Clean Air Act 112fr) Risk Management Program (RMP;

SPCC/FRP

EPCRA

March - April 2012

US EPA Region 10

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•	Ammonia Safety

•	Explosion Hazards

•	Goodyear

•	Aqua Ammonia

•	Pressure Relief Valves

•	Program Alert: OR NHS
Fertilizer Retailers

•	EPCRA Tier 2 Reports

•	RMP Training in 2012

•	Wenatchee facility fined
for RMP Violation

CHEMICAL EMERGENCY
PREVENTION & PLANNING

Newsletter

US EPA Region 10,
ERU ECL-116
1200 6th Avenue, Suite 900
Seattle, Washington 98101

206.553.1255
Fax: 206.553.0124

R10 RMP Webpaqe

Newsletter Contacts:
For RMP: Javier Morales at

moraies.iavier@epa.gov

For SPCC/FRP: AK: Matt Carr at

carr. matthe w @ epa. go v

WA OR ID: Michael Sibley at

sibley.michael@epa.gov

For EPCRA: Suzanne Powers at

powe rs.suzan ne @ epa. go v

For free Subscription:

allen.stephanie@epa.gov

©REPORT

J

CHEMICAL or OIL SPILLS

to the NATIONAL RESPONSE CENTER

1-800-424-8802

PROGRAM ALERT

Oregon Ammonia
Retailers

The state of Oregon OSHA has
added agricultural ammonia retailers
to the Process Safety Management
program. Should you fall under the

rule requirements for Process Safety
Management (PSM) 1910.119 (see
below), your Program Level in the Risk
Management Program may change.

One criterion for Risk Management
Program Level 3 status is regulation by
PSM. If this applies to your facility, you
need to access your RMP through CDX
and correct your Program Level.

Details of Program Level 3 requirements
are available online (RMP Guidance)

More information on PSM requirements
are available online (Oregon OSHA PSM)

Oregon OSHA Letter to Agricultural
Ammonia Retailers

Marilyn K. Schuster

Policy Manager Oregon OSHA

October 15, 2010

The purpose of this letter is to advise
you that agricultural farm supply
businesses having large quantities of
anhydrous ammonia at their principal
place of business(s) may fall under
the rule requirements for Process
Safety Management (PSM) 1910.119.
The threshold quantity for this rule
to apply is 10,000 pounds or 1,943
gallons of anhydrous ammonia.

(Read on ...)

Aqua Ammonia
Explosion Sends
Four Workers to
Hospital

(Gatekeeper Newsletter 11/1/11)

WNDU 16 South Bend (Indiana):
An explosion at an Elkhart
County, indiana fertilizer business
October 3, 2011 sent four workers
to the hospital. A little after
11:30 a.m., a large tank filled
with aqua ammonia exploded
at T and T Fertilizer. The most
serious injuries were suffered
by a 24-year-old employee of
Southwest Welding, a private
contractor hired to perform tank
repairs. He was removed from the
scene by a medical helicopter.

The tank became airborne after
the explosion and landed on the
southwest corner of the property.
Three other workers were sent to
the hospital after being exposed
to, or inhaling chemicals at the
scene.

Editors note:

Ammonia becomes flammable at
concentrations of approximately
15% to 28% by volume in air.
When mixed with lubricating
oils, its flammable concentration
range is increased. It can explode
if released in an enclosed
space with a source of ignition
present, or if a vessel containing
anhydrous ammonia is exposed
to fire.

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Chemical Emergency Prevention & Planning Newsletter

March - April 2012

Over-pressure Protection: Heat exchanger rupture and
ammonia release

U.S. Chemical Safety and Hazard Investigation Board (CSB)

This case study examines a heat exchanger rupture
and ammonia release at the Goodyear Tire and
Rubber Company plant in Houston, Texas.

Goodyear uses pressurized anhydrous ammonia
in the heat
exchanger to cool
the chemicals used
to make synthetic
rubber. Process
chemicals pumped
through tubes inside
the heat exchanger
are cooled by
ammonia flowing
around the tubes in
a cylindrical steel
shell.

