Helena Chemical Company - Garden City - Executive Summary

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PROJECT NO. 52987014 
June 8, 1999 
1.    EXECUTIVE SUMMARY (40 CFR 68.155) 
The Executive Summary is a brief description of the Risk Management Plan (RMP).  Helena will submit the Executive Summary to a central point as specified by the Environmental Protection Agency (EPA) prior to June 21, 1999. 
1.1.    Accidental Release Prevention and Emergency Response Policies (40 CFR 68.155(a)) 
Helena's responsibility for providing its employees with a safe workplace, as well as operating in an environmentally responsible manner, is as important as the quality products and services offered to it's customers.  Helena's Health, Safety, and Environmental Program is committed to provide safe working conditions, and preventing accidents and damages to employees, the environment, and the general public.  Health, safety, and environmental compliance is a fundamental part of every Helena Chemical Company employee's job.  Helena's spill  
policy seeks to implement appropriate controls to prevent accidental releases of anhydrous ammonia.  If such a release does occur, Facility personnel are prepared to work with the local fire department, Local Emergency Planning Commission, and other authorities to control and mitigate the effects of the release.  Helena protects the safety of  employees, the nearby community, and the environment. 
1.2.    Stationary Source and Regulated Substance Handled (40 CFR 68.155(b)) 
The primary activity at Helena's Garden City, Kansas Facility, herein referenced as the stationary source and the Facility, is the storage, handling, and blending of fertilizers for direct retail sale to end users.  As defined in 40 CFR 68.3, a stationary source means any buildings, structures, equipment, installations, or substance-emitting stationary activities which belong to the same industrial group, which are located on one or more contiguous properties, from which an accidental release may occur.  Helena receiv 
es, stores, and distributes anhydrous ammonia for direct application and blending for mixed-grade fertilizers used for crop production nutrients.  The maximum inventory of anhydrous ammonia at the Facility is 305,127 pounds (lbs) stored in a 30,000 gallon bulk storage vessel, twenty-five 1,000-gallon nurse tanks, and a 40,000 gallon T-Reactor.  The T-Reactor mobilizes to the Facility and reacts anhydrous ammonia and phosphoric acid about every 6 - 8 months. 
1.3.    Worst Case Release Scenario and Alternative Release Scenario (40 CFR 68.155(c)) 
Methodology given in the RMP Offsite Consequence Analysis Guidance by the EPA was applied using the DEGADIS dense gas dispersion model approach to the perform worst case release scenario (WCRS) and alternative release scenario (ARS). 
The WCRS submitted for Program 2 toxic substances involves a catastrophic release of the total contents of the 30,000 gallon bulk anhydrous ammonia storage vessel at the Facility.  The WCRS is based on the release of 
145,095 lbs of anhydrous ammonia in a gaseous form over 10 minutes.  Under worst case weather conditions, namely Class F atmospheric stability and 1.5 meters per second (m/s) windspeed, the maximum distance of 5.9 miles is obtained corresponding to a toxic endpoint concentration of 0.14 milligrams per liter (mg/L) or 200 parts per million (ppm). 
The ARS for anhydrous ammonia involves a release from a ruptured 1-inch transfer hose from the 30,000 gallon bulk storage vessel to a 1,000 gallon nurse tank.  The ARS is based on the release of 264.6 pounds per minute (lbs/minute) of anhydrous ammonia in a gaseous form over 2 minutes.  Under neutral weather conditions, namely Class D atmospheric stability, the maximum distance to the toxic endpoint concentration of 0.14 mg/L is 0.54 miles. 
1.4.    The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps (40 CFR 68.155(d)) 
Helena's Garden City, Kansas Facility has taken the necessary steps to comply with the 
accidental release prevention requirements of 40 CFR 68.  This Facility was designed and constructed in accordance with applicable state and federal regulations as listed in the RMP.  The following sections briefly describe the elements of the release prevention program that are in place at the stationary source. 
1.4.1.    Process Safety Information and Process Hazard Analysis 
Helena maintains a separate written Emergency Action Plan regarding safety information that describes the chemical hazards associated with anhydrous ammonia.  Further safety information is also detailed in the RMP.  In addition, operating procedures and equipment design codes and standards associated with the anhydrous ammonia process are  maintained in the RMP at the Facility. 
The Facility conducts safety inspections to identify and control the hazards associated with the anhydrous ammonia process.  Helena inspects the 30,000 gallon anhydrous ammonia bulk storage vessel, the twenty-five 1,000 gallon nurse tanks 
, hoses, valves, gauges, and pumps  on a monthly basis, and documents the inspection results.  Any findings related to the hazard analysis are addressed in a timely manner. 
