Rivergate Terminal - Executive Summary |
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1. Accidental Release Prevention and Emergency Response Policies The Unocal Rivergate Terminal handles anhydrous ammonia which is considered a hazardous material and is a regulated substance under the Federal Accidental Release Program (ARP) and is considered in this Risk Management Plan (RMP). The properties of this chemical make it necessary to observe safety preccautions in handling the chemical 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 Oregon rules and regulations. The prevention of accidental releases depends on adherence to the procedures used to handle anhydrous ammonia; the safety devices and systems designed and constructed into the facility; and the training of pertinent personnel. The various programs and documentation can be found in the facility's comprehensive loss control program. 2. Description of the Stationary Sou rce and Regulated Substances Handled Unocal's Rivergate Terminal along with the Kennewick Plant, which is comprised of the three neighboring areas, Kennewick, Hedges, and Finley Areas, the West Sacramento Plant, and the Fresno Terminal comprise the integrated operation known as Unocal Agricultural Products Group's West Coast Facilities. Unocal distributes anhydrous ammonia and solid prilled/granular urea through the Rivergate Terminal. Anhydrous ammonia is brought into Rivergate by marine vessel. Occasionally anhydrous ammonia is brought into the facility by rail. The river barges, Hedges and Columbia, transport anhydrous ammonia from Rivergate up the Columbia river to the Kennewick Plant. Anhydrous ammonia is also shipped by truck and rail car. The Rivergate Terminal ships anhydrous ammonia for use in water treatment for industrial facilities, the production of ink, the production of resins and for use as nitrogen-based fertilizers throughout the western United States. 3a. Wor st 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 temperatures 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. A loaded railroad car with anhydrous ammonia yields the greatest distance to the end-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. 3b. Alternative Release Scenario The Alternative Release scenario for anhydrous ammonia, as submitted, is the most credible release scenario with the greatest distance to toxic endpoint. This is the continuous release of gaseous anhydrous ammonia from a Pressure Relief device on Tank F-150 or Tank F-400 due to overpressurization. This results in the release of gaseous ammonia at the rate of 1,708 lb/min for 10 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. 3c. Administrative Controls Administrative controls are in place to prevent accidental releases. Additional administrative controls exist for each reported scenario that minimize the amount of anhydrous ammonia released, 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, as well as the tra ining 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, systems and related equipment and components that use anhydrous 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 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 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 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 public notification and alert systems and procedures for alerting personnel at the facility to shelter-in-place or to evacuate, if required. Both the shelter-in- place and evacuation procedures have designated assembly areas and personnel accounting methods included. The facility has a qualified emergency response team trained in accordance with HAZWOPER, 29 CFR 120. The facility conducts emergency internal drills and joint drills with the Fire Department. 7. Planned Changes To Improve Safety A comprehensive Ammonia Process PHA Revalidation was conducted in October 1998. The action plans for those recommendations which identified unacceptable risk rankings have been completed. Current applicable codes and regulations are reivewed as part of the ongoing PSM Program to determine if other additional changes need to be made to achieve increased operational safety for the regulated anhydrous ammonia processes and systems. Investigations are also completed for accidental releases of ammonia and recommendations implemented where appropriate. |