Jupiter Sulphur, LLC - Ponca City Facility - Executive Summary |
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1.0 Ponca City Facility Risk Management Plan: Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Ponca City Facility (Facility) has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of the facility's processes. The Jupiter Sulphur, Inc. (Jupiter Sulphur) policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to, control, and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Facility is located in Kay County approximately one-fourth mile south of the intersection of Highway 60 and Highway 177 in Ponca City, Oklahoma. The Facility produces and distributes chemicals used in the agriculture and chemical market. The facility has three plants (NaHS and Concentrate and ATS). Production at the Facility consists of the manufacturing of ammonium thiosulfate (ATS), ammonium sulfide (AS concentrate), ammonium bisulfite (ABS), sodium hydrosulfide, and molten sulfur. Anhydrous ammonia and hydrogen sulfide, regulated substances, are integral to the above mentioned processes. Ammonia is brought in by truck and stored in pressurized vessels. Hydrogen sulfide is piped to the Facility from processes at an adjacent refinery. The products and raw materials require loading/unloading operations at the Facility, as well as the associated process and storage equipment and piping. The Facility was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, Jupiter Sulphur identified no listed flammable substances and two listed toxic regulated substances kept on site. The chemicals, largest quantities on site, and associated threshold quantity are presente d in Table 1. TABLE 1 Largest Quantity of Regulated Substances Regulated Substances Largest Quantity On Site (lbs) Threshold Quantity (lbs) Ammonia (anhydrous) 393,975 10,000 Hydrogen Sulfide 274 10,000 Worst-Case Scenarios The only listed substance, which is stored above threshold quantity at the Ponca City Facility, is anhydrous ammonia. Based on worst-case analysis, the distance to the endpoint exceeds the distance to public receptors. In addition, the Facility is subject to OSHA PSM. Therefore, the Ponca City Facility has Program 3 processes under the Accidental Release Prevention (ARP) program. Flammable Substances There are no regulated flammable substances at the Ponca City Facility. Therefore, analyses of flammable substances are not required. Toxic Substances The endpoint for a worst-case release of a toxic substance is based on the Emergency Response Planning Guideline level 2 (ERPG-2) developed for each substance by the American Industrial Hygiene Association. The ARP Program requirement for toxics, in a worst-case scenario, assumes total quantity released in ten minutes. Passive mitigation, such as diked areas, may be taken into consideration. Additionally, administrative controls that reduce actual storage capacity can be also considered. The distance to the endpoint for the worst-case release of anhydrous ammonia using the EPA equations are presented in Table 2. Anhydrous ammonia has a worst-case toxic release of a 6.62 miles distance to the endpoint. TABLE 2 Distance to Endpoint for Toxic Worst-Case Scenario Chemical Name Ammonia (anhydrous) Operating Storage Capacity (gallons) 25,500 Weight (lbs) 131,325 Toxic Endpoint ERPG-2 (mg/L) 0.14 Distance toERPG-2 (miles) 6.62 Alternative Releases Scenarios Alternative release scenarios are those that are more likely to occur than the worst-case release scenario. Alternative release scenarios for flammable substances should have the potential to cause substantial damage, including onsite damage. Alternative release scenarios for toxic substances should be those that lead to concentrations above the endpoints beyond the facility's fenceline. The alternative release scenarios may also represent cases included in either the five-year accident history or hazard analysis of a facility. The following conditions may be considered for alternative release scenarios: 7 Release rate dependent upon scenario; 7 Use of typical meteorological conditions at the stationary source; 7 Actual release height; and 7 Consideration of active and passive mitigation systems. Flammable Substances The Ponca City Facility does not have any regulated flammable substances held on site. Therefore, analyses of flammable substances are not required. Toxic Substances One alternative release scenario for each toxic substanc e is required under the ARP program. A hypothetical, but likely to occur, release scenario has been identified for the toxic substance above threshold quantity. The three ammonia anhydrous tanks are connected to a common header pipe on the three-inch suction pump line. The total length of piping is 49 feet. A seal leak develops on the pump line that may eventually activate the excess flow valve at each tank, preventing the release of the entire contents of each tank. The leak opening is estimated to be a maximum of 1/8-inch diameter before the excess flow valve will activate. The release rate and duration were estimated. A release rate of 1.17 pounds per minute (lbs/min) was developed. The leak will continue a maximum of twelve hours before detection by employees and appropriate action is taken. To be conservative, the alternative release scenario assumes that the total mass released is based on the 1/8-inch hole and twelve-hour release duration. The total mass released, rele ase rate, and distance to the toxic endpoint for the alternative-case release is presented in Table 3. The alternative-case release resulted in a 0.02-mile distance to the 0.14 mg/L ERPG-2 endpoint for anhydrous ammonia. Table 3 Distance to Endpoint for Toxic Alternative Release Scenario Chemical Name Ammonia (anhydrous) Mass Released (lbs) 842.40 Release Rate (lbs/min.) 1.17 Toxic Endpoint ERPG-2 (mg/L) 0.14 Distance to Endpoint ERPG-2 (miles) 0.02 GENERAL ACCIDENT RELEASE PROGRAM The following is a summary of the accident prevention program in place at the Ponca City Facility. The processes at the plant are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP), regulation and are also subject to the Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) Standard. Therefore, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident p revention program. The facility is in the continuous process of Reviewing the accident prevention program and as such is in various stages of implementing changes to improve work place safety. Employee Participation Active employee participation and involvement in the development and implementation of the Facility's PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Employee