CF Industries, Inc., Tampa Terminal - Executive Summary |
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About CF Industries, Inc. CF Industries, Inc. is one of North America's largest interregional agricultural cooperatives and is owned by and serves 9 regional farm 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's fertilizer distribution system includes a network of 22 company-owned anhydrous ammonia storage facilities. The Tampa Terminal, located at the Port of Tampa, was purchased by CF in 1992 and serves as a vital link in supplying ammonia to its own manufacturing facilities and other customers. Accidental Release Prevention and Emergency Response Policies CF's Tampa Terminal handles anhydrous ammonia, a commercial chemical that is defined by the EPA as a "regulated substance" for purposes of the RMP. Its most extensive use (about 80%) is in soil fertilization as a source of nitrogen, which is essential for plant growth. The Tampa Te rminal has an extensive safety program that assures compliance with all applicable local, state, and federal rules and regulations. The facility operates under a Corporate Environmental Health and Safety Policy that endorses going beyond regulatory requirements when necessary to protect the health and safety of its employees and the public. The design, maintenance, and operation of this facility are carried out in conformance with this policy to provide a safe operation and to prevent exposure of our employees and nearby neighbors to ammonia. The facility's Emergency Response Plan is based on OSHA's emergency response standard, 29 CFR 1910.120(q). The plan includes procedures for the notification of local fire and emergency response authorities and notification of any potentially affected neighbors. The facility is linked to an alarm and telephone notification ring down system that provides emergency notification to nearby neighbors. In addition, emergency preparedness is assur ed by: Hazardous Materials (HAZMAT) trained operating and supervisory personnel; emergency response drills with local emergency responders; ammonia sensors located at critical locations in the process area and along the facility perimeter; continuous computer monitoring of ammonia sensor readings and weather conditions; and water deluge capability for ammonia vapor suppression. Stationary Source and Regulated Substance * The Tampa Terminal receives anhydrous ammonia from ships at the Tampa Port Authority's unloading dock. Ammonia is pumped from the ship to an atmospheric storage tank where it is refrigerated to -28oF. Truck and rail facilities are on site to load ammonia from the storage tank for transfer to CF manufacturing facilities and other customers. The Tampa Terminal also transfers ammonia to a privately owned pipeline for delivery to other customers. Access to the site is restricted to authorized facility employees, authorized management personnel and authorized cont ractors. * The only substance subject to EPA's RMP requirements at this facility is ammonia. 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 and Alternate Release Scenarios are based on the modeling guidelines set forth in 40 CFR Part 68, which specifies the time duration for the release to occur, weather conditions, and other assumptions to be used in the worst case and alternative case analyses. * Worst-Case Scenario: Failure of the largest storage tank when filled to the greatest amount allowed would release the contents of the tank into an emergency containment area. Administrative controls, continuous process monitoring, high-level alarms, and calibration procedures prevent the tank from being filled to capacity. It is assumed that the entire contents are released into the containment area as a liquid and evaporates. The Worst- Case Scenario is highly unlikely due primarily to the extensive and detailed safety program that guides the design, maintenance and operation of the facility (i.e. comprehensive tank inspection and maintenance program). Although highly unlikely, if a worst case release did occur, the release is predicted to go off-site. * Alternative Release Scenario: Failure of a 16-inch diameter ammonia unloading pipeline would release refrigerated ammonia into a 6,500 foot drainage ditch that discharges into Tampa Bay. It is assumed that the contents of the line segment are released as a liquid and evaporate. The alternative release scenario is highly unlikely due primarily to the extensive and detailed safety program that guides the design, maintenance and operation of the facility and includes several layers of protection to prevent line rupture and to minimize a release (e.g. annual pressure test, relief valves, emergency isolation valves, traffic protection and video surveillance). Altho ugh highly unlikely, if an alternative release scenario did occur, the release is predicted to go off-site. Accidental Release Prevention Program and Specific Prevention Steps The CF Tampa Ammonia Terminal is subject to OSHA's Process Safety Management (PSM) Standard, 29 CFR 1910.120. As recognized by EPA, the PSM Standard forms the basis for the Agency's RMP prevention program component. The primary purpose of this facility's PSM Program is to safeguard our employees and nearby neighbors from exposure to ammonia by providing assistance in evaluating and updating the facility's process and mechanical safety procedures and programs. The objectives of the PSM Program are: 1. To periodically review and update the facility's process/mechanical safety procedures and programs; 2. To provide for regular and periodic review of the facility's procedures to maintain compliance with OSHA's PSM regulations; 3. To perform Process Hazard Analyses on new and existing processes; and 4. To a ssure follow-up on the action items generated by the Process Hazard Analyses until completion Key mechanisms are listed below: 1. A comprehensive tank inspection program requires the storage tank be emptied and inspected at fifteen-year intervals; 2. The terminal has automated emergency shutdown systems with isolation valves to minimize a potential release; 3. Continuous monitoring and surveillance are conducted by operating personnel via computer and remote cameras; 4. System design incorporates multiple layers of protection including: flare system, emergency power sources, break away protection for trucks and railcars, pressure relief valves, and leak detectors; 5. Plant personnel receive annual Process Safety Management training; 6. Traffic is strictly controlled throughout the facility; and 7. Site access is strictly controlled and monitored. Five Year Accident History In the past five years there have been no ammonia releases that caused injury or property damage either o n-site or off-site. Emergency Response Program HAZMAT training is performed in accordance with OSHA regulation 29 CFR 1910.120 (q) and pre-emergency planning and drills are conducted with local emergency responders. The emergency response program complies with the OSHA PSM Program as outlined in 29 CFR 1910.119. The HAZMAT team conducts joint training and drills with the local fire department. Facility personnel conduct meetings informing the public of the facility's Emergency Response Program. The facility uses the Incident Command System that was developed by the National Fire Academy. Planned Changes to Improve Safety CF will continue to provide support to and work with the Local Emergency Planning Committee and emergency responders to plan for the appropriate emergency response and to prepare for responding to an emergency through practice and drills. CF Industries, Inc. Tampa Ammonia Terminal Risk Management Program (RMP) Executive Summary |