1. The Shepherd Chemical Company Lisa Thamann 11/12/2013 AMMONIUM NITRATE A New Understanding

2. OVERVIEW Background Original State Process Hazard Analysis Applicable Code Review Current State Lessons Learned NH 4 NO 3

3. BACKGROUND Schedule of PHAs conducted annually Ammonium Nitrate was not on the 2013 schedule West, TX incident on 4/17/2013 Address management and employee concerns

4. ORIGINAL STATE Main Raw Material Storage  Up to 60,000 lbs. of Ammonium Nitrate Prill  Secured Entry  Shared Storage Satellite Storage  Four locations in plant  Up to 2000 lbs.  Open piece bags  Limited Security

5. ORIGINAL STATE

6. PROCESS HAZARD ANALYSIS Systematic approach to assess the potential hazards of a process using a defined methodology Methodology: What If Analysis  Creative brainstorming methodology  Process is broken up into nodes  Nodes are organized around major pieces of process equipment or systems Rank each risk based on two parameters  Severity  Likelihood

7. PHA GOALS Identify potential hazards/risks and their impact on:  Health & Safety of personnel  Environment  Community  Regulatory Requirements Recommend actions to drive risk down Prioritize recommendations  Based on Risk Ranking Document safe operating limits

8. NON-TRADITIONAL PHA: Code Comparison NH 4 NO 3 Storage & Handling o Receiving o Bulk Storage o Distribution o Satellite Storage

9. APPLICABLE CODE REVIEW Applicable Codes: OSHA 1910.109(i): Storage of Ammonium Nitrate NFPA 400: Hazardous Materials Code  Chapters 1-6: General Definitions, Classifications & Requirements  Chapter 11: Ammonium Nitrate Solids & Liquids

10. APPLICABLE CODE REVIEW Maximum Allowable Quantity OSHA 1910.109(i): >1000 lbs. NFPA 400: Depends  Oxidizer Classification  Unstable Reactive Classification

11. NFPA CLASSIFICATIONS CLASSOXIDIZERUNSTABLE REACTIVE 1Does not moderately increase the burning rate of combustible materials Normally stable but could become unstable at elevated T & P 2Causes a moderate increase in burning rate of combustible materials Materials that readily undergo violent chemical change at elevated T & P 3Causes a severe increase in burning rate of combustible materials Materials that in themselves are capable of detonation, explosive decomposition or explosive reaction, but require a strong initiating source, heat & confinement before initiation 4Class 3 plus can undergo an explosive reaction from contamination or exposure to thermal/physical shock. Materials that in themselves are readily capable of detonation, explosive decomposition or explosive reaction at normal T & P

12. NFPA 400 MAQ Class 3 Oxidizer, Class 3 Unstable Reactive  10 lbs.  Protection Level: 2 MAQ can be increased to 550 lbs. if the following requirements are met:  < 200 lbs./ft 2  < 6 feet high  < 100 lbs. per container  Noncombustible floors  Incompatibles at least 30 feet away  Hazard identification per code  4 foot aisles If fire suppression meets NFPA 13 MAQ can be doubled to 1100 lbs.

13. COMMON REQUIREMENTS Storage approval from area of jurisdiction No basement One story building 30 feet from incompatible materials Adequate ventilation Automatic sprinklers system designed per NFPA 13 ≥ 1-hr fire resistive walls Noncombustible flooring < 130 ° F At least 3 foot aisles 30 inches from wall Can’t be stacked 3 feet from roof Dry and free of water intrusion Controlled access

14. OTHER NFPA 400 REQUIREMENTS Specific Training  Physical & Health Properties  Emergency Response  Storage  Transporting Labeling Egress Secondary Containment Spill Control Plan Security Plan

15. Detached Building Requirement Class 3 Unstable Reactive  1 ton or less on site 40,000- 60,000 lbs.  At least 2000 feet away from inhabited buildings for un- barricaded storage OR  At least 1300-1600 feet away from inhabited buildings for barricaded storage

16. PHA OUTCOME 38 Recommendations  Adequate storage location Upgrade storage facility to meet applicable codes Reduce MAQ  Incompatible materials  Improved training  Labeling  Security  Disposal  Hot work practices  Containment

17. TODAY Drastically reduced onsite storage to 4,400 lbs.  Worked with supplier to provide weekly deliveries A maximum of 1100 lbs. is kept in each control area Implemented rated storage cages with secondary containment Separated incompatibles Monthly reconciliation & tighter security Improved training & hazard communication Opportunities to use liquid ammonium nitrate

18. TODAY

19. LESSONS LEARNED NFPA provides an excellent resource to aid in code applicability Actual hazards of bulk ammonium nitrate storage Improve site-wide awareness of ammonium nitrate storage and incompatibilities OSHA vs. NFPA  Strive to implement best practices

20. LESSONS LEARNED The ability and necessity to act quickly to address high hazard concerns Shepherd Chemical’s commitment to the safety of our employees and the community