Apache Nitrogen Products, Inc. - Executive Summary |
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1 .0 INTRODUCTION Apache Nitrogen Products, Inc. (ANPI) manufactures nitrogen-based chemical products for the mining and agricultural industries. ANPI (formerly the Apache Powder Company) has been manufacturing at its Cochise County facility since 1922. ANPI established a mission to be "best in its class" and recognizes that attaining that commitment means operating and maintaining its manufacturing process in a safe and responsible manner. To prevent accidental releases of hazardous substances, ANPI has developed and is implementing a comprehensive Risk Management Program (RMP) in accordance with Title 40 of the Code of Federal Regulations (CFR) Part 68. ANPI understands the risks associated with releases of hazardous substances and ensures that those risks are being well managed at its facility. To help ensure the safety of its employees and the public as well as to protect the environment, ANPI's RMP is a combination of accidental release prevention programs and emergency pl anning programs. ANPI has already begun implementation of this program. This document provides a brief overview of the comprehensive risk management activities ANPI has developed and is implementing. 2 .0 SOURCE AND PROCESS DESCRIPTION ANPI manufactures nitrogen-based chemical products for the mining and agricultural industries. In simplest terms, ANPI converts anhydrous ammonia into various ammonium nitrate products. There is one manufacturing process at the ANPI facility consisting of six interconnected production units: 1) Ammonia Unloading and Storage Area, 2) Nitric Acid Plant AOP3, 3) Nitric Acid Plant AOP4, 4) Liquid Ammonium Nitrate (LAN) Plant, 5) Prilled Ammonium Nitrate Plant, and 6) Liquid Fertilizer Plant (Figure 1). ANPI has two support (i.e., non-production) units that are located apart from the manufacturing process: 7) Brine Concentrator and 8) Powerhouse (Figure 1). Different safeguards apply to different production and support units in ANPI's manufacturing p rocess. Anhydrous ammonia is the only regulated substance present at the ANPI facility in an amount equal to or greater than the "threshold quantity", as defined by 40 CFR Part 68. Anhydrous ammonia is imported to the ANPI facility by railcar. The railcars are unloaded into the Ammonia Unloading and Storage Area (Figure 1). Ammonia then enters into ANPI's Nitric Acid Plants (AOP3 and AOP4). The resulting acid feeds into the LAN Plant where it is reacted with more ammonia to produce LAN. The majority of the LAN is then pumped to the Prilled Ammonium Nitrate Plant were it is concentrated and converted from liquid to solid form. The remaining LAN is either sold directly to customers or converted into fertilizer solutions at the Liquid Fertilizer Plant. At the Liquid Fertilizer Plant, LAN is used to produce several liquid fertilizers to serve the seasonal needs of the agricultural industry. 3 .0 SUMMARY OF MAJOR HAZARDS The potential hazards associated with ANPI's manufacturin g process are related to chemical releases, equipment failures, and process upsets. The nature of the hazard is related to the type of event or accident that could occur. Relevant onsite or facility hazards associated with the production and support units are reported in this document on a unit-by-unit basis. Major onsite hazards include toxic release; fire; explosion; over pressurization; corrosion; overfilling; contamination; equipment failure; and/or loss of cooling, heating, electricity, or instrument air. The relevant offsite hazard that could impact the local population and environment is also reported in this document. The major offsite hazard would arise from an accidental release of anhydrous ammonia gas resulting in a toxic vapor cloud. Whether a release of anhydrous ammonia poses a threat to health depends on the concentration of ammonia in the air and the duration of exposure. If individuals remain exposed to high concentrations of ammonia in air for long periods of time, any or all of the following health effects could occur: 1) eye contact: severe irritation, swelling, partial or full blindness; 2) skin contact: severe irritation, blisters; and 3) inhalation: difficulty breathing, lung damage, and death by suffocation. 4 .0 EXPLANATION OF HOW RELEASES ARE PREVENTED ANPI's RMP is designed to reduce the number and severity of potential hazardous substance releases. ANPI's RMP focuses its primary prevention measures on anhydrous ammonia, the chemical that poses the greatest risk to offsite receptors near the ANPI facility. At the ANPI facility, the frequency and severity of a hazardous substance release is reduced through the implementation of effective prevention, management, mitigation, and emergency response (ER) measures. 4.1 Prevention Program Management System ANPI's RMP reduces the likelihood of a hazardous substance release by implementing a prevention program. An organizational chart illustrating ANPI's prevention program m anagement system is provided (Figure 2). ANPI's prevention program elements are the same as the requirements for the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119). ANPI has qualified employees trained in PSM and has established an organization to assure proper implementation of PSM within the RMP (Figure 2). ANPI implements a set of twelve management areas designed to protect worker health and safety in the event of accidental releases. To address the hazards of a potential hazardous substance release, the following PSM steps are taken at the ANPI facility: 1. Employee Participation - ANPI consults with its employees on the development of process hazard analysis (PHA) and the development of the other elements of PSM. In addition, ANPI employees are provided access to all PSM information. ANPI has also prepared a written plan of action that describes how employee participation is implemented (ANPI Document No. PSM-0001). 