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PCS Nitrogen Fertilizer, L.P.

Parent Companies:
Potash Corporation of Saskatchewan
EPA Facility ID:
100000141884
Other ID:
70734RCDNCHIGHW
Facility DUNS:
117417444
Parent Company DUNS:
858404015

Location:

Address:
HWY 30 AND 3115
GEISMAR, LA 70734
County:
ASCENSION
Lat / Long:
30.218, -91.055 (Get map)
Method:
Global Positioning System (GPS) Carrier Phase Static Relative Positioning Technique
Description:
Plant Entrance (General)
Horizonal accuracy:
100 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
PCS NITROGEN FERTILIZER, L.P.
Phone:
(225) 621-1500
Address:
P.O. BOX 307
GEISMAR, LA 70734
Foreign Address:

Person responsible for RMP implementation:

Name:
Warren Stroman
Title:
GENERAL MANAGER

Emergency contact:

Name:
Cecil Hopper
Title:
ENVIRONMENTAL MANAGER
Phone:
(225) 621-1867
24-hour phone:
(225) 290-2651
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(225) 621-1500
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Ascension and Iberville LEPC
Full-Time Equivalent Employees:
CBI claimed
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2241-V6
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 5, 2016
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

OLEUM STORAGE TANKS
RMP ID:
1000082735
CBI claimed:
Yes
Program Level:
3
NAICS:
General Warehousing and Storage (49311)
Chemical name
CAS#
Quantity (lbs.)
CBI
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]
8014-95-7
None
Yes
Public OCA Chemical
0
Yes
Nitrogen Production Area
RMP ID:
1000082736
CBI claimed:
Yes
Program Level:
3
NAICS:
Nitrogenous Fertilizer Manufacturing (325311)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
None
Yes
Flammable Mixture
00-11-11
None
Yes
Public OCA Chemical
0
Yes
Public OCA Chemical
0
Yes

RMP Preparer:

Name:
Cecil Hopper
Address:
Hwy 3115
Geismar, LA 70734
Foreign Address:

Phone:
(225) 621-1867

Latest RMP Submission:

Date:
Oct. 4, 2017
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000066069

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Nitrogen Production Area)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Berms
not considered:
  • Dikes
  • Enclosures
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in OLEUM STORAGE TANKS)
CBI claimed:
No
Percent weight:
30.0
Physical state:
Liquid
Model used:
STAWaRS
Wind speed (meters per sec):
3.00
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Berms
  • Sumps
  • New secondary containment installed in 2015
not considered:
  • Enclosures
  • Drains
Active mitigation
considered:
  • Excess flow valve
  • Emergency shutdown
  • New secondary containment installed in 2015
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers
Public OCA Chemical (in Nitrogen Production Area)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Nitrogen Production Area)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Nitrogen Production Area)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

Jan. 20, 2016 at 04:05
ID:
1000051361
NAICS:
Nitrogenous Fertilizer Manufacturing (325311)
Duration:
9 hours and 25 minutes
Chemicals involved:
  • Ammonia (anhydrous)
Release events:
Gas release
Weather conditions at time of event
Wind speed:
4.0 miles/h NE
Temperature:
53.00 ℉
Atmospheric stability:
C
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
15
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Overpressurization
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • New mitigation systems
Feb. 14, 2013 at 19:45
ID:
1000051360
NAICS:
Nitrogenous Fertilizer Manufacturing (325311)
Duration:
15 minutes
Chemicals involved:
  • Ammonia (anhydrous)
Release events:
Gas release
Weather conditions at time of event
Wind speed:
1.0 miles/h N
Temperature:
50.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
2
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
200
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Revised maintenance
  • Revised operating procedures

