Agrium, Reese Operations - Executive Summary |
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Executive Summary, Reese Operations 1. Accidental Release Prevention and Emergency Response Policies Agrium Reese Operations is committed to employee and public safety as well as environmental stewardship. The operation has implemented measures intended to prevent possible releases of regulated substances. In the unlikely event of a release, Reese operations has an emergency response plan in place to minimize the potential effects of a release. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Manufaturing and blending of Nitrogen, Phosphate and Potash Fertilizers. We have 1 regulated substance present at our facility. This substance is Ammonia (anhydrous). Ammonia (anhydrous) is used for blending with Phosphate Fertilizers. . The maximum inventory of Ammonia (anhydrous) at our facility is 172,814.00 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 evaluate the worst case scenario, we have used TFI Lookup Tables. For alternative release scenario analyses we have employed TFI Lookup Tables as well. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from the Reese Fertilizer Blending Facility. In this scenario 100000 lb. of Ammonia (anhydrous) is released in a gaseous form over 10 minutes. The alternative release scenario for Ammonia (anhydrous) involves a release from anhydrous ammonia piping (2") in the Fertilizer Blending Facility. The scenario involves the release of 2814 lb. of ammonia in a gaseous form over 2 minutes. The release is assumed to be controlled by excess flow valve(s) and Emergency Response Procedures. 4. The General Accidental Release Prevention Program a nd 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, Reese Operations maintains a detailed record of safety information associated with the covered process. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled. The methodology used to carry out these analyses is the HAZOP methodology. The studies are undertaken by a team of qualified personnel with expertise in process operations. The most recent PHA/update was performed on 12/01/1998. Operating Procedures For the purposes of safely conducting activities within our covered processes, Agrium, Reese Operations maintains written operati ng procedures. The information is readily accessible to operators involved in the processes. Training Agrium, Reese Operations has a training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Mechanical Integrity Agrium, Reese Operations carries out 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 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, Reese Operations to manage changes in process chemicals, t echnology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews will be conducted as a regular practice as new processes are implemented and as modifications are made within established processes. These reviews are to be conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Agrium, Reese Operations conducts audits at least every three years to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 06/27/1996. Deficiencies identified during the audit are corrected. Incident Investigation Agrium, Reese Operations investigates any incident that has resulted in, o r 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 Company employees are 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 of 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. Agrium, Reese Operations has a policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Agrium, Reese Operations 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 that resulted in on-sight or off-sight injuries during this period. 6. Emergency Response Plan Agrium, Reese Operations carries a written emergency response plan to deal with accidental 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. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response plan. Saginaw County LEPC is the Local Emergency Planning Committee (LEP C) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Continued development of piping inspection programs are some of the steps we are taking to improve safety at our facility. These changes are expected to be implemented by October 1999. |