2. Process Safety Information (PSI) - ANPI has established and implements a written program that addresses and controls written PSI on each production and support unit in the manufacturing process (ANPI Document No. PSM-0002). PSI was compiled with respect to the hazard of the chemicals used in the process, the technology of the process, and the equipment in the process. ANPI implements good engineering practices for the design, maintenance, inspection, testing, and operation of process equipment. 3. Process Hazard Analysis (PHA) - ANPI has established and implements a written program to identify, evaluate, and control the hazards for each production and support unit in the manufacturing process (ANPI Document No. PSM-0003). ANPI has performed eight PHAs. ANPI established the priority order and schedule for conducting the PHA, addressed the items to evaluate in the analyses, decided the make-up of the PHA team, and determined a system to resolve PHA findings and rec ommendations. ANPI retains the PHA record for the life of the manufacturing process. 4. Operating Procedures (OPs) - ANPI has developed and implements a written program that addresses and controls written OPs process (ANPI Document No. PSM-0004). OPs are consistent with the PSI for each production and support unit in the manufacturing process. OPs address the steps for each operating phase of the manufacturing process, the operating limits, certain safety and health considerations related to the process, and safety systems and their functions. OPs are readily accessible to ANPI employees, reviewed periodically for accuracy, and reviewed on an annual basis. ANPI has developed and implements safe work practices such as lockout/tagout, confined space entry, opening process equipment or piping, and control over entrance into the manufacturing area. 5. Training - ANPI has well trained employees. ANPI trains each employee involved in an operating process and trains each emplo yee before operating a new process or transferring into a new unit (ANPI Document No. PSM-0005). PSM refresher training is provided at least every three years. Additional hazardous substance training is provided to ANPI employees under the HAZWOPER and Hazard Communication standards. Training is documented to record that each ANPI employee received and understood the training. ANPI employees are held accountable for safe operations. 6. Contractors - As part of its selection process, ANPI evaluates the safety performance and programs of ANPI contract employees in accordance with ANPI Document No. PSM-0006. ANPI informs contractors of process hazards and applicable parts of ANPI's Emergency Response Program (ERP). ANPI has developed and implements safe work practices to control contractor access to the manufacturing process areas. ANPI conducts periodic walk-through inspections to evaluate the safety performance of contractors. ANPI's policy is to hire qualified contractors who are trained to safely perform their jobs and who are knowledgeable in the hazards related to their jobs. The contractor's training is verified by ANPI. Safety rules are strictly enforced at the ANPI facility to ensure that contract employees follow safety rules. ANPI requires contractors to inform ANPI of any unique hazards presented by the contractor's work. 7. Pre-Startup Safety Review (PSSR) - When a modification requires a change in the PSI, ANPI performs a PSSR for new sources of hazardous substances (ANPI Document No. PSM-0007). The PSSR confirms that specific listed items are addressed before a hazardous substance is introduced into ANPI's manufacturing process. 8. Mechanical Integrity - One of the most important prevention program elements is to ensure mechanical integrity. Maintaining mechanical integrity is vital to preventing releases of anhydrous ammonia from the ANPI facility. ANPI has well maintained equipment. ANPI has developed a policy and implements proce dures for maintaining mechanical integrity (ANPI Document No. PSM-0008). Mechanical integrity training is provided to ANPI maintenance employees. The schedule of inspection and testing is consistent with manufacturers' recommendations and good engineering practices. Daily walk-through inspections are performed for each production and support unit at the ANPI facility. Inspections are conducted to find any unusual or increasing vibration, leaks, stress corrosion cracking, or other indications of potential failures. Scheduled replacement and preventive inspection and maintenance for pressure relief valves are performed. Scheduled inspection and calibration of liquid level, temperature, and pressure instruments, switches, and shutdown devices that have safety implications are performed. Scheduled inspections of major powered equipment such as compressors, pumps, large fans, bearings, couplings, shaft seals, and mountings are performed. Also, process equipment is inspected and tested according to generally accepted good engineering practices and each inspection and test is documented. Any deficiencies in equipment that are outside acceptable limits are corrected in a timely manner. In addition, construction of new equipment is evaluated to ensure proper assembly and installation. Finally, maintenance materials and spare parts must be suitable for ANPI's manufacturing process. 