Kemin Industries, Inc. - Port of Houston Facility - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

RISK MANAGEMENT PLAN 
 
This document and accompanying supporting documentation contains information required to meet 40 CFR 68 (Risk Management Program) including an Executive Summary and list of RMP Data Elements.  We have also provided supporting documentation for our hazard assessment results and population estimations. 
 
EXECUTIVE SUMMARY 
 
1. Accidental release prevention and emergency response policies: 
 
Because our company has a strong regard for environmental protection, product stewardship and safety concerns, we conduct our activities in such a manner as to protect the physical environment, our employees, our customers, and the general public.  We comply with environmental, stewardship and safety laws and regulations; and develop and implement programs to insure compliance. We are both responsible and responsive in our efforts relating to environmental protection, product stewardship and employee safety. 
 
Where our company becomes aware of environmental and product safety risks 
not covered by existing laws or regulations, we develop our own good faith standards and practices based on comprehensive and relevant scientific data.  We cooperate with the public, government, industry and employees in identifying environmental, product stewardship and safety goals and in developing effective control programs.  Each operating unit of the company is expected to be guided by this policy in forming plans, setting objectives, and conducting their day-to-day activities. 
 
Our emergency response procedures include notification of the local fire.  In addition, access to the site is restricted to authorized facility employees, management personnel, and contractors.  The facility is fenced to help keep it secure. 
 
 
2. The stationary source and regulated substances handled: 
 
The regulated substance handled at this facility is anhydrous ammonia.   
 
The primary purpose of this facility is to produce specialty ingredients, nutritional additives, and environmental products for a 
nimal agriculture and human foods.  Anhydrous ammonia is received by truck (transports) and is stored in a single tank located in the central portion of our property.  The capacity of the storage tank is 15,000 gallons of anhydrous ammonia.  The tank is designed to store 85 percent of its capacity; therefore, the maximum amount of anhydrous ammonia that can be stored at our plant is approximately 12,750 gallons, or approximately 75,000 pounds.   
 
 
3. The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario: 
 
' Worst-Case Scenario - After careful review of potential worst-case scenarios, we feel our worst-case scenario is an outdoor release of the largest quantity in the tank (75,000 pounds), released during an unloading accident that causes rupture of the tank, with no building passive mitigation effects.   
 
' The distance to the toxic endpoint of 0.14 mg/L  
(200 ppm) for the worst-case scenario is approximately 1.78 miles. 
 
' Alternative Scenario - A pipe rupture causes a release through a small hole approximately 2-inch diameter.  The anhydrous ammonia releases immediately to vapor and is carried downwind. 
 
' The distance to the toxic endpoint of 0.14 mg/L for the alternative scenario is estimated to be 1.09 miles.  This release has the possibility of extending beyond the facility boundary. 
 
4. The general accidental release prevention program and the specific prevention steps: 
 
This facility complies with EPA's Accidental Release Prevention Rule and with applicable state codes and regulations including OSHA's Process Safety Management Standard.  This facility was designed and constructed in accordance with good engineering practices to provide a safe system for our employees as well as our neighbors and environment.  Delivery drivers have been thoroughly trained regarding anhydrous ammonia hazards and emergency response.  Our employe 
es watch the delivery of each truck bringing anhydrous ammonia to our site. We lease our anhydrous ammonia storage from anhydrous ammonia vendors and require them to periodically inspect our anhydrous ammonia system, and make any necessary adjustments to either equipment or procedures to continue to ensure safe handling and use of anhydrous ammonia. 
 
5. Five-year accident history: 
 
This facility was opened in 1996; therefore a five year history in not available.  However, since 1996 there have been no accidental releases, injuries, or environmental damage resulting from the anhydrous ammonia system. 
 
6. The emergency response program: 
 
This facility's emergency response program is based upon the management system we have in place and the appropriate discovery and notification procedures to ensure coordination with our local emergency responders.  We have discussed this program with the Des Moines Fire Department.  A mock drill with the Des Moines Fire Department was performed in 19 
98.                                                                              
 
7. Planned changes to improve safety: 
A process hazard analysis of our anhydrous ammonia system was conducted during June 1995.  From this review, the recommendations were:   
 
' Continued development and implementation of standard operating procedures (SOPs) and scheduled maintenance activities. 
 
' Continued implementation of equipment manufacturers' operation and maintenance procedures. 
 
' Continued implementation of a mechanical integrity program, including visual inspections and replacement of equipment as necessary. 
 
' Continued implementation of a training program, and expansion of the program to cover more employees to make them aware of the anhydrous ammonia system and its potential hazards. 
 
' Continued implementation of spill response measures. 
 
' Continued training of operators and other personnel as to proper procedures during power cutoff. 
 
' Continued ensurance of adequate lighting at night t 
o deter trespassers.
Click to return to beginning