PCS Nitrogen Ohio L. P. - Executive Summary

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PCS Nitrogen, Ohio, L.P., Lima, Ohio 
EPA Risk Management Plan - Executive Summary 
 
 
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES 
 
As employees of PCS Nitrogen, we have the responsibility to manage our operations, to protect human health and the environment.  Sound health, safety, and environmental practices are an integral part of our everyday job. 
 
In recognition of this responsibility, we will correct any unsound health, safety, and environmental practices or conditions, call them to the attention of those who will do so, as soon as they are identified.  Specifically we will: Conduct our operations in compliance with all applicable health, safety, and environmental laws and regulations.  Continue to improve our health, safety, and environmentsl performance through the quality improvement process.   Conduct periodic assessments of our operations to ensure compliance and identify risks.  Implement progressive health, safety, and environmental practicies that apply risk managemen 
t and loss control principles to our operations.  Establish health, safety, and environmental performance goals and assign responsibilites for developing and implementing related measurement.  Provide education and training regarding applicable laws, regulations, policies, and procedures to protect human health and the environment.  Cooperate with our neighbors, industry trade groups, governmental agencies, and others to develop effective, reasonable rules and regulations to protect human health and environment.  PCS Nitrogen's success depends upon our positive health, safety and environmental attitude and actions to achieve continuous improvement. 
 
We at PCS Nitrogen 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.  Our plant 
adheres to process safety policies, guidelines, and best practices that have been developed based on company and industry experience over the years.  Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances.  However, if a release does occur, our trained personnel will respond to control and contain the incident. 
 
DESCRIPTION AND REGULATED SUBSTANCES 
 
The PCS Nitrogen, Ohio, L.P., plant is located at 1900 Ft. Amanda Road, Lima OH 45804.  Adjacent to this facility is BP Chemicals, Inc. which operates and provides personnel for this facility under an agreement with the parent company PCS Nitrogen.   
 
The primary activities at the PCS Nitrogen facility include production of anhydrous ammonia, urea, and nitric acid for agricultural and industrial applications.  The plant's primary product, ammonia, is manufactured by combining natural gas and air. Ammonia is a key ingredient in the production of urea, nitric acid and for the production of acry 
lonitrile at the adjacent BP Chemical facility.  We have 5 regulated substances present at our facility.  These substances include  Ammonia (anhydrous), Aqueous Ammonia (solution), Chlorine, Methane and Hydrogen.  The inventory levels of methane and hydrogen are below the reporting requirements provided by the EPA  (10,000 pounds). 
 
HAZARD ASSESSMENTS 
 
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 have been performed for all listed flammable and toxic chemicals at the facility.  To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations.  A technical team consisting of seven local area chemical manufacturers and the City of Lima selected the basis for the scenarios.  The team findings were communicated in public meetings in May of 99.  The following paragraphs provide deta 
ils of the chosen scenarios. 
 
Worst Case Scenario                     
 
The worst case release scenario (WCS) submitted for Program 3 toxic substances as a class involves a catastrophic release from PCS Nitrogen Manufacturing.  In this scenario ammonia (anhydrous) is released from a ruptured tank.  The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to evaporate over 10 minutes.  The effects of administrative controls, mitigation systems, and safety systems are not included in determining the distance to the endpoint. At Class F atmospheric stability and 1.5 m/s windspeed.  Public receptors would be affected by this type of release. This release is unlikely due to the high-integrity design of the tank and associated equipment.   Specific information on this release is presented in more detail in the plan. 
 
Alternative Release Scenarios 
 
The alternative release scenario submitted for Program 3 toxic substances in 
volves Ammonia (anhydrous) and a release from PCS Nitrogen.  The scenario involves the release of  13,500 lb. of liquid from a rupture of a safety valve.  Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to have evaporated after 20 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.4 miles. Specific information on this release is presented in more detail in the plan. 
 
The alternative release scenario for Aqueous Ammonia (solution) involves a release from PCS Nitrogen.  The scenario involves the release of 35,300 lb. of  liquid Ammonia Solution from leaking loading hose.  Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to have evaporated after 10 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.3  
miles. Specific information on this release is presented in more detail in the plan. 
 
The alternative release scenario for Chlorine involves a release from PCS Nitrogen.  The scenario involves the release of 678 lb. of Chlorine from a leaking feed line.  Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to have evaporated after 60 minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.1 miles. Specific information on this release is presented in more detail in the plan. 
 
PREVENTION PROGRAM 
 
The following is a summary of the accident prevention program in place at the PCS Nitrogen, Lima plant. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.    The following sections briefly describe the elements of the release prevention program that is in place 
at our stationary source.  Because processes at the plant that are regulated by the  EPA RMP regulation are also subject to the OSHA PSM standard this summary also addresses the OSHA PSM elements and describes the management system in place to implement the prevention program. 
 