On June 10, 2008,

Goodyear operators
closed an isolation
valve between the
heat exchanger shell
(ammonia cooling
side) and a relief
valve to replace a
burst rupture disk
under the relief
valve that provided
over-pressure protection. Maintenance workers
replaced the rupture disk on that day; however, the
closed isolation valve was not reopened.

On the morning of June 11, an operator closed a
block valve isolating the ammonia pressure control
valve from the heat exchanger. The operator then
connected a steam line to the process line to clean
the piping. The steam flowed through the heat
exchanger tubes, heated the liquid ammonia in
the exchanger shell, and increased the pressure
in the shell. The closed isolation and block valves
prevented the increasing ammonia pressure from
safely venting through either the ammonia pressure
control valve or the rupture disk and relief valve.
The pressure in the heat exchanger shell continued
climbing until it violently ruptured at about 7:30 a.m.

The catastrophic rupture threw debris that struck
and killed a Goodyear employee walking through the
area. The rupture also released ammonia, exposing
five nearby workers to the chemical. One additional
worker was injured while exiting the area.

Maintenance Procedures

Training requirements for operators in the
production area included standard operating
procedures specifically applicable to the rupture

disk maintenance
performed on June
10:

•	Use of the
work order system
including obtaining
signature verification
both before the work
starts and after job
was completed; and

•	Use of lockout/
tagout procedures
for equipment that
was undergoing
maintenance.

The CSB found
evidence of
breakdowns in
both the work
order and lockout/
tagout programs
that contributed
to the incident.
Although the work
order procedure required a signature before work
commenced and after the work had been completed,
operators reported that maintenance personnel did
not always obtain production operators' signatures as
required. Additionally, work order documentation was
not kept at production control stations.

Operators used the lockout/tagout procedures to
manage the work on the heat exchanger rupture disk,
but did not clearly document the progress and status
of the maintenance. Information that the isolation
valve on the safety relief vent remained in the closed
position and locked out was limited to a handwritten
note.

Goodyear's work order system for maintenance
requires the process operator to sign off when
the repairs are completed. However, whether this
occurred during the June 10 dayshift is unclear, and
Goodyear was unable to produce a signed copy of
the work order.

continued on page 3

Heat exchanger explosion caused by blocked relief valve

(Goodyear 2008)

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Chemical Emergency Prevention & Planning Newsletter

March - April 2012

continued from Page 2

Over-pressure Protection: Heat exchanger rupture and ammonia release

Pressure Vessel Over-pressure Protection

A rupture disk and a pressure relief valve in series
protected the ammonia heat exchanger from over-
pressure. An isolation valve installed between
the rupture disk and the heat exchanger isolated
the rupture disk and relief valve for maintenance.
However, when the valve was in the closed
position, the heat exchanger was still protected
from an over-pressure condition by the automatic
pressure control valve.

The next day, when operators began a separate
task to steam clean the process piping they closed
a block valve between the heat exchanger and
the automatic pressure control valve. This isolated
the ammonia side of the heat exchanger from all
means of over-pressure protection. Steam flowing
through the heat exchanger increased the ammonia
temperature and the pressure in the isolated
heat exchanger. Because the over-pressure
protection remained isolated, the internal pressure
increased until the heat exchanger suddenly and
catastrophically ruptured.

Pressure Vessel Standards

The American Society of Mechanical Engineers
Boiler and Pressure Vessel Code, Section VIII (the
ASME Code), provides rules for pressure vessel
design, use, and maintenance, including over-
pressure protection. Use of the ASME Code was
required at Goodyear by OSHA's 29 GFR 1910.119
Process Safety Management Standard.

The ASME Code requires that when a pressure
vessel relief device is temporarily blocked and
there is a possibility of vessel pressurization above
the design limit, a worker capable of releasing the
pressure must continuously monitor the vessel.
Goodyear's maintenance procedures did not
address over-pressurization by the ammonia
when the relief line was blocked, nor did it require
maintenance and operations staff to post a worker
at the vessel to open the isolation valve if the
pressure increased above the operating limit.