1.4.2.    Operating Procedures 
For the purposes of safely conducting activities at the Facility associated with anhydrous ammonia, Helena maintains written operating procedures included in the RMP.  These procedures address various modes of operation such as initial startup, normal operations, emergency shutdown, emergency operations, normal shutdown and startup after an emergency shutdown.  The information is reviewed as needed and is readily accessible to operators involved with the processes. 
Helena has an anhydrous ammonia operator safety training program in place to train employees involved in the anhydrous ammonia process.  New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently.  Refresher training i 
s provided annually and more frequently as needed.  In addition, employees not operating the anhydrous ammonia process are involved in safety training on the hazards associated with anhydrous ammonia. 
1.4.4.    Mechanical Integrity 
Helena performs documented maintenance checks on anhydrous ammonia storage and transfer equipment to ensure proper functions.  Maintenance operations are carried out by qualified personnel.  Equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
When outside contractors are required for maintenance and construction activities, those personnel are accompanied by Helena employees or are briefed by the area supervisor on the rules, regulations, and emergency procedures outlined in the Emergency Action Plan before initiating work.  Contractors use hot work permits, confined space permits, comply with lockout procedures, and use appropriate personal protective equipment when needed.  Contractors are briefed on the e 
mergency alarm procedures and emergency rendezvous point.  Contractors must sign the visitor log.  The supervisor debriefs the contractor after each day. 
1.4.5.    Compliance Audits 
Helena conducts audits on a regular basis to determine whether the provisions of the RMP rule are being implemented.  These audits are performed at least every 3 years as required by 40 CFR 68.  Corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
1.4.6.    Incident Investigation 
Helena promptly investigates any incident that has resulted in, or could have reasonably resulted in a catastrophic release of a regulated substance.  These investigations are performed to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  Reports are retained for a minimum of 5 years.  The anhydrous ammonia spill release reporting procedures are found in the Emergency Action Plan spill procedures.  Report forms that w 
ill be completed in the event of an incident or possible incident are found in the Emergency Action Plan and the RMP. 
1.4.7.    Employee Participation 
Helena believes accident prevention is a team effort.  Helena employees are encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, Helena employees have access to information created as part of the Facility's implementation of the RMP. 
1.5.    Five-year Accident History (40 CFR 68.155(e)) 
Helena Chemical Company's Garden City, Kansas Facility has an excellent chemical release prevention record.  Due to release prevention policies, the Facility has not had a reportable accidental release of anhydrous ammonia in the five years previous to June 21, 1999, the effective date of the RMP regulation. 
1.6.    Emergency Response Plan (40 CFR 68.155(f)) 
Helena's Garden City Facility has an Emergency Response Plan which is called their Emergency Action Plan.  The Emergency Action Plan descri 
bes response procedures to minimize hazards to human health and the environment in the event of an anhydrous ammonia accidental release.  Aspects of emergency response include adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.  In the event of an anhydrous ammonia accident, first aid procedures for anhydrous ammonia exposure, and procedures to inform authorities and the public are described in the Emergency Action Plan.  A general emergency practice drill is performed at least annually and includes an invitation to the local fire department, Finney County Emergency Coordinator and sheriff.  A site map, MSDSs, and a list of chemicals kept on the site are included in the Emergency Action Plan. 
1.7.    Planned Changes to Improve Safety (40 CFR 68.155(g) 
Mechanical integrity checks, maintenance checks, compliance audits, and incident investigations will identify  
changes to improve safety.  Helena has a continued commitment to update equipment and improve safety regarding the anhydrous ammonia process when necessary. 
1.0     EXECUTIVE SUMMARY (40 CFR 68.155)    1 
1.1 Accidental Release Prevention and Emergency Response Policies (40 CFR 68.155(a))    1 
1.2 Stationary Source and Regulated Substance Handled (40 CFR 68.155(b))    2 
1.3 Worst Case Release Scenario and Alternative Release Scenario (40 CFR 68.155(c))    2 
1.4 The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps (40 CFR 68.155(d))    3 
1.4.1 Process Safety Information and Process Hazard Analysis    3 
1.4.2 Operating Procedures    3 
1.4.3 Training    4 
1.4.4 Mechanical Integrity    4 
1.4.5 Compliance Audits    4 
1.4.6 Incident Investigation    5 
1.4.7 Employee Participation    5 
1.5 Five-year Accident History (40 CFR 68.155(e))    5 
1.6 Emergency Response Plan (40 CFR 68.155(f))    5 
1.7 Planned Changes to Improve Safety (40 CFR 68.155(g)    6
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