Agrium Conda Phosphate Operations - Executive Summary |
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Executive Summary of the RMP Plan for Agrium Conda Phosphate Operations Nu-West Industries, Inc. 3010 Conda Road Soda Springs, Idaho 83276 1. Accidental Release Prevention and Emergency Response Policies We at Agrium CPO are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass manufacturing agricultural chemicals; phosphoric acid and phosphate fertilizer. We have 1 regulated substance present at our facility. This substance is Ammonia (anhydrous). Ammonia (anhydrous) is used for formulation of granular phosphate fert ilizer. The maximum inventory of Ammonia (anhydrous) at our facility is 1,220,000 lb.. 3. The 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 To perform the required offsite consequence analysis for our facility, we have used PHAST 5.20. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from our "NH3 Processes". In this scenario 1,220,000 lb. of Ammonia (anhydrous) is released as a gas over ten minutes. The released quantity represents the maximum storage capacity of our storage sphere. There would be offsite consequences from such a release, however limited due to the sparse residential population within the affected area of this modeled release. The alternative release scenario for Ammonia (anhydrous) involves a relea se from NH3 Processes. The scenario involves the release of 5558 lb. of Ammonia (anhydrous) in two (2) minutes. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The release is also assumed to be controlled by excess flow valve(s), emergency shutdown system(s) and water monitor. These active mitigation systems have the effect of curtailing, stopping, and/or preventing a larger release. There is no residential population within the affected area of this modeled release. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Agrium CPO maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What If/Checklist (combined). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 08/24/1994. Operating Procedures For the purposes of safely conducting activities within our covered processes, Agrium CPO maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and star tup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Agrium CPO has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed. Mechanical Integrity Agrium CPO carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Agrium CPO to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 03/04/1998. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Agrium CPO. The most recent review was performed on 01/28/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Agrium CPO conducts audits on a regular basis to determine whether the provisions set out under the RMP ru le are being implemented. The most recent compliance audit was conducted on 09/04/1998. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Agrium CPO promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Agrium CPO truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation o f the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Agrium CPO has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Agrium CPO has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period that resulted in death, injury, or significant property damage onsite. 6. Emergency Response Plan Agrium CPO carries a written emergency response plan to deal with ac cidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. LEPC District 5, Pocatello, ID is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety As developments and findings result from the implementation of the various elements of our accidental release prevention program, steps will be taken to improve safety at our facility. These changes will be implemented in a timely fashion. |