Lessons Learned

Maintenance Completion

Although maintenance workers had replaced
the rupture disk by about 4:30 p.m. on June
10, the primary over-pressure protection for the
heat exchanger remained isolated until the heat
exchanger ruptured at about 7:30 a.m. on June 11.

Communicating plant conditions between
maintenance and operations personnel is critical
to the safe operation of a process plant. Good
practice includes formal written turnover documents
that inform maintenance personnel when a process
is ready for maintenance and operations personnel
when maintenance is completed and the process
can be safely restored to operation.

Isolating Pressure Vessels

Goodyear employees completely isolated an
ammonia heat exchanger, including the over-
pressure protection, while steaming a process
line through the heat exchanger. Workers left
the pressure relief line isolated for many hours
following completion of the maintenance.

In accordance with the ASME Boiler and Pressure
Vessel Code, over-pressure protection shall be
continuously provided on pressure vessels installed
in process systems whenever there is a possibility
that the vessel can be over-pressurized by any
pressure source, including external mechanical
pressurization, external heating, chemical reaction,
and liquid-to-vapor expansion. Workers should
continuously monitor an isolated pressure relief
system throughout the course of a repair and
reopen blocked valves immediately after the work is
completed.

To read the complete report: CSB Case Study

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Chemical Emergency Prevention & Planning Newsletter

March - April 2012

Common Mistakes Made in Pressure Relief Valve (PRY) Installation

One of the most commonly
used safety related pieces of
equipment used for controlling
over pressurization in chemical
plant operation is the PRV. PRVs
protect process equipment by safely
releasing process fluids/gases.

PRVs are installed on pressure
vessels or high pressure piping.
They serve as over-pressure
protection devices. However, if
installed improperly, PRVs will
not protect equipment from over
pressurization. Improper installation
of PRVs could endanger plant
equipment as well as compromise
worker safety. Below, are

common installation mistakes that

compromise PRV operation:

•	Safety valve is not
mounted vertically

•	Block valves are installed
at the upstream and or
downstream of safety valve

•	The inlet pipe size is
smaller than connection
size of the safety valve

•	A cap or plug is installed
at the vent line

•	The diameter of outlet
pipe is smaller than the
safety valve outlet

The discharge outlet is not located
at safe distance* that could harm
workers' safety and health. The
vent discharge should also be
considered to be far enough from
ignition source if the discharging
material is combustible or
flammable.

*ANSI/IIAR 2-1999 Section 7.3
Pressure Relief Piping: Distance
from window, ventilation intake or
personnel exit shall be 20 ft or more
(7.3.2). Distance shall be not less
than 15 ft. above adjacent grade or
roof level (7.3.3).

Is Your Emergency and Hazardous
Chemical Inventory Report (Tier
Two) Late?

Facilities covered by Emergency Planning and
Community Right-to-Know Act (EPORA) requirements
must submit an Emergency and Hazardous Chemical
Inventory Form to the Local Emergency Planning
Committee (LEPC), the State Emergency Response
Commission (SERC), and the local fire department
annually on March 1. Facilities provide either a Tier I or
Tier II form. Most States require the Tier II form. Some
states have specific requirements in addition to the
federal Tier II requirements. Many accept Tier2 Submit,
an electronic reporting program.

State reporting requirements are available at Tier2
Submit.

The quantities of materials that trigger reporting are 500 pounds or the listed threshold planning quantity, whichever is
less, for extremely hazardous substances like ammonia and 10,000 for most other substances like diesel fuel. The list
of extremely hazardous substances and their threshold planning quantities can be found on the "List of Lists".

Penalties for failing to report under Section 312 of EPCRA can be up to $37,500 per day per violation. If you discover
that you should have been reporting under this regulation, EPA's self audit policy can help you come into compliance.

On January 26, EPA released a press release on an EPCRA penalty by Oregon Potato for its Warden, Washington
facility. The penalty included failure to report on Tier Two under Section 312 of EPCRA and failure to immediately
report releases under Section 304 of EPCRA and Section 103 of CERCLA.