9. Hot Work Permits - ANPI has established and implements a process that issues a hot work permit (i.e., safety checklist) for all hot work operations performed on or near a manufacturing process (ANPI Document No. PSM-0009). Hot work operations include welding, cutting, brazing, burning, grinding; using non-intrinsically safe electrical tools and instruments; working on electrical circuits; or using flame or spark producing devices. This permit (i.e., safety checklist) documents and ensures the implementation of fire prevention measures before beginning hot work. 10. Manag ement of Change (MOC) - ANPI has established and implements written procedures to manage changes to process chemicals, technology, equipment and procedures, as well as changes to hazardous substances that affect ANPI's manufacturing process (ANPI Document No. PSM-0010). MOC procedures ensure that specific listed items are addressed prior to any change. Also, ANPI employees and/or contract employees affected by the change are informed of, and trained in, the change before start-up. If a change results in a change to the PSI or the OPs, these PSM elements are updated accordingly. 11. Incident Investigation - ANPI investigates each incident that resulted in, or could reasonably have resulted in, an accidental release of a hazardous substance (ANPI Document No. PSM-0011). An ANPI investigation team immediately initiates an incident investigation. The ANPI investigation team prepares an incident report and develops a system to address and resolve report findings and recommendations. In addition, the incident investigation report is reviewed with all affected ANPI personnel and the report is retained for five years. 12. Compliance Audit - At least every three years, ANPI evaluates compliance with the provisions of the PSM (ANPI Document No. PSM-0013). ANPI specifies the requirements for the audit team and the report. Response or corrective actions to compliance audit findings are implemented and documented. 4.2 Response Actions in the Event of a Release In the event of accidental release of a hazardous substance that could have offsite consequences, ANPI response actions would include any or all of the following: employing mitigation measures, implementing the ER Plan, notifying the community, performing shelter-in-place, or evacuating the affected area(s). 4.2.1 Mitigation Mitigation prevents or minimizes an accidental hazardous substance release. ANPI process controls and mitigation systems are reported in this document on a unit-by-unit bas is. Process controls in use at the ANPI facility include: vents, relief valves, check valves, scrubbers, manual shutoffs, automatic shutoffs, interlocks, alarms and procedures, keyed bypass, emergency air supply, backup pumps, grounding equipment, rupture disk, excess flow device, quench system, and purge system. Mitigation systems in use at the ANPI facility include: dikes, blast walls, deluge system, enclosure, neutralization, and containment pad. 4.2.2 Emergency Response Program (ERP) In the event of a release, ANPI has a comprehensive ERP that is coordinated with the Cochise County Sheriff's Department (the local emergency planning committee [LEPC]). The purpose of the ANPI ERP is to prevent or minimize the impact to on-plant personnel, offsite populations, and the environment. It is ANPI's policy to maintain a current and accurate written ER Plan for facility operations (ANPI ER Plan, February 1999; and ANPI Document No. PSM-0012). ANPI's ER Plan is updated on an a nnual basis as a minimum and is updated more often to reflect changes at the ANPI facility. ANPI employees are promptly informed of ER Plan changes. ANPI's ER Plan is all-inclusive and addresses a number of ER elements. The ANPI facility is also included in the LEPC's written Community ER Plan. ANPI has developed a close working relationship with the LEPC to ensure that local authorities fully understand the ANPI facility risk and management systems. To better assist with ER, ANPI conveys accurate and up-to-date information about the facility to the LEPC. ANPI employees are also active members of the LEPC. 4.2.3 Emergency Response Training Training is provided to ANPI employees for relevant ER procedures. In accordance with OSHA standard 29 CFR 1910.120, initial 40-hour and 8-hour annual refresher training for hazardous substance/waste operations and emergency response is provided. ANPI maintains a fifty-plus member ER team. ANPI's ER team is well trained and equipped to respond to onsite accidental hazardous substance release. ANPI has developed and manages an onsite Incident Command System (ICS) to be utilized during emergencies. The ICS includes the designation of responsibilities for ANPI personnel responding to onsite emergencies. The ANPI ER team and the Cochise County LEPC periodically participate in tabletop ER sessions and drills. As a minimum, ANPI's ER Plan is tested and exercised on an annual basis. 4.2.4 Community Notification System ANPI has established an emergency notification system that utilizes a community-warning siren, Community Alert Network (CAN) telephone notification system, and, if needed, public radio announcements. In the event of a release, ANPI utilizes the CAN system to notify residences within a 1-mile radius of the ANPI anhydrous Ammonia Unloading and Storage Area. 4.2.5 Community Outreach Program ANPI has worked with the LEPC to put in place a community outreach program. ANPI's community outreach progr am alerts and protects nearby residents in the event of an off-plant ammonia release. ANPI's community outreach program: 7 Presents the basic health hazards associated with ammonia 7 Explains how you will be notified in the event of an off-plant ammonia release 7 Details the shelter-in-place protection procedures 7 Provides general information on evacuation, fundamental first aid, decontamination measures, and special assistance needs. 