CF Industries, Inc. - Mount Vernon Terminal - Executive Summary
Risk Management Program (RMP) Executive Summary |
CF Industries, Inc., Mt. Vernon Terminal
About CF Industries, Inc.
CF Industries is one of North America's largest interregional cooperatives, owned by and serving nine regional cooperatives. Through its Members, the Company's nitrogen, phosphate and potash fertilizer products reach over a million farmers and ranchers in 48 states and two Canadian provinces. CF Industries' fertilizer distribution system includes a network of 22 Company-owned anhydrous ammonia storage facilities.
It is the policy of CF Industries to conduct its business and operate its facilities in a manner designed to protect the environment, and the health and safety of its employees. This protection extends to neighbors of the Terminal. Additionally, we are committed to complying with all applicable environmental laws, rules and regulations and the Company will promote environmental concern and education among our employees and with the communities in which we op
erate. CF Industries is equally committed to protecting the safety and health of its employees, and will take all practical steps to eliminate or reduce the exposure of employees to conditions adversely affecting their safety or health while on the job, and encourages off-the-job employee safety and health awareness as well. The Company will not hesitate to go beyond legal requirements if, in its prudent judgment, a higher level of performance is in order. The commitment to excellence regarding Environmental, Health & Safety (EHS) issues is supported in total by Senior Management of CF Industries.
Stationary Source and Regulated Substance
One of the Company's distribution facilities is the Mt. Vernon Terminal, located approximately 2 miles southwest of Mt. Vernon. CF Industries has been a member of the community since 1973. Anhydrous ammonia is the only RMP-regulated substance at the Mt. Vernon Terminal. The Mt. Vernon Terminal receives ammonia by barge on the Ohio River and dis
tributes it into tank trucks. The Terminal stores anhydrous ammonia in one refrigerated above-ground tank. An extensive EHS program assures compliance with applicable local, state and federal rules and regulations.
CF Industries' anhydrous ammonia is used primarily as a fertilizer. Ammonia is a source of nitrogen that is essential for plant growth. It is classified by the Department of Transportation as a non-flammable, compressed gas.
Accidental Release Prevention and Emergency Response Policies
CF Industries' Layers of Protection
CF Industries has implemented a comprehensive program at its distribution facilities designed to safeguard the environment, its workers and the surrounding communities. The layers of protection are the numerous prevention mechanisms implemented at the Company's fertilizer storage facilities to help manage the risks inherent in handling anhydrous ammonia. The key safety features are listed below.
7 The facility conducts comprehensive reviews to insu
re that hazards associated with CF Industries' processes are identified and controlled efficiently. These reviews are conducted in accordance with the U.S. Occupational Safety and Health Administration's Process Safety Management (PSM) Standard. One of these reviews is a Process Hazards Analysis (PHA) which is designed to identify all failure scenarios that could lead to a significant exposure of ammonia to workers, the public, or the environment. The review is undertaken by a team of qualified personnel with expertise in engineering and process operations and is revalidated every five years. Any findings related to the PHA are addressed in a timely manner. All PHA's conducted after June 21, 1999 will consider offsite impact.
7 Critical operating conditions at the Mt. Vernon Terminal are monitored through two independent sets of instrumentation. Pressure and level gauges alert Terminal personnel with alarms and automatic shutdowns.
7 A flare, activated automatically, helps cont
rol tank pressure by burning ammonia vapor before it can be released to the atmosphere. This is performed when the ammonia compressors are unable to maintain the tank pressure.
7 The ammonia tank system is protected by pressure/vacuum relief valves and compressors which operate automatically.
7 Emergency shutdown buttons are located throughout the facility. These buttons can be used by anyone to shutdown the product flows in the event of an emergency.
7 CF Industries has instituted a comprehensive tank inspection program that requires every tank be inspected at fifteen year intervals. Tanks are emptied and subjected to a series of tests. This program is designed to identify and correct any tank problems. A tank outage typically lasts three months and costs the Company $300,000. Although an inspection is costly in terms of money and distribution logistics, CF Industries believes the safety benefits far outweigh the costs.
7 Through CF Industries' PSM program, all covered equip
ment used at the facility undergoes routine performance tests and maintenance. This PSM program forms the foundation for the RMP prevention program.
7 The Mt. Vernon Terminal is staffed around-the-clock. Thus, operating temperatures and pressures, and other parameters, are monitored 24 hours a day. Such monitoring allows Terminal personnel to quickly respond to operational problems in their early stage; thereby preventing releases of ammonia to the environment.
7 Every truck which enters or leaves the facility with anhydrous ammonia is inspected by facility personnel. Each truck is checked for leaks, and surveillance cameras provide operating personnel additional views of truck loading conditions. Any truck that fails the inspection is not permitted to remove anhydrous ammonia from the facility.