involvement will help to ensure that all perspectives regarding PSM are considered, and that the best ideas are implemented. Open communications are encouraged between supervisors and employees regarding all safety and health issues. The Facility strongly promotes employee involvement in safety issues through existing programs. These programs include regularly scheduled safety meetings, tail-gate safety meetings, Hazard Communication, Safety Suggestion Forms, "near-miss" report ing, and special training programs (emergency response training, first aid, etc.). The Ponca City Facility actively seeks employee involvement in the development and the conducting of all accident prevention activities through the appropriate existing safety programs. Accident prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments, or suggestions. Process Safety Information Complete and accurate written process safety information (PSI) concerning process chemicals, process technology, and process equipment is essential to effective PSM and RMP programs and to completing and maintaining a process hazard analysis (PHA). The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans. Process safety information is to be readily available to all employees. A variety of technical documents are to be kept that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). Numerous technical documents are to be maintained that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) There is a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Facility primarily uses the hazard and operability (HAZOP) method analysis technique to perform these evaluations. However, as situations warrant, the Facility will use other inductive techniques such as what if/checklist and failure mode and effect or the deductive fault tree technique. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. PHA team members include the process/project engineer responsible for the process/project; plant manager or knowledgeable plant p erson; person knowledgeable in methods of hazard analysis; and others with particular expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk matrix assigned by the PHA team. The matrix is based on severity (criticality) and probability (frequency). This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not even tually deviate significantly from the original design safety features, the PHA team periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The recommended order of analysis will be based upon the following criteria: 1) age of process; 2) extent of process hazards; 3) number of affected employees; and 4) operating history of the process. The results and findings from these updates are documented and retained. The team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. Operating Procedures Written procedures are to be maintained that address various modes of process operations, such as: 7 initial startup; 7 normal operations; 7 temporary operations; 7 emergency shutdown; 7 emergency operations; 7 normal shutdown; 7 startup following a turnaround; and 7 start up after emergency shutdown. These procedures provide guidance for experienced operators and also provide the basis for training new operators. Operating procedures are to be periodically reviewed and annually certified as current and accurate. The review is to assure that the procedures reflect current operating practice, include changes from process technology changes, chemical changes, equipment changes, and changes to facilities. The review and certification process involves both operators and technical staff. The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities. To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees. Operating procedures are specific instructions or details on what steps are taken or followed in carrying out the stated procedures. The specific instructions include the applicable safety precautions and appropriate information on safety implications. Training In addition to training on operating procedures, there is to be a comprehensive training program for all employees involved in operating the process. New employees are to receive basic training in process operations and procedures. This refresher training is to be conducted at least every three years. In addition, all operators are periodically to receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. The appropriate frequency of training is to be based on management in consultation with the employees involved in operating the particular process. All of this training is to be documented for each operator including the means used to verify that the operator understood the training. Contractors The Ponca City Facility uses contractors during peri ods of increased maintenance or construction activities. Because some contractors work on or near process equipment, there are to be procedures in place to ensure that contractors do as follows: 7 perform their work in a safe manner; 7 have appropriate knowledge and skills; 7 are aware of the hazards of their workplace; 7 understand what they should do in the event of an emergency; 7 understand and follow site specific safety rules; and 7 inform plant personnel of any hazards that they find during their work period. This is to be accomplished by providing contractors with an orientation session that covers the following: 7 a process overview; 7 information about safety and health hazards including known or potential fire, explosion, or toxic release hazards; 7 emergency response plan requirements; and 7 control of entrance, presence, and exit of contract personnel prior to beginning their work. In addition, contractor safety programs and performance during the selection of a contr actor are to be evaluated. Contract employee injury and illness log should be maintained. Plant personnel are to periodically monitor contract performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Review (PSSR) A PSSR should be conducted on any new facility or facility modification that requires a change in process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment and highly hazardous chemicals into service. This review provides one additional check to make sure construction is in accordance with design specification and that all-supporting systems are operationally ready. The PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. The PSSR also ensures that procedure s (safety, operating, maintenance, and emergency) are in place and adequate. A PSSR verifies that a PHA has been conducted, recommendations have been resolved, and training of employees involved in the process has been completed prior