7. Prevention: Program level 3

OLEUM STORAGE TANKS, General Warehousing and Storage (49311)
Prevention Program ID:
1000069732
Safety Review Date
April 30, 2015, since latest RMP submission
PHA Update Date
Feb. 12, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • Perimeter Monitors
Changes since PHA
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
Nov. 1, 2016, since latest RMP submission
Training Review Date
March 1, 2017, since latest RMP submission
Maintenance Review Date
Jan. 8, 2016, since latest RMP submission
Maintenance Inspection Date
Aug. 29, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 21, 2017
Management of Change Review Date
July 31, 2013
Pre-startup Review Date
Aug. 9, 2017
Compliance Audit Date
Aug. 5, 2016
Compliance Audit Change Completion Date
July 31, 2019
Incident Investigation Date
March 20, 2008
Incident Invest. Change Completion Date
Aug. 20, 2008
Participation Plan Review Date
July 31, 2013
Hot Work Review Date
April 14, 2014
Contractor Safety Review Date
July 31, 2013, since latest RMP submission
Contractor Safety Eval. Date
Sept. 27, 2017, since latest RMP submission
Nitrogen Production Area, Nitrogenous Fertilizer Manufacturing (325311)
Prevention Program ID:
1000069733
Safety Review Date
July 1, 2015, since latest RMP submission
PHA Update Date
June 23, 2017, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Observation
Procedure Review Date
March 20, 2017, since latest RMP submission
Training Review Date
March 1, 2017, since latest RMP submission
Maintenance Review Date
Jan. 8, 2016, since latest RMP submission
Maintenance Inspection Date
Feb. 23, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 29, 2017
Management of Change Review Date
Sept. 21, 2017
Pre-startup Review Date
Sept. 21, 2017
Compliance Audit Date
Aug. 5, 2016
Compliance Audit Change Completion Date
July 31, 2019
Incident Investigation Date
June 11, 2017
Incident Invest. Change Completion Date
Dec. 31, 2019
Participation Plan Review Date
July 31, 2013
Hot Work Review Date
June 1, 2014
Contractor Safety Review Date
July 31, 2013, since latest RMP submission
Contractor Safety Eval. Date
Sept. 27, 2017, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Sept. 28, 2017
Local Response Agency:
Local Response Agency Phone:
(225) 621-8300
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES



As a division of PotashCorp, PCS Nitrogen Fertilizer, L.P. must abide by all of Potash Corp's policies. It is PotashCorp's Safety, Health and Environmental (SHE) policy that "Everybody who works for Potash Corp, anywhere, is responsible for PotashCorp's SHE performance. Good SHE performance is critical to the success of our business."



Our goals are simply stated: no harm to people, no accidents and no damage to the environment. We will continue to drive down the environmental and health impact of our operations by reducing waste, emissions and discharges, and using energy efficiently. We will produce quality products that can be used safely by our customers.



Management Plan



Review and updating the facility RMP is the responsibility of the facility Environmental Manager. The facility RMP will be updated in accordance with the requirements of 40 CFR 68.190. Circumstances which may warrant changes to the RMP include, but are not limited to, the following:



- At least every 5 years from the last update.

- Modification of an existing process that contains an RMP regulated compound.

- Within 6 months of a qualifying RMP emergency/release/explosion type incident (e.g., incident where off site shelter in place required, incident where road closure is required)

- No later than the date upon which an RMP regulated substance is present in a new process above a threshold quantity.

- Within 6 months of a change that requires a revised PHA, Hazard Review or offsite consequence analysis.

- Within 6 months of a change that alters the Program level that applies to any covered process.



Implementation of the facility RMP Program is a shared responsibility. An organization chart of facility management is provided in Section 1.5 of the PCS RMP Manual. Implementation of the various RMP Program Elements is assigned as follows:



? RMP Process Delineation - Environmental Manager

? RMP Threshold Determinati
ons - Environmental Manager

? RMP Offsite Consequence Analysis - Environmental Manager

? RMP Manual Updates - Environmental Manager

? RMP Training - Environmental Manager

? RMP Compliance Audits - Environmental Manager

? OSHA PSM (elements not otherwise specified) - Safety Manager

? Mechanical Integrity - Maintenance Manager

? Incident Investigations - PSM Coordinator



DESCRIPTION AND REGULATED SUBSTANCES



The PCS Nitrogen Fertilizer, L.P. (PCS) facility is located on Highway 3115 between Highway 75 and 30 in Geismar, Louisiana. The facility manufactures liquid Phosphate and Nitrogen based fertilizers and industrial grade Nitric Acid, Ammonium Nitrate (liquid only) and Phosphoric Acid. The Applicable NAICS codes are 325311 and 325312. The regulated substances on site that are above the threshold quantity are ammonia, oleum and a flammable gas mixture (Ammonia Process - Primarily Hydrogen and Natural Gas). The Geismar Complex is subject to the requirements of Program 3 as stated in 40 CFR Part 68.12 due to the applicability of the NAICS code. The facility is also subject to the requirements of the OSHA Process Safety Management Standard, 29 CFR 1910.119.



