UPDATED 8/17/14
Routinely we hear the argument that Anhydrous Ammonia should not be on OSHA’s or EPA’s chemical lists for PSM/RMP inclusion. Like most industries that use a single highly hazardous chemical as a “utility” in their process(es) v.s. manufacturing the HHC or using the HHC in the manufacturing process, these industries feel “their chemical” is “safe” and no one should have any concerns. So a client recently challenged me to find any data that would justify a heightened level of concern for a process containing anhydrous ammonia. Unfortunately, it took me only five minutes to win the bet and now the client clearly understands my “radical PSM views” towards his Anhydrous Ammonia. The data I used was…
from the RMP database at www.RTKNET.org. Using the 5-year accident histories currently on file I sorted by the “# of deaths” and below is the result. How many Anhydrous Ammonia processes can you identify below (I helped with this)? Here are the numbers, as of 8/17/2014:
- 67 RMPs have a 5-year accident history associated with them
- 20 of these accidents resulted in DEATHS
- 10 of the 20 FATAL accidents involved NH3 (50%)
| Facility Name | City | State | # of accidents | # of deaths | # of injuries | # evacuated | Property damage (dollars) |
|---|---|---|---|---|---|---|---|
| Tesoro Anacortes Refinery | Anacortes | WA | 1 | 7 | 0 | 0 | $21,000,000 |
| Delek Refining Ltd | Tyler | TX | 2 | 2 | 3 | 0 | $48,000,000 |
| CF Industries Sales, LLC – Pine Bend Terminal (AMMONIA) | Rosemount | MN | 1 | 2 | 0 | 0 | $0 |
| American Cold Storage (AMMONIA) | Louisville | KY | 2 | 2 | 3 | 0 | $1,000,000 |
| sgSolutions, LLC | West Terre Haute | IN | 1 | 2 | 4 | 0 | $6,700,000 |
| River Valley Cooperative Calamus NH3 (AMMONIA) | Calamus | IA | 1 | 1 | 2 | 0 | $7,500 |
| Baker Petrolite Corporation – Sand Springs | Sand Springs | OK | 1 | 1 | 0 | 0 | $0 |
| Tyson Prepared Foods – South Hutchinson, KS (AMMONIA) | South Hutchinson | KS | 1 | 1 | 2 | 0 | $0 |
| MACKEY BRANCH (AMMONIA) | MACKEY | IN | 1 | 1 | 3 | 0 | $600,000 |
| Cowtown Gas Plant | Cleburne | TX | 1 | 1 | 0 | 0 | $50,000 |
| OXEA Bishop LLC | Bishop | TX | 1 | 1 | 0 | 0 | $25,000 |
| Valero Memphis Refinery | Memphis | TN | 3 | 1 | 2 | 0 | $23,763,168 |
| Kraft Foods Global – Madison (AMMONIA) | Madison | WI | 1 | 1 | 1 | 0 | $0 |
| Mountaire Farms, Inc. (AMMONIA) | Lumber Bridge | NC | 1 | 1 | 3 | 0 | $0 |
| Valero St. Charles Refinery | Norco | LA | 1 | 1 | 1 | 0 | $0 |
| Tanner Industries, Inc. (AMMONIA) | Swansea | SC | 1 | 1 | 7 | 0 | $0 |
| Paynesville Farmers Union Coop Oil Co. (AMMONIA) | Paynesville | MN | 1 | 1 | 2 | 0 | $0 |
| Louisiana Pigment Company, L.P. | Westlake | LA | 6 | 1 | 8 | 441 | $234,765 |
| Blanchard Refining Company LLC – Galveston Bay Ref | Texas City | TX | 3 | 1 | 2 | 85,000 | $34,670,804 |
|
Goodyear Houston Chemical Plant (AMMONIA) |
Houston | TX | 1 | 1 | 7 | 0 | $1,300,000 |
Here are some more data and analysis using the National Toxic Substance Incidents Program (NTSIP) and Hazardous Substances Emergency Events Surveillance (HSEES) databases. These databases began in 1995 and the last year we have data compiled for is 2011; however, the database ONLY includes data from as few as seven (7) states and some years there was up to 13 states reporting. Participating States were required to report any release in which the amount of substance released—or that might have been released—was greater than 10 pounds or 1 gallon, or, for substances on the HSEES mandatory reporting list (which NH3 is on this list), the release of any amount.
In 2010 and 2011 the definition is “Any acute, uncontrolled, or illegal hazardous substance release that meets the established minimum reporting quantity”. With that said, I counted 6,224 releases of NH3 from 1995-2011 at fixed facilities.