For more information on these requirements, contact Suzanne Powers, (360) 753-9475.

Facility Ideritifi cation

Tier Two

EMERGENCY
AND

HAZARDOUS

Owner/Operator N;

Emergency Contact

24 Hr. Phore i )

Important: Read ali instructions before completing form I RepO"ti1C FeriOd FrOTI Januaiy 1 to December 3'. 2C _

Chemical Description

Physical
and Health
Hazards

Ciec* all that apply)

C ertlfi c at I on (Real and sign after compk/mg cJJstc

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Chemical Emergency Prevention & Planning Newsletter

March - April 2012

Packer agrees to pay EPA fine

Updated: January 12, 2012

WENATGHEE, Wash. -- Custom Apple Packers Inc. of
Wenatchee has agreed to pay a $69,480 penalty to the federal
Environmental Protection Agency for failing to submit a risk
management plan for anhydrous ammonia.

The company had a plan for the chemical but failed to submit it
to the EPA for the time period of Aug. 1, 2002 to April 1, 2009,
said Javier Morales, EPA Northwest regional risk management
plan coordinator for the Glean Air Act.

Submittal of the plan is important so that the public knows the
company has a plan and so that local emergency responders
know the quantity and type of chemical and facility capabilities
and coordination in the event of a leak, Morales said.

Custom said it was unaware it needed to submit the plan to
the EPA, Morales said.

i O %.

w

%-PRO^

Plan to attend the FREE EPA Risk
Management Training Day in your

area

RISK MANAGEMENT PROGRAM
(RMP) Training

Quincy, Washington:

April 24, 2012

Portland, Oregon:

Fall, 2012

Find details on: EPA Region 10's RMP website - Quincy Training

Where Do I Go For More Information?

http://www.epa.gov/emergencies/rmp will be
updated as new information becomes available.

EPA maintains numerous listservs to keep the
public, state and local officials, and industry
up to date, including several that pertain to
emergency management. You can sign up for
our list serve to receive periodic updates:
https://lists.epa.gov/read/all forums/
subscribe?name=callcenter_oswer

EPA Region 10 RMP Coordinator:

Javier Morales 206-553-1255

EPA Region 10 RMP Website:
http://yosemite.epa.gov/R10/
CLEANUP.NSF/sites/rmp

Superfund, TRI, EPCRA, RMP & Oil Information

Center - The Information Center can also
answer questions related to Clean Air Act section
112(r) and RMP reporting requirements.
(800) 424-9346 or TDD (800) 553-7672
(703) 412-9810 or TDD (703) 412-
3323 in the Washington, D.C. area
Normal Hours of Operation:

Monday - Thursday 10:00 a.m. -
3:00 p.m. Eastern Time
Extended Hours of Operation (May, June, and July):
Monday - Friday 9:00 a.m. - 5:00 p.m. Eastern Time

Closed Federal Holidays
http://www.epa.gov/superfund/contacts/infocenter/

Risk Management Program (RMP) Reporting

Center - The Reporting Center can answer
questions about software or installation problems.
The RMP Reporting Center is available from 8:00

a.m. to 4:30 p.m., Monday through Friday, for
questions on the Risk Management Plan program.
(703) 227-7650 (phone)
RMPRC@epa.cdx.net (e-mail)

This newsletter provides information on the EPA
Risk Management Program, EPCRA, SPCC/FRP
and other issues relating to Accidental Release
Prevention Requirements. The articles contained
herein are provided for general purposes only.
EPA does not accept responsibility for any errors
or omissions or results of any actions based upon
this information. Please consult the applicable

regulations when determining compliance.
Mention of trade names, products, or services
does not convey, and should not be interpreted as
conveying official EPA approval, endorsement, or
recommendation. The information should be used
as a reference tool, not as a definitive source of
compliance information. Compliance regulations are
published in 40 CFR Part 68 for CAA section 112(r)
Risk Management Program, 40 CFR Part 355/370
for EPCRA, and 40 CFR Part 112.2 for SPCC/FRP.

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