HAZARD ASSESSMENTS



The worst-case release scenario (WCS) and the Alternative Release Scenario(s) (ARS), including administrative controls and mitigation measures to limit the distances for each reported scenario, have been performed for all the listed toxic chemicals at the facility. The EPA RMP Comp program was used to perform the offsite consequence analysis for the facility for the ammonia releases and the STAWaRS model was used for the oleum releases. The reported worst-case scenarios are the toxic chemicals that could result in the release of the largest quantity of chemical and has the greatest distance to the endpoint. An ARS was reported for each substance above the regulated threshold. The scenarios were modeled for releases that are more probable than the worst-case scenario.



PREVENTION
PROGRAM



The objective of the accident prevention program is to develop a proactive approach to the identification, evaluation, and prevention of chemical releases which results from lack of procedures, human error or equipment failure. PCS strives to meet these objectives through the implementation of the PSM and RMP programs. The key elements of these programs are:

1. employee participation

2. process safety information

3. process hazard analysis

4. operating procedures

5. training

6. contractor safety

7. pre-startup safety reviews

8. mechanical integrity program

9. hot work permitting

10. management of change

11. incident investigations

12. emergency response plans

13. compliance audits



Employee participation



Employee participation is an important element of the Process Safety Management (PSM) and the Risk Management programs. The knowledge, education, experience, and skills of selected employees are used to enhance the process hazard analysis (PHA), standard operating procedures(SOPs), operator training, and the incident investigation element of these programs. PCS Nitrogen employees are selected on the basis of their experience, process knowledge, operating job task requirements, and knowledge of maintenance practices.



Process Safety Information



PCS Nitrogen's process safety information is included in the facility PSM Manual. The process safety information in the PSM Manual provides a database to support the required elements of its PSM and Risk Management programs; as well as supplying information for PCS Nitrogen employees to identify and understand the chemical, technological, and equipment hazards associated with the process. This information has been made available to all employees, including contractors, in PCS Nitrogen's Geismar complex. Process safety information includes information from the following areas: 1) Material Safety Data Sheets (MSDS) on all chemicals 2) other hazardous chemical information such as exposure guide
line, physical property data, formulas, reactivity data, toxicity data, corrosivity data and vendor information can be found in their respective reference documents 3) Technology Information and 4) Process Equipment Information.



Process Hazard Analysis



The purpose of conducting a process hazard analysis (PHA) is to identify potential accidents or hazard scenarios that may occur and could result in undesirable consequences. Depending upon the complexity of the process system being analyzed, a variety of methodologies can be used. PCS Nitrogen chose the "HAZOP" (Hazard and Operability Study) and "What if" processes. PCS conducts a PHA on any process involving an OSHA defined highly hazardous chemical and/or RMP regulated substances. The scope of each PHA includes: 1) hazards of the process, 2) identification of any previous accident which had a likely potential for catastrophic consequences, 3) Engineering and administrative controls, 4) Consequences of failure of controls, 5) facility location, 6) human factors, 7) qualitative evaluation of the effects on all work place employees, 8) risk ranking matrix, 9) Environmental impact, 10) RMP review. The PHA team will write the analysis findings and all suggestions are be considered by management based on risk ranking.



Operating Procedures



PCS has developed operating procedures that provide operating instructions for each part of the process from the introduction of raw material to the shipment of finished product. The operating procedures give detailed step by step operating instructions for each part of the process during: 1) Initial startup, 2) Normal operation, 3) Temporary operation, 4) Emergency shutdown, 5) Emergency operation, 6) Normal shutdown, and 7) Start-up following turnaround or emergency shutdown.



Training Plan



PCS has developed a training plan that provides a guide for the training of each employee in job related and job specific responsibilities. Each new employee is given a comprehensiv
e orientation training program and a basic job specific training covering their job duties and responsibilities as they relate to both normal and abnormal operating conditions. Each employee must demonstrate the required skills to perform their job upon completion of training and must be certified and proficient in performing the duties of their assigned jobs.



