PCS Nitrogen Fertilizer, L.P. LaPlatte Plant - Executive Summary |
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a) Accidental release prevention (ARP) policies follow OSHA's PSM format. The ARP policies are identified in our LaPlatte Risk Management Program Manual. Emergency response (ER) policies follow the Integrated Contingency Plan format. The ER policies are identified in our One-Plan Manual. b) The stationary source is the LaPlatte Plant owned by PCS Nitrogen Inc. that produces liquid nitrogen based fertilizers for the agricultural industry. The raw materials are natural gas, water, and air. Through chemical processes, the raw materials form anhydrous ammonia, liquid carbonic, urea, ammonium nitrate, nitric acid, and UAN. Regulated substances in excess of the threshold quantities and within the covered process are Ammonia, Ammonia Solutions, Chlorine, and Hydrogen gas. Regulated substances below the threshold quantities and located on site are Nitric Oxide and Methane. c) Toxic worst case involves release of anhydrous ammonia from a large refrigerated storage tank. The amount relea sed is nearly 30 million gallons and the 200 ppm endpoint distance exceeds 25 miles. Passive mitigation includes a containment dike. Flammable worst case involves the release of Hydrogen gas from a process vessel resulting in an explosion. The 1 psi overpressure endpoint reaches less than 100 ft. off-site. Alternative toxic release cases involve anhydrous ammonia, aqua ammonia, and chlorine. Anhydrous ammonia case involves a high pressure leak with an endpoint distance of 2.2 miles. Aqua ammonia case involves a pipe rupture with an endpoint distance extending about 200 ft. off-site. Chlorine case involves a storage cylinder release with a 3 ppm endpoint distance of 1.2 miles. Alternative flammable release case involves a hydrogen release similar to the worst case except using a smaller explosive yield factor. The endpoint distance extends less than 100 ft. off-site. Active mitigation for ammonia releases can include water spray suppression of gas release and absorbent suppres sion of liquid spill. Active mitigation for chlorine releases can include the use of a chlorine patch to seal a leak. Active mitigation for all chemicals can include emergency isolation of the release source. d) Accidental release prevention is promoted through the use of standard operating procedure manuals, standard operating conditions & limits manuals, process safety management (LRMP) manual, safety procedures manual, and One-Plan emergency response and prevention manual. For example, an accidental spill of nitric acid can be neutralized by the use of soda ash, and then cleaned up, preventing the spill from harming the environment. For ammonia gas, a mist nozzle on a fire hose can be used to knock down a portion of the release since ammonia gas will rapidly combine with any source of moisture. e) The LaPlatte Facility has had no accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries , evacuations, sheltering in place, property damage, or environmental damage within the last five years. f) Emergency response program consists of policies and training identified in the One-Plan integrated contingency plan. The LaPlatte plant maintains an emergency response team on staff and coordinates with outside response agencies through the Sarpy County LEPC for additional assistance. g) Planned changes to improve safety include conducting a more extensive facility siting review, conducting an industrial hygiene assessment for chemical exposure, qualifying vendors and suppliers through a more comprehensive approval process, and implementing safety improvements identified through process hazard analyses. |