5 .0 CONSEQUENCES OF FAILURE TO CONTROL THE HAZARDS Consequences of failure to control hazards were determined through offsite consequence analysis (OCA) in accordance with the U.S. Environmental Protection Agency (EPA) OCA guidance. The worst-case release scenario was determined using both EPA OCA guidance tables and a release and dispersion model (i.e., PHAST Professional v. 5.20, a professional, commercial program often used for RMPs). The alternative release scenario was determined using the release and dispersion model, PHAST Professional v . 5.20. The ANPI facility is located in a rural setting with nearby residential areas. There are a number of onsite structures and considerable topographic variations (e.g., hills). Therefore, an urban (i.e., congested) setting was used in the OCA for both worst-case release scenario and alternative release scenario. 5.1 Worst-Case Release Scenario The worst-case scenario considers a release due to a catastrophic event and does not consider mitigation or prevention measures that reduce the seriousness or impact of a release. For the worst-case release scenario, ANPI considered the release of the entire contents of the largest anhydrous ammonia storage vessel. The worst-case release scenario assumes that the anhydrous ammonia is released directly into the air as a gas. The ammonia gas release is assumed to form a toxic vapor cloud. Because the ANPI facility is located in a semi-populated area, the worst-case release scenario would reach offsite endpoints and nearby publi c receptors. This scenario is highly unlikely, however, because pressure and refrigeration liquefies the anhydrous ammonia gas that is stored at the ANPI facility. Furthermore, the worst-case release scenario is unlikely due to ANPI's strict policies and enforcement of an accidental release prevention program such as PSM. 5.2 Alternative Release Scenario A more likely alternative release scenario considered an opening in the liquid piping located near the bottom of the largest anhydrous ammonia storage vessel. The release was assumed to be liquid ammonia that formed a liquid pool that then vaporized into a toxic vapor cloud. Active mitigation was considered for the alternative release scenario. Active mitigation measures employed for the alternative release scenario included: plant and community emergency warning systems; plant personnel evacuation; trained Incident Command System emergency responders; piping and valve isolation; equipment shutdown; repairs of leaks; and wa ter deluge. The alternative release scenario assumes that ANPI employees stopped the release in 60 minutes. ANPI personnel are trained to respond to emergency ammonia releases. Therefore, the release was reduced through mitigation and ER measures employed by ANPI. Because residences are located within a 1-mile radius of the ANPI facility, the alternative release scenario would reach offsite endpoints and nearby public receptors. Fortunately, ANPI's community outreach program details shelter-in-place procedures and community notification procedures. In the event of an offsite release, residents within a 1-mile radius of the ANPI Ammonia Unloading and Storage Area are notified. 6 .0 FIVE-YEAR ACCIDENT HISTORY In the past five years, there has not been an anhydrous ammonia release from the ANPI facility that meets the regulatory criteria for accident reporting under the RMP rule (40 CFR 68.42). ANPI has had no onsite deaths, injuries, or property damage as a result of an a ccidental release of anhydrous ammonia. There have been no offsite deaths, injuries, evacuations, shelter-in-place, property damage, or environmental damage as a result of an accidental release of anhydrous ammonia from the ANPI facility. While ANPI has had no reportable release of anhydrous ammonia for purposes of the RMP rule, ANPI has had accidental anhydrous ammonia releases that have been reported to federal, state, and local agencies under Section 304 of SARA Title III (Emergency Planning and Community Right-to-Know Act [EPCRA]) and Section 302 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). ANPI maintains documentation of anhydrous ammonia releases reported under EPCRA and CERCLA. ANPI has upgraded relief valves to the highest quality and has reduced the occurrence of these accidental releases. 7 .0 CONCLUSION At ANPI, the risk for hazardous substance release is taken seriously and all employees are accountable for safe oper ations. ANPI has taken the appropriate steps to address the hazards associated with accidental hazardous substance releases. To continually improve safety at the ANPI facility, implementation of ANPI's RMP is an on-going process. As potential safety improvements are identified, these changes or enhancements are reviewed and implemented. This Risk Management Plan summarizes ANPI's rigorous RMP. ANPI's comprehensive RMP consists of a prevention program that is managed in accordance with OSHA's PSM Standard. In the event of an accidental release of anhydrous ammonia, various ER actions may be employed including, but not limited to, the following: mitigation measures, ER Plan, community notification, shelter-in-place, or evacuation. ANPI's commitment to the RMP is a critical component in the mission to be "best in class." |