The Facility is a nitrogenous fertilizer manufacturing facility that produces anhydrous ammonia, urea solutions, urea-ammonium nitrate, and by-product gaseous carbon dioxide. The Facility also produces intermediates (including nitric acid and ammonium nitrate solution) during the manufacture of the above products. Based on the quantity of anhydrous ammonia present at the Facility, the Facility is subject to the following requirements of the general duty clause:
a. Identify hazards which may result from accidental releases using appropriate hazard assessment techniques;
b. Design and maintain a safe facility taking such steps as are necessary to prevent releases; and
c. Minimize the consequences of accidental releases which do occur.
This release was determined, by the facility’s investigation, to have been caused by “a failure to follow Operating Procedure XXXXXXX.”