A sign of the times for the USA and our HAZMAT Facility Siting?

haifa NH3 ref tank

haifa NH3 ref tankThis anhydrous ammonia (NH3) refrigerated storage tank (photo source: Jerusalem Post) was feared to be a target of terrorist and as one report claimed, imminent failure.  The battle heated up in 2013 when “Hezbollah” (a recognized terrorist group) threatened to blow up the tank (or the ship delivering the NH3) with missiles and the courts got involved.  It seems the tank was built without the proper HAZMAT and business permit(s) and this was why the court (legally) decided that the tank was to be removed from service.  On a political note, it seems the Isreali government actually owns the plant/tank and Haifa Chemicals just operates it.  So this was a battle between the Israeli and Haifa governments with a company stuck in the middle?!?!?  Now the company says without their key raw material (NH3), they are shutting down the south plant and laying off 400+ workers (NOTE: some reports are that Haifia has decided to close BOTH the north and south plants and layoff over 800+ workers).  But wait, the Haifa Labor Court ordered the dismissal of employees the be suspended until the end of September! The plant has not been able to operate since March (2017) and reportedly kept its workforce employed in the hopes that some kind of deal could be reached that would allow the plant to continue operations.  The company claims it is has lost hundreds of millions of shekels (1 shekel = $0.28 USD) over this time period.  Is the USA ready for this level of “facility siting”?

Now the company is talking about using smaller ships carrying ammonia ISO containers that would dock in a port, and then the ammonia is shipped over the road(s) by truck to the plant or use a pipeline to supply NH3; however, from what I can tell from news reports, Haifa municipality officials are against BOTH plans.  With no means to receive their primary raw material, the company has announced it is shutting down.

The company had been exploring alternative plans to save the plants (both the North and South plants). In 2013, the Isreali government (not Haifa) decided to shut down the ammonia tank in Haifa Bay by this year and to set up a new production plant in the Negev (a desert in southern Israel). The Isreali government also committed to ensuring a continuous supply of NH3 until this new plant was up and running in Negev.  A plan for the new plant failed last year (2016) due to a “lack of bidders”.  “Lack of bidders” seems really odd; either politically or security reasons???

The proverbial cherry on top of this mess is a report that was produced for the Haifa municipality by a local chemistry professor (can’t find where he/she is a professor) who has data showing the 31-year-old tank is suffering from its age.  His report is said to have identified four (4) problem areas on the tank and claims the tank could fail on its own (no attack necessary) and this would result in 16,000 fatalities.  The report has said to have been released to the public but I have been able to find it to learn more about its contents and data sources.  His report also supposedly states that the “delivery ship” containing 16,000 tons (176,000,000 pounds) of NH3 would even be a more severe “worse case scenario” killing 600,000 people.  The ship is said to have five individual compartments, and if all five (5) were ruptured, the resulting release “would cover the entire Haifa area with a deadly hot ammonia gas for some eight hours, suffocating to death anyone caught without special breathing equipment“.  

I have tried to gather the necessary info so that I could use our USA based methodologies to determine if this report is factual.  I used EPA’s RMP*Comp modeling software to establish a distance of >25 miles for the WCS involving the refrigerated storage tank.  However, I do not know if the tank is “diked” or the capacity or the dimensions of the dike and this will have an impact on the distance as this is a “refrigerated liquid”.  I also have no idea as to the population density around the plant, but from aerial views of the area I would say it is high!  Not sure if it is 600,000 deaths “high”, but it appears to be heavily populated.  Somes news reports claim the report states “the tank could fall apart tomorrow morning” and just an FYI, this is usually a sign that the report may be a tad slanted in favor of the tank removal.  As I said, without having read a copy of this report and seeing the data and its sources, I have no idea as to the validity of this statement.  I do have a lot of experience working with large capacity NH3 refrigerated storage tanks and a 31-year-old tank would not be one I would expect to “fall apart” unexpectedly.  

In closing, there are probably several hundred of these large capacity NH3 refrigerated storage tanks in operation in the USA.  The ones I have worked with are NOT in any heavily populated areas, but they can impact populations as shown by their WCS.  And yes they do fail from time to time, as happened last year in Bangladesh (SAFTENG Members) and yes I am well aware that Bangladesh is not in the USA.  See pic below showing the aftermath of a 500-ton (i.e. about 1/25th the size of the Haifa tank); SAFTENG members can click on the link above to see more pics and read what happened.

fertiliser factory blast2

 

The question I pose… is this what we can expect in the USA when it comes to using a facility’s RMP Worst-Case Release scenarios against the business?  And we wonder by “industry” had issues with EPA’s amendments to its Risk Management Plan rule and the “public information” aspects.  The USA is not to the point of Haifa type battles just yet, but in my professional opinion, I can see a business fighting this fight in the next 10 years and for all I know there may be a battle already underway albeit quietly at this point.  In some regards, we are seeing something similar occurring in California with the use of Hydrofluoric Acid at refineries.  These refineries, when built decades ago were “off in the distance” and now the community has built up around them and some of their operations pose off-site consequences.  But this leads to the question… which came first – the chicken or the egg (i.e. the refinery or the community).  And if the refinery was there first, who is at fault for developing a “housing community” in such proximity?  

Most of our situations with worst case scenarios impacting hundreds of thousands of people stem from “ignorance” in zoning and planning within our communities.  Anyone who does a lot of RMPs and RMP Audits can attest to the fact that there are times that NOTHING within the facility has changed that would require a “correction” or “re-submittal” of their RMP; however, there are times that something in the community changes and thus the facilities Off-Site Consequence Analysis (OCA) can drastically change in it’s five-year window.  I can clearly remember four (4) clients (and there is probably more) in the past 5 years who when we did their initial RMP submittal the WCS population reported was less than 100, as the facility was built out and away from the population.  However, in our 5-year review we came to discover several housing communities, both subdivisions and apartment complexes, built not just in their WCS distances but in some cases within the shadow of these facilities.  Note this is occurring in 2012-today, so it seems we, as a society, still have not grasped the concept of zoning and planning.  For some of these facilities, the complaints have already begun with noise complaints and odor complaints.  It is just a matter of time until someone learns of their WCS and files a lawsuit.

So the Haifa battle is just an indicator of what is to come for the chemical industry in the USA!  And Hurricane Harvey, although not responsible for any WCS, will be the energy to start this ball rolling.  I have come to the personal opinion after watching the politicians who “permit” these new jobs and then turn around and zone property in the shadow of these facilities for homes.  It seems companies can’t win this battle as it is driven by politics rather than science and that folks is how we got into this mess!

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