Employee Participation 
 
The PCS Nitrogen Lima plant encourages employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation range from updating and compiling technical information to participating as a member of a process hazard analysis (PHA) team.  Employees have access to all information created as part of the plant prevention program.  Specific ways that employees can be involved in the prevention program are documented in the employee participation plan that addresses each prevention program element.  In addition the plant has a number of initiatives under way that address process safety and personal safety issues.  These initiatives inclu 
de forming teams to promote both process and personal safety.  The teams typically have members from various areas of the plant, including operation, maintenance, engineering, and plant management.  
 
Process Safety Information 
 
The PCS Nitrogen plant keeps a variety of technical documents that are used to help maintain safe operation of the processes.  These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.  Each process has documentation available showing the location of this information to help employees and visitors locate any necessary process safety information.  
 
Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs).  This information is supplemented by documents that specifically address known exposure concerns and any known hazards as 
sociated with the inadvertent mixing of chemicals.  For process areas. the plant has documented safety-related limits for specific process parameters (i.e. temperature, level, composition).  The plant assures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (i.e. automated shutdown systems).  In addition, information is available summarizing the consequences of deviation from these limits and the corrective actions to take. 
 
The plant also maintains technical documents that provide information about the design and construction of process equipment.  This information includes materials of construction, design pressure and temperature ratings, electrical ratings of equipment, piping and instrument drawings, etc.  This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as fo 
r evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. 
 
Process Hazard Analysis 
 
The PCS Nitrogen plant has 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. 
 
This plant primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations.  HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques.  The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise.  This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team belie 
ves such measures are necessary. Any findings related to the hazard analysis are addressed in a timely manner.   
 
To help ensure that the process controls and or process hazards do not eventually deviate significantly from the original design safety features, this plant periodically updates and revalidates the hazard analysis results.  These periodic reviews are conducted at least every five years as long as the process exists.  The recommendations from these updates are also forwarded to management.  Final resolution of the recommendations is tracked, documented, and retained.   
 
Operating Procedures 
 
The PCS Nitrogen plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process.  These procedures are developed/revised by experienced operators as needed and provide a basis for consistent training of new  
operators.  The procedures are periodically reviewed and annually certified as current and accurate.  The procedures are revised as necessary to reflect changes made through the management of change process. 
 
Also safe operating limits are maintained to provide guidance on how to respond to upper or lower exceedences for specific process or equipment parameters.  This information, along with the written operating procedures, is readily available to the process operators and other personnel to use as necessary to safely perform their job tasks. 
 
The PCS Nitrogen plant has long-standing safe work practices in place to help ensure worker and process safety.  Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, and (4) a permit and procedure to ensure that a 
dequate 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 
 
Training 
 
To complement the written procedures for process operations, the PCS Nitrogen plant has implemented a comprehensive training program for all employees involved in operating a process.  New employees receive basic training in chemical plant operations.  After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks.  After the new operator demonstrates (i.e. through tests, skills demonstration, etc.) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently.  In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an 
acceptable level.  This refresher training is conducted at least every three years.  All of this training is documented, including the means used to verify that the operator understood the training. 
 
Contractors 
 
The PCS Nitrogen plant uses contractors to supplement its work force during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work.  This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior 
to work starting.  In addition, the PCS Nitrogen plant evaluates contractor safety programs and performance during the selection of a contractor.  Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 
 
Pre-Startup Safety Reviews (PSSRs) 
 
The PCS Nitrogen plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information.  The purpose of the PSSR is to ensure that safety features, equipment, procedures, and personnel are appropriately prepared for startup prior to placing the equipment into service.  This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready.  The PSSR review team uses checklists to verify all aspects of readiness.  A PSSR involves field verification of the construction and serves a quality assurance function by requiring verifi 
cation that accident prevention program requirements are properly implemented. 
 
Mechanical Integrity 
 
The PCS Nitrogen plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition.  The basic aspects of this program include: (1) conducting training, (2) developing written procedures and plans, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures.  In combination these activities form a system that maintains the mechanical integrity of the process equipment. 
 
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner.  Written procedures help ensure th 
at work is performed in a consistent manner and provide a basis for training.  Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (i.e. adequate wall thickness for pressure vessels).  If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. 
Another integral part of the mechanical integrity program is quality assurance.  The BP Chemical, Inc. plant incorporates quality assurance measures 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.  
 