This is nearly 6X’s that which was stated to have occurred in the allgov.com piece. So yes their data was IMPROPER, but in a very favorable manner for NH3.
It was asked about comparing NH3 to chlorine. From 1995-2011 there were 2,548 CL2 incidents from these databases using the same criteria used to obtain the NH3 release data.
Here are the numbers, as of 8/2/13
| Facility Name | City | State | # of accidents | # of deaths | # of injuries | # evacuated | Property damage (dollars) |
|---|---|---|---|---|---|---|---|
| Tesoro Anacortes Refinery | Anacortes | WA | 1 | 7 | 0 | 0 | $21,000,000 |
| Delek Refining Ltd | Tyler | TX | 2 | 2 | 3 | 0 | $48,000,000 |
| CF Industries Sales, LLC – Pine Bend Terminal (AMMONIA) | Rosemount | MN | 1 | 2 | 0 | 0 | $0 |
| American Cold Storage (AMMONIA) | Louisville | KY | 2 | 2 | 3 | 0 | $1,000,000 |
| sgSolutions, LLC | West Terre Haute | IN | 1 | 2 | 4 | 0 | $6,700,000 |
| River Valley Cooperative Calamus NH3 (AMMONIA) | Calamus | IA | 1 | 1 | 2 | 0 | $7,500 |
| Baker Petrolite Corporation – Sand Springs | Sand Springs | OK | 1 | 1 | 0 | 0 | $0 |
| Tyson Prepared Foods – South Hutchinson, KS (AMMONIA) | South Hutchinson | KS | 1 | 1 | 2 | 0 | $0 |
| MACKEY BRANCH (AMMONIA) | MACKEY | IN | 1 | 1 | 3 | 0 | $600,000 |
| Cowtown Gas Plant | Cleburne | TX | 1 | 1 | 0 | 0 | $50,000 |
| OXEA Bishop LLC | Bishop | TX | 1 | 1 | 0 | 0 | $25,000 |
| Valero Memphis Refinery | Memphis | TN | 3 | 1 | 2 | 0 | $23,763,168 |
| Kraft Foods Global – Madison (AMMONIA) | Madison | WI | 1 | 1 | 1 | 0 | $0 |
| Mountaire Farms, Inc. (AMMONIA) | Lumber Bridge | NC | 1 | 1 | 3 | 0 | $0 |
| Valero St. Charles Refinery | Norco | LA | 1 | 1 | 1 | 0 | $0 |
| Tanner Industries, Inc. (AMMONIA) | Swansea | SC | 1 | 1 | 7 | 0 | $0 |
| Paynesville Farmers Union Coop Oil Co. (AMMONIA) | Paynesville | MN | 1 | 1 | 2 | 0 | $0 |
| Louisiana Pigment Company, L.P. | Westlake | LA | 6 | 1 | 8 | 441 | $234,765 |
| Blanchard Refining Company LLC – Galveston Bay Ref | Texas City | TX | 3 | 1 | 2 | 85,000 | $34,670,804 |
| Goodyear Houston Chemical Plant | Houston | TX | 1 | 1 | 7 | 0 | $1,300,000 |
This is NOT picking on Ammonia or any industry that uses it, but the numbers do not lie. Ammonia has many useful properties and is VITAL to the US economy, but we have to RESPECT this hazardous material and stop minimizing its hazards. Just because we put it in the ground as fertilizer does not make it “natural” or “healthy”. Granted there are much more bad actors in the PSM/RMP world, but Ammonia has honestly earned it’s way onto the PSM/RMP Chemical listing, as noted in the table above. I am sure there will be some that will argue the numbers and claim I am skewing the data to pick on ammonia, which is why I pass on the challenge to challenge my numbers.
I am sure someone will make the argument that Ammonia is more widely used than any other PSM/RMP chemical and this is why the fatality numbers “appear to be bad”. Be careful playing these games! At first glance, the data shows Ammonia and Chlorine are the two most common processes, but when we add up all the flammable covered processes, we see that Ammonia is in 7,378 covered processes, Flammables are in 3,755 covered processes and chlorine is in 2,824 covered processes. And when it comes to quantity, “flammables” out do Ammonia 10 to 1. So when the challenge is made that the reason for the high rate of fatalities is that Ammonia is present in over 7,378 of the covered process, by far the most common process; it is not that far ahead flammable processes, representing 3,755 processes.
Bottom line, Ammonia needs to be on the list and in fact some of the data even begins to point to the need for a LOWER PSM/RMP Threshold, rather than removing the chemical from the lists!