Agrifos Fertilize L P - Executive Summary
The goal of Agrifos' chemical accident prevention efforts is to ensure there are no chemical releases that threaten public health, employee safety or the environment. To accomplish this goal we manage risk through layers of protection including, but not limited to, equipment/process design, safety inspections, employee training, HAZOP's, emergency drills, etc. The Pasadena Plant's Emergency Preparedness Manual delineates roles and responsibilities during plant emergencies. The Emergency Preparedness manual also summarizes and documents the Pasadena facility's policies regarding accidental chemical releases and emergency responses. |
Agrifos' Pasadena facility is located in Harris County on the South shore of the Houston Ship Channel at 2001 Jackson Road, Pasadena, Texas 77506. This facility manufactures sulfuric acid and phosphoric acid which are used at the Pasadena facility to produce ammonium phosphate and ammonium thiosulfate fertilizers. Anhydrous ammonia, an important plant n
utrient used in the manufacture of fertilizers, is the only substance at this facility that satisfies the requirements of 40 CFR 68 Subpart F.
Off-site consequence analyses have been performed for both worst-case and alternative release scenarios. Worst-case release depicts catastrophic release of anhydrous ammonia from a cryogenic storage tank. An alternative scenario addresses a release of ammonia resulting from the rupture of a hose during a barge unloading operation. In both scenarios Agrifos used EPA guidance documents to evaluate off-site impacts. The worst-case scenario predicts an impact on the surrounding community, but this evaluation does not take into account the many safety features incorporated in the system such as engineering design, dual lined storage tank, check valves, relief valves, deluge systems, HAZOP analyses and employee training. Computer modeling indicates the alternative release scenario will impact only the nearest industrial neighbors and will not im
pact any residental neighborhoods or the community at large.
Risk Management covers all aspects of a manufacturing facility from design and construction, through start-up and operation, to maintenance and training. Accidental release prevention is an ongoing process requiring frequent monitoring and testing of equipment, management systems and people to ensure the safety of employees, the community and to protect the environment.
Industry engineering standards are used throughout design and construction. Pre-startup reviews include a safety review to ensure compliance with all OSHA standards. Safety audits include periodic HAZOP's and monthly safety inspections. Operating procedures are kept current. Management of change procedures are strictly adhered to ensure all proposed changes to equipment, operating procedures a
nd process conditions are thoroughly thought-out and receive management approval. Safe work permits are routinely employed to assure maintenance activities are conducted properly and safely. Pre-employment physicals include blood and urine testing for drugs and alcohol. All employees receive on the job training prior to job assignment. Monthly safety meetings and annual safety training are an integral part of the plant's accident prevention program.
Anhydrous ammonia is stored in a tank within a tank. The tank is equipped with redundant level controls which are remoted to a control room and equipped with high level alarms. Plant policy limits maximum level to 90% of design. Emergency pressure relief valves are located on top of the storage tank to protect the vessel from excessive pressure. Like level indicators, pressure indicators are remoted to a control room where they are recorded on a 24-hour circular chart. A vapor re-compression system eliminates routine vent
ing from the tank. Emergency power and air supply are available. Interlocks, excess flow devices, check valves, in line stack monitors, process area detectors and scrubbers provide additional protection against accidental releases.
There have been no reportable releases in the last five years and no injuries to plant personnel.
The Plant's Emergency Response Program consists of a written Emergency Preparedness Manual that outlines roles and responsibilities during emergencies and gives response guidelines for different emergency situations that may occur at the Plant. The Plant also conducts emergency drills for all employees on all shifts to test the Plant response and to improve the plan where necessary. The Plant also maintains an emergency response team with coverage around the clock. The team is trained and equipped to handle fires, rescues and HAZMAT incidents. The Plant is also a member of the CIMA mutual aid emergency response organization.
The Plant has a number of pr
ocesses in place to provide for the continuous improvement of safety. Safety policies and procedures are reviewed and updated regularly. New policies and procedures are developed as necessary. Safety training is conducted for all employees monthly. All accidents and incidents are investigated and results reviewed and tracked. An annual program evaluation is written with an action plan for improvement. An employee safety committee meets monthly to discuss current safety issues and to address any safety concerns. Specific changes designed to improve Plant safety are summarized in the Agrifos 1999 Safety Plan.