Hot Work Permit 
 
The PCS Nitrogen plant has a hot work permit program which details those areas which require a permit an 
d those areas for which a permit is not required.  A permit is required in process areas for all cutting, welding, spark producing equipment, etc. except in designated  areas.  The procedure includes accountability and responsibility for authorizing and issuing the hot work permit, display of the permit at the site of the hot work until the work is completed, site inspection, designation of appropriate precautions to be taken with the hot work, and assignment of a fire watch where appropriate. 
 
Management of Change 
 
The PCS Nitrogen plant has a comprehensive system to manage changes to processes.  This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented.  Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromise 
d 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 are provided any necessary training on the change.  The system ensures that all documentation is updated and training completed prior to the commissioning of the change. 
 
Incident Investigation 
 
The PCS Nitrogen plant promptly investigates 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 is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident.  The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to management for resolution.  Corrective actions taken in response to the investigation  
team's findings and recommendations are tracked until they are complete.  The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings.  Incident investigation reports are retained for at least 5 years, so that the reports can be reviewed during future PHAs and PHA revalidations.  
 
Compliance Audits 
 
To help ensure that the accident prevention program is functioning properly, the PCS Nitrogen plant 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 3 years with internal audits conducted on an annual bases.  Both hourly and management personnel participate as audit team members.  The audit team develops findings that are forwarded to plant management for resolution.  Corrective actions taken in response to the aud 
it team's findings are tracked until they are complete.  
 
Five-year Accident History 
 
PCS Nitrogen has had a very good record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, there have been only two accidental releases during this period that has affected the community.   The first occurred in 12/21/94  during  the loading of Ammonia rail  where a load line was inadvertently blocked causing over pressurization and a safety valve to lift releasing 283 lb. of ammonia.  While attempting to shut down  loading pumps  an employee was exposed to ammonia vapors.  Employee was transfered to hospital  where he was treated and released.  The second accident occurred on 5/7/97 where 13,500 lb. of ammonia was released over 20 minutes.  This was caused by the explosive failure of a process safety valve which damaged the process unit.  During this event a police officer was exposed to ammonia vapors while directing traffic and was taken to t 
he local hospital where he was treated then released.  
 
Over the past five years there have been other incidents where chemical reportable quantity releases have occurred but did not affect the local community.  These are documented in our incident reporting system along with notification given to the proper governmental agencies.  Information on these incidents are available at the facility from the RMP Coordinator (419-226-1200). 
 
CHEMICAL SPECIFIC PREVENTION STEPS 
 
The processes at the PCS Nitrogen plant have hazards that must be managed to ensure continued safe operation.  The accident prevention program summarized previously is applied to all Program 3 EPA RMP covered processes at this facility.  Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. 
 
In addition to the accident prevention program activities, the PCS Nitrogen plant has safety features on many units to help (1) contai 
n/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release.  The following types of safety features are used in various processes:  
 
Release Containment/Control 
 
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases. 
2. Scrubber to neutralize chemical releases. 
3. Valves to permit isolation of the process (manual or automated). 
4. Curbing or diking to contain liquid releases 
5. Redundant equipment and instrumentation (i.e. uninterruptible power supply for process control system, backup firewater pump) 
6. Atmospheric relief devices 
 
Release Mitigation 
 
1. Fire suppression and extinguishing systems  
2. Deluge systems for specific equipment 
3. Trained emergency response personnel 
4. Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus) 
5. Mobile fire fighting equipment 
 
 
EMERGENCY RESPONSE PROGRAM INFORMATION 
 
The PCS Nitrogen plant maintains a written emergency 
response program, which is in place to protect worker and public safety as well as the environment.  The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released.  The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements.  In addition, the PCS Nitrogen plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment.  Employees receive training in these procedures as necessary to perform their specific emergency response duties.  The emergency response program is updated whe 
n necessary based on modifications made to plant processes or other plant facilities.  The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes. 
 
The overall emergency response program for the PCS Nitrogen plant is coordinated with the Allen County Local Emergency Planning Committee (LEPC).  This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives.  The PCS Nitrogen plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., Shawnee Fire Department).  This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.  In addition to periodic LEPC meetings, the PCS Nitrogen plant conducts periodic emergency drills that involve the LEPC and emergen 
cy response organizations.  The plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant.  
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
The PCS Nitrogen Lima plant resolves all findings from PHAs, some of which result in modifications to the process.  In addition to meeting Process Safety Management requirements this plant location is committed to meeting OHSAs Voluntary Protection Program (VPP) and CMAs Responsible Care.  Under Responsible Care, CMA members are pledged to continually improve their over-all health, safety and environmental performance which includes reducing vulnerability and risk potential. Further information on these programs are available at the facility from the Quality/Safety Systems Manager or the RMP Coordinator (419-226-1200).
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