7 Another essential element of our Layers of Protection is employee training and continuing education. Every operating person receives extensive Hazardous Materials Safety training wit
h eight hours of refresher training each year. They also receive documented training covering 49 specific topics.
7 The Mt. Vernon facility maintains industrial hygiene and medical programs that meet or exceed standards of good professional practice.
7 CF Industries also works extensively with the local emergency and fire responders through simulation training and drills. The Company believes it is important that first responders are prepared to deal with any emergency on site.
7 CF Industries routinely carries out highly documented maintenance checks on its process equipment to ensure proper functions. Process equipment examined by these checks includes pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.
7 CF Industries maintains and enforces formal procedures and policies on environmental protection, safety awareness, facility design and operation, and contractor compliance that, in many cases, go beyond le
gal and regulatory requirements. The Company's internal EHS audit program is designed to make the Mt. Vernon Terminal the best in the industry. In addition, the Terminal maintains written operating procedures which describe what tasks a process operator must perform, define safe operating parameters that must be maintained, and set safety precautions for operations and maintenance activities. Each facility is assessed for compliance with federal, state and local regulations every year.
Emergency Response Program
CF Industries has developed Emergency Manuals for all of its distribution facilities, including the Mt. Vernon Terminal. Copies of the Mt. Vernon Emergency Manual are kept at the facility and the Company's corporate headquarters. Copies are sent to the Local Emergency Planning Committee, the State Emergency Response Commission, and the Mt. Vernon Fire & Rescue Department. The Manual includes all aspects of emergency response including personnel roles and responsibilities
, lines of authority, communication, pre-emergency planning, emergency recognition and prevention, emergency alerting and response procedures, site evacuation routes, site security, decontamination, emergency response equipment, medical treatment and first aid services, and post-emergency activities and training. The Manual is reviewed annually with the first responders. In addition, CF Industries trains its employees annually on the use of this Manual.
Worst Case Scenario
The worst case release scenario for the Mt. Vernon Terminal was calculated using the methodology included in the EPA's RMP Off-Site Consequence Guidance. The worst case release scenario, which is highly unlikely, involves a complete release of the volume of the storage tank. Liquid ammonia is assumed to be immediately released to form a pool in the secondary containment (a passive mitigation measure), from which evaporation takes place. Under the worst case weather conditions of low wind speed and minimal atmos
pheric dispersion, off-site impacts will occur. The EPA's RMP*Comp program, Version 1.06, was used to determine the maximum downwind distance the ammonia release could impact the general public and/or the environment. This assessment incorporated a toxic endpoint (ammonia concentration) of 0.14 mg/L. This toxic endpoint refers to the maximum airborne concentration below which it is believed nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair an individual's ability to take protective action.
Alternative Release Scenario
In addition to the worst case scenario, the RMP rule also requires the submittal of an alternative release scenario, or more realistic release scenario. For the Mt. Vernon Terminal, the alternative release scenario involves a release of ammonia vapor from a pressure relief valve on the top of the ammonia storage tank. The scenario further assumes th
at the pressure relief valve properly re-seats, as has been shown in practice. Thus, the release is assumed to occur for one minute. No active mitigation measures were considered in evaluating a release under this scenario.
The above-described release was chosen because it represents the most common type of release, as determined from an evaluation of all recent releases from CF Industries Terminals. CF Industries believes this release represents the most probable type of release which could occur at the Mt. Vernon Terminal, which has off-site impacts to the general public and/or the environment.
Under average weather conditions of low/moderate wind speed and neutral atmospheric dispersion, the release will cause off-site impacts. The EPA's RMP*Comp program, Version 1.06, was used to perform the off-site consequence analysis. The ammonia toxic endpoint of 0.14 mg/L was used in the assessment.
The Five-Year Accident History
There has never been a catastrophic failure of a refri
gerated storage tank at any of the 22 CF Industries-owned ammonia storage and distribution facilities. Additionally, CF Industries' Mt. Vernon Terminal has had no releases in the last five years that resulted in any deaths, injuries, or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
Planned Changes to Improve Safety
CF Industries will continue to coordinate information and training with emergency responders. This information-sharing will occur during face-to-face discussions and emergency response drills.
CF Industries will continue its long standing policy to host Community Interface Meetings for the first responders, government officials, businesses and neighbors. During these meetings, the attendees receive a tour of the facility and receive information about CF Industries and its accident prevention programs. Following the presentation, the facilities' employees are available
to answer questions.
In addition, as part of the Company's Community Giving Program, CF Industries provides financial assistance to enhance public safety in the community. CF Industries also provided funds used to send 3 members of the Mt. Vernon Fire & Rescue Department to special ammonia suppression training in Holden, Louisiana, conducted by CF Industries and the Louisiana State Police. This training provides firefighters the opportunity to learn how to protect the public in the unlikely event of an accidental ammonia release. Also, the Company has supported the local Red Cross Disaster Relief Fund.