Contractor Safety



PCS developed a contractor entry authorization program in accordance with 29 CFR 191.119 and API Recommended Practice 2220, Sept. 1991. This program outlines the entrance requirements a contractor, sales person, visitor, consultant, vendor or service company must abide by in order to perform work at the facility.



Pre-Start up Review



PCS conducts a pre-start up review prior to the introduction of any OSHA defined highly hazardous chemical and/or RMP regulated substance to ensure that new process facilities or modifications to original equipment, controls or safety interfaces of a covered process or covered system do not create a hazard to the facility personnel, civilian population surrounding the facility or the environment. The review is also intended to ensure that hazards identified in the PHA have been properly addressed by design or procedural changes.



Mechanical Integrity



The mechanical integrity program establishes and implements the maintenance and inspection programs to ensure the mechanical integrity and reliability of fixed equipment, plant piping, rotating equipment, relief devices, instrumentation and electrical equipment within the covered processes. The maintenance and inspection program includes and applies to pressure vessels, non or low pressure vessels, storage tanks, piping and piping components, heat exchangers, pumps, compressors, heaters, pressure safety relief valves, emergency shutdown devices, controls, electrical equipment and instrumentation. This program encompasses preventive and predictive maintenance of plant equipment, calibration and testing
of instruments and electrical equipment, and routine inspections for plant equipment and piping.



Hot Work Permits



The Safety Work Permit System establishes the safest, most useable method of providing all personnel, with procedures to consistently apply when performing work at sites under the PCS jurisdiction. The Safety Work Permit system is broken down into 8 types of permits. 1) Confined Space- Attendants Permit, 2) Confined Space Entry Permit, 3) General Safe Work Permit, 4) Line Breaking Permit, 5) Hot Work Permit, 6) Electrical Permit, 7) Excavation, 8) Vehicle Entry. The requirements of each of the permits can be found in the PCS Nitrogen Safety Manual section 11.0.



Management of Change



This process ensures that all modifications to equipment, procedures, raw materials and processing conditions other than "replacement in kind" are identified and are reviewed by qualified personnel prior to their implementation. Except in emergencies, such changes are approved in writing prior to their implementation. This review process ensures that additional risk are not introduced, all changes are documented, existing procedures are updated, new procedures are written as required, all process safety information is updated, and that all employees that are affected by the change are properly trained.



Process Incident Investigation



The objectives of the Process Incident Investigation management system are to: 1) Carefully analyze and document the root cause(s) of the more significant problems that are encountered. 2) Identify, track and implement the corrective actions required to reduce the likelihood of recurrence of the more significant incidents and 3) Track and trend the root cause data from these incidents to identify system problems that when corrected, can lead to dramatic improvements in performance by eliminating whole classes of problems.



Emergency Planning and Response



PCS has implemented an Emergency Management Plan (EMP) to assure the be
st possible prevention, preparedness, response, and recovery in the event of an emergency. The Primary objectives of EMPs are protection of life and elimination or reduction of harm to the public, employees, contractors, and the environment. Secondary objectives are continued production and delivery of products and services. Response and recovery actions must minimize damage done to facilities, equipment, and both delivery and communication systems.



Compliance Audits



This plan ensures that compliance audits will be conducted in each operating department and service department exposed to highly hazardous and/or regulated toxic chemicals in the covered processes every three years. The audits are directed by both a Corporate Process Safety Assessment Procedure and an Internal Process Safety Assessment Procedure. Each audit is performed by a team that is knowledgeable of the process.



FIVE-YEAR ACCIDENT HISTORY



Although PCS Nitrogen has a stringent release prevention policy, there have been three incidents within a covered processes at the facility within the past 5 years. These are as follows:



1. On February 14, 2013, at approximately 7:45 PM operators were in the process of starting up the Urea Plant when an Aldrich Pump seal failed resulting in the release of 1,608 lbs of ammonia gas. Facility personnel sheltered in place. Two people were injured with one person requiring hospitalization with vision and breathing impairment. Release notifications were promptly made to all appropriate State and federal officials. Follow up written reports were submitted to the LDEQ, State Police, Ascension and Iberville Parish LEPCs and EPA Region VI. In response to this incident the Urea Plant start up procedures were modified as well as additional preventative measures were incorporated into maintenance procedures associated with the Urea Plant. The following provides the specific data elements for this release:



a) Duration of Release - 30 seconds

b) NAICS Code
- 325311

c) Type of Release - Air

d) Weather Conditions - 50 ?F, Wind Direction - North, Wind Speed - 5 mph, Precipitation - None

e) On-site Impacts - Two persons injured, one hospitalized

f) Known Offsite Impacts - None

g) Initiating Event and Contributing Factors - Quad ring failure during Plant/pump start up.