to a start-up. Mechanical Integrity Well established practices and procedures for maintaining process equipment should be kept. The basic aspects of this program are to include: 7 training; 7 developing written procedures; 7 performing inspections and tests consistent with good engineering practices; 7 correcting equipment deficiencies outside acceptable PSI limits; and, 7 applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on: 7 an overview of the process; 7 safety and health hazards; 7 applicable maintenance procedures; 7 emergency response plans and; 7 applicable safe work practices. This training is to help ens ure that they can perform their jobs in a safe manner. Another integral part of mechanical integrity program is quality assurance. Quality assurance measures are to be incorporated into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices During construction of new processes all equipment to be installed is to be determined to be suitable for the process application. Checks and inspections are to be performed to assure that installation is consistent with design specifications and manufacturer's instructions suitable for the particular application. The Facility has long standing safe work practices in place to help ensure worker and process safety. Examples of these include the following: 7 control of the entry/presence/exit of support personnel, 7 a lockout/tagout procedure to ensure isolation of energy sources for equipment underg oing maintenance, 7 a procedure for safe removal of hazardous and toxic substances before process piping and equipment is opened, 7 a permit and procedure to control spark-producing activities (i.e., hot work), and 7 a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change There is a comprehensive system of written procedures to manage changes to all covered processes. This system requires that changes to items such as process chemicals, process equipment, technology (including process-operating conditions), procedures, impact to safety and health and other facility changes be properly reviewed and authorized before being implemented. Prior to changes being made, they are reviewed to ensure that adequate controls are in place to manage any new hazards and verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition operating and maintenance personnel, including contractor's employees, are provided any necessary training on the change. Incident Investigation The facility will promptly investigate (within 48 hours) all incidents that resulted in or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation will be to gather the facts, determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident. The reports will be maintained for five years. An investigation team will be established to investigate each process incident. The team will consist of members involved in the incident including at least one person knowledgeable in the process involved; a contract employee (if the incident involved the work of a contractor); and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. The investigation team will document its findings in a report. The report will include dates of incident and of investigation, description of incident, factors contributing to the incident, will develop recommendations to prevent a recurrence, and forward these results to the business management team for resolution. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Ponca City Facility periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three years. Both operations and management personnel participate as audit team members with at least one person knowledgeable in the audit techniques. The audit team develops findings in a report that is forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked and documented until they are complete. The final resolution of each finding is documented, and the appropriate enhancements to the prevention program are implemented. The two most recent compliance audit reports are retained. Chemical Specific Prevention Steps The processes at the Ponca City Facility have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program summarized previously is applied to the RMP-covered process at the Ponca City Facility. Collectively, these prevention program activities help prevent potential accident scenarios th at could be caused by equipment failures and human errors. Specialized Safety Features The Facility has safety features on many units to help 7 contain/control a release, 7 quickly detect a release, and 7 reduce the consequences of (mitigate) a release. The following types of safety features are used in the RMP covered process: Release Detection 1. Hydrogen sulfide sensors with audible alarms. 2. High pressure and low pressure sensors. Release Containment/Control 1. Pressure relief valves on railcars designed to relieve at 75 psi. 2. Vents scrubbers and flares to relieve processes. 3. Key manual valves are chained and padlocked in their critical (open/closed) position. 4. Excess flow check valves designed to plug the outlet if outflow reaches equivalent 90 lbs per minute. 5. Automatic shutoff valves. Release Mitigation 1. Standard operating procedures that control, isolate, and terminate leaks. 2. Personnel trained in emergency procedures. 3. Personal protective equipme nt (e.g., escape respirator, self-contained breathing apparatus, and supplied air breathing apparatus). 4. Ventilate contaminated areas. Five Year Accident History The Ponca City Facility has an excellent record of accident prevention over the past five years. There have been no incidents involving a release of anhydrous ammonia with off-site consequences. Emergency Procedure Information The Facility maintains a written emergency procedure, which is in place to protect worker and public safety as well as the environment. The procedures account for the possibility of a toxic substance being accidentally released, as well as for the possibility of a fire or explosion. The procedures address notification of local emergency response agencies if a release occurs, and post incident cleanup and decontamination requirements. Employees receive training in emergency procedures. The emergency procedure is updated when necessary based on modifications made to the Facility. The emergency p rocedure changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes. The overall emergency procedure program for the Facility is coordinated with the County LEPC. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Facility has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire and police department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. |