S & M Fertilizer & Seed Co., Inc. - Executive Summary

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The United States Environmental Protection Agency (USEPA) developed the Risk 
Management Program (RMP) rule (40 CFR 68) to assist facilities in preventing 
accidental releases of highly toxic or flammable chemicals.  The RMP established  
three levels of requirements for the program.  Programs 1 and 2 are for facilities that 
pose less risk to the environment and therefore have reduced compliance 
requirements.  Program 1 is designed for "no impact" facilities and has the fewest 
requirements, while Program 3 is the most stringent of the three levels. 
The program level for each facility is determined by: 
      Use of regulated substances in threshold quantity 
      Impact of an off-site public receptor (e.g., residence, school, park) 
      Standard Industrial Classification (SIC) code 
      Five-year accident history 
      OHSA PSM (29 CFR 1910.119) applicability.  
This facility is regulated under Program 2 requirements under 40 CFR 68.10 because: 
      It stores anhydrous ammonia in excess of the threshold quantity 
      A release from this facility could impact an offsite public receptor (residence) 
      It does not operate under a SIC code specified in the rule 
      It has not had a reportable accident in the past five years 
      It is not subject to OSHA PSM (this is a retail facility). 
40 CFR Part 68 Subpart G applies to an owner or operator of a stationary 
source that has more than a threshold quantity of a regulated substance in a process, 
as determined under 40 CFR 68.115.  S & M Fertilizer stores more than the threshold quantity 
of anhydrous ammonia (10,000 pounds) for commercial sale as fertilizer.   Therefore, 
S & M Fertilizer is required to submit a Risk Management Plan (RMP) as defined in 
40 CFR 68.150 by June 20, 1999. 
The S & M Fertilizer & Seed Co., Inc. is committed to operating in a safe and compliant manner.  
Employees involved in operating the ammonia storage and transfer facility are throughl 
y trained 
to identify and understand the hazards posed by this the transfer process.  Process safety and 
emergency response materials are kept on site and periodically reviewed.  Information includes 
information pertaining to the hazards of ammonia, process technology, process equipment, and 
emergency response procedures. 
The stationary source is the S & M Fertilizer anhydrous ammonia storage and transfer facility.  
The facility has a stationary storage tank with capacity of 30,000 water gallons 
(145,000 pounds).  The facility also stores numerous smaller transportable tanks (nurse tanks) 
that are actually used in the fertilizer application process.         
The facility is required to complete one worst-case release scenario per 40 CFR 68.165(a)(2) to 
determine program applicability.  S & M Fertilizer has chosen to use the DEGADIS+ 
to determine offsite impacts. 
Worst-Case Scenario Parameters 
    1.   Land Use - Rural 
    2.   Release Qty - 125,000 lb  
    3.   Release Rate - 12 
,500 lb/min 
    4.   Release Duration - 10 min 
For this facility, a worst-case release would occur in the event that a primary ammonia tank 
would rupture and the entire contents would be released to the atmosphere in 10 minutes.  The 
worst-case scenario requires a ground-level release height (0 feet).  Release calculations are 
presented below: 
Sample Endpoint Calculation 
    Given:    Largest Tank Capacity is 26,000 water gallons 
              Liquid Ammonia Density = 5.67 lb/gal (www.nh3.com) 
              Maximum Fill Volume = 85% capacity (Administrative Limit)  
    Release Rate   = Tank Capacity / 10 minutes 
                   = (26,000 gal * 5.67 lb/gal)*(0.85)  / 10 min  
                   = (147,420 lb)*(0.85) / 10 min 
                   = 125,000 (rounded) / 10 min 
                   = 12,500 lb/min  
Input of the preceding data into DEGADIS+ Comp program, the results indicate a worst-case 
impact of 2.2 miles for the facility.  The rule defines  
the toxic endpoint of anhydrous ammonia to 
be 0.14 mg/L.  The residential population within a 2.2 mile radius of the facility is 600 (rounded) 
based on the 1990 US Census data (average population density is 41 people per square mile, 
worst-case area of influence is 15 square miles).   
The facility is required to complete one alternate release scenario per 40 CFR Part 68.165(a)(2).  
The alternative release scenario considered is in accordance with the guidelines provided in 40 
CFR 68.22 and 68.28.  Alternative release parameters are presented below: 
Alternative Scenario Parameters                 
   1.   Land Use - Rural                  
   2.   Release Qty - 600 lb            
   3.   Release Rate - 60 lb/min  
   4.   Release Duration - 10 min 
The alternative scenario chosen for this facility involves a release because of a 
sudden split in the hose during transfer.  While this scenario is still unlikely because 
the transfer hoses used have multiple lay 
ers of rubber and a layer of braided stainless 
steel wire underneath the outer sheath (to prevent abrasions, cuts, and splits) it is 
more likely than the worst-case as required by 40 CFR 68.28(b)(i).  This scenario is also the 
most likely to occur, since overfilling is prevented by a return vapor line to the tank 
truck making the delivery.  The transfer hose rupture area is assumed at 0.5 square 
inches.  Because personnel are always present at the facility during transfer, S & M Fertilizer 
personnel will respond within 10 minutes.  Release rate was calculated using  
the OCAG tank release equation (Section 8.1.1).              
Input of the preceding data into DAGADIS+ revealed an alternative release scenario impact  
of 0.23 miles for the facility. Since there are residences approximately 0.23  
miles from the facility, this alternative release scenario satisfies the conditions  
of 68.28.  The population impact from the alternative release scenario is estimated  
at 7 people (from 
1990 census data).      
The facility maintains written process safety information to enable employees involved in 
handling ammonia to identify and understand the hazards posed by this process.  Written 
information includes physical properties of ammonia, health risks associated with ammonia 
exposure, and material safety data sheets.  In addition, the facility has conducted and/or 
implemented the following: 
            hazards review 
            standard operating procedures 
            training program 
            maintenance program 
            compliance audits 
            incident investigation      
The S & M Fertilizer anhydrous ammonia has had no recordable accidents within the 
past five years.          
Recommendations for safety improvements were identified in the hazard review 
which was completed February 5, 1999.  Recommendations were identified for 
two categories: Standard Operating Procedures, and Training.  Safety improvements 
will be investigated 
concerning their impacts on other systems and/or procedures 
prior to implementation.  Additional recommendations may be made upon review of 
any accidents and/or when the hazard review  is updated every five years.
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