h) Offsite Responders Notified - Yes, Ascension and Iberville LEPCs

i) Operational or Process Change that Resulted from Investigation - (A) Revision to Maintenance Procedures and (B) Addition of Water Deluge Over Pumps



2. On January 20, 2016, at approximately 4:05 AM the emergency relief vent on the north ammonia storage tank lifted releasing ammonia vapor. After investigating, it was determined that the ammonia vapor discharge line was obstructed by an accumulation of oil, causing the tank to become pressurized. The blockage was upstream of the header to the ammonia vapor discharge compressors and the emergency flare associated with the ammonia storage tanks resulting in the relief valve lifting. Road blocks along 3115 in front of the plant were established as a precautionary measure. PCS personnel conducted monitoring along HWY 3115 between Gate C-1 and the Ammonia Plant Cooling Tower using Draeger™ tubes and a portable field meter. Initial results were from 30 to 40 ppm, but by 8:38 AM the ammonia levels had dropped to 15 ppm. After 9 AM the ammonia levels were from 0 to 5 ppm in this same area. A total amount of 2,183 lbs of ammonia was released. The following provides the specific data elements for this release:



a) Duration of Release - 9 hours, 25 minutes

b) NAICS Code - 325311

c) Type of Release - Air

d) Weather Conditions - 53 ?F, Wind Direction - Northeast, Wind Speed - 4 mph, Precipitation - None

e) On-site Impacts - None

f) Known Offsite Impacts - None

g) Initiating Event and Contributing Factors - Accumulation of compressor oil in ammonia distribution piping and pressurization of north ammonia storage tan
k

h) Offsite Responders Notified - Yes, Ascension and Iberville LEPCs

i) Operational or Process Change that Resulted from Investigation - (A) Revision to Maintenance Procedures and (B) Project to Add Water Deluge Over PSVs (C) Project to Redesign Ammonia Distribution System



CHEMICAL SPECIFIC PREVENTION STEPS



The processes at the PCS Nitrogen plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA RMP and PSM covered processes at this facility. Collectively, these prevention program activities will help prevent potential accident scenarios.



In addition to the accident prevention program activities, the PCS Nitrogen plant has safety features on many units to help 1) contain and control a release, 2) quickly detect a release, and 3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes.



Release Containment and Control

1. Process relief valves in ammonia service that discharge to a flare to capture and incinerate episodic releases.

2. Scrubbers to neutralize chemical releases.

3. Valves to permit isolation of the process (manual or automated)

4. Secondary containment to contain liquid releases

5. Redundant equipment and instrumentation

6. Atmospheric relief devices



Release Mitigation

1. Fire suppression and extinguishing systems

2. Vapor suppression systems

3. Trained emergency response personnel on site

4. Personal protective equipment

5. Mobile fire fighting equipment



EMERGENCY RESPONSE PROGRAM INFORMATION



The core elements of the emergency response program are incorporated in the Emergency Management Plan (EMP). The EMP works in conjunction with numerous other plans including Hazardous Materials Response (HAZMAT), Hazard Communications (HAZCOM) and various site-specific plans. The core elements of the EMP are training of personnel, roles and responsibilities, emer
gency action levels, emergency operations center, exercises and drills, and notification procedures. This comprehensive plan is available to all personnel in the event of an emergency.



PLANNED CHANGES TO IMPROVE SAFETY



PCS continually strives to improve the safety of operations and the impact on the public and the environment. PCS has fully staffed, well trained and experienced, environmental and safety departments. All members of each department work closely together to implement sound accident and release prevention programs. In addition, PCS has implemented an employee driven Behavioral Based safety program to operate alongside the traditional safety and environmental process. This program allows co-workers to observe each other's actions and anonymously report safe or unsafe behaviors and conditions. Through the dedication and effort of PCS employees working toward continual improvement of SHE programs will result in further reductions of OSHA recordables and environmental releases.