 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 ammonia and propane, 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 Hawkinsville Fertilizer, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program 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 regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with Pulaski Emergency Management which provides highly trained emergency response personnel to control and mitigate the effects of the release. FACILITY DESCRIPTION AND REGULATED SUBSTANCES HANDLED Hawkinsville Fertilizer, Inc. sales anhydrous ammonia to area farmers as a source of nitrogen. Anhydrous ammonia is delivered to the facility via transport and is stored in above-ground storage tanks at the facility prior to sale. The regulated toxic substance handled at our facility is anhydrous ammonia. The maximum quantity o f anhydrous ammonia that can be stored at the facility is 100,000 pounds in two 12,000 gallon storage tanks. The regulated flammable substance handled at our facility is propane. The maximum quantity of propane that can be stored at the facility is 130,000 pounds in two 18,000 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 substances as the failure of our largest storage tank when filled to the greatest amount allowed. For toxic gases, the entire contents of the tank are assumed to be released as a gas over a ten-minute period. For toxic liquids, the entire contents of the tank are assumed to spill instantaneously to form a liquid pool. The rat of release to air is determined from the volatilization rate of the liquid pool. Passive mitigation measures (e.g. enclosures, dikes) 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, the 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 ammonia is 0.14 mg/L (200 PPM). Based on 100,000 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 3.2-miles from the location of the storage tank. The EPA defines worst-case release scenario for flammable subst ances as the failure of our largest storage tank when filled to the greatest amount allowed. The entire contents of the tank are assumed to release as a vapor cloud, which finds an ignition source. Ten percent of the released quantity is assumed to participate in the resulting explosion. This worst-case scenario as defined by the EPA is also highly unlikely to occur. During the evaluation, the 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. Hawkinsville Fertilizer, Inc. has incorporated a facility policy that limits the maximum filling capacity of all propane storage tanks to 88% at 60oF. Therefore, our worst-case release scenario would result in a release of 67,000 pounds of propane from a 18,000 gallon storage tank. Based on 67,000 pounds of propane released, RMP*Comp calculated the distance the affects of a vapor clo ud explosion is expected to have no serious harm to the general public is 0.2-mile 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 for anhydrous ammonia deemed most likely to occur at the facility is the failure of a flexible liquid transfer hose while transferring anhydrous ammonia from a transport to the storage tank. The 3-inch flexible transfer hose is connected to iron piping. Excess flow valves at the storage tanks and transport function to stop the flow of anhydrous ammonia out of the storage tank and transport. Therefore, the anhydrous ammonia released would be limited to 555 pounds, the amount of anhydrous ammonia in the transfer hose and iron piping between the transport and the storage tanks. T he entire contents of the flexible transfer hose and iron piping will be released within the estimated time is would take for 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 +/- 0.2-mile. The alternative release scenario deemed most likely to occur for propane is the failure of a flexible transfer hose. The transfer hose connects to iron piping. Excess flow valves at the storage tanks and truck transport function to stop the flow of propane out of the storage tank and truck transport. Therefore, the propane released would be limited to 150 pounds of propane, the amount in the transfer hose and iron piping. In this alternative release scenario, the entire contents of the transfer hose and piping would be released before facility personnel could implement actions to stop the release. RMP*Comp estimates the d istance endpoint for the release of 150 pounds of propane to no longer pose a hazard to the public as 0.03-mile. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PREVENTION STEPS Hawkinsville Fertilizer, 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 68. Additionally, our facility has implemented the standards of 29 CFR 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 Hawkinsville Fertilizer, Inc. maintains a detailed record of safety information that describes the chemical hazards, ope rating parameters, and equipment designs associated with the ammonia and propane processes. Process Hazard Analysis Hawkinsville Fertilizer, Inc. conducts comprehensive studies to ensure that the hazards associated with our ammonia and propane processes are identified and controlled efficiently. The methodology used to carry out these analysis 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 lease once every five years. Any findings related to the hazard review are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our ammonia and propane processes, Hawkinsville Fertilizer, Inc. maintains written operation procedures. These procedures address various modes of operation such as initial startle, 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 esses. Training Hawkinsville Fertilizer, Inc. has a comprehensive training program to ensure employees are competent in the operations and procedures associated with the processes. Mechanical Integrity Hawkinsville Fertilizer, 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 a 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 p rocedures. 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 the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Hawkinsville Fertilizer, 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. Compliance Audit Hawkinsville Fertilizer, 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. Incident Investigation Hawkinsville Fertilizer, Inc. promp tly investigates any incident that resulted in, or could reasonably result in a catastrophic release of anhydrous ammonia, or propane. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All investigation reports are retained for a minimum of five years. Employee Participation It is our belief at Hawkinsville Fertilizer, Inc. that process safety management and accident prevention are a team effort. Our employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. FIVE-YEAR ACCIDENT HISTORY The facility has an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no accidental release of anhydrous ammonia or propane during this period that resulted in deaths, injuries, or significant property damage onsite, or know n off-site deaths, injuries, evacuations, sheltering in place, property damage of environmental damage. EMERGENCY RESPONSE PROGRAM The facility has a written emergency action plan in accordance with the 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. There are no additional specific ammonia or propane safety recommendations for implementation at this time. |