TERRA INTERNATIONAL, INC. (EMMETSBURG, IA.) - Executive Summary |
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TERRA INTERNATIONAL, INC. - EMMETSBURG, IA CERTIFICATION STATEMENT FOR THE RMP PROGRAM 2 - ANHYDROUS AMMONIA AND PROPANE To the best of the undersigned's knowledge, information and belief formed after reasonable evaluation by actual knowledge of the facility and process, the information submitted is true, accurate, and complete. _________________________________ RICK REED Signature Print Name RMP Coordinator 3-10-99 Title Date EXECUTIVE SUMMARY - ANHYDROUS AMMONIA AND PROPANE THE ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES AT OUR FACILITY: This facility complies with the 1989 ANSI K61.1 "Safety Requirements for the Storage and Handling of Anhydrous Ammonia" and with NFPA #58 "The Liquefied Petroleum Gas Code" for the safe storage and handling of propane. In addition, it is our policy to adhere to all applicable federal, state, and local laws. Terra's Corporate Mission states "To provide for the safety of our employees, our customers and the general public". In order to fulfill this mission, Terra provides a corporate EHS group to maintain and administer comprehensive safety and environmental programs and procedures. EHS field safety services supervisors audit and monitor facility compliance with the safety standards of the company. All locations are required to conduct their own internal audit utilizing checklist survey forms that are reviewed regularly and updated as necessary to ensure all applicable federal, state, and local regulations are covered. The EHS group conducts comprehensive annual audits at every location to measure regulatory compliance. This audit process includes specific requirements for the safe handling and storage of anhydrous ammonia and propane. The field supervisors require a timely written response with the completion d ate of all recommendations resulting from the audits. In addition, each location has a "Site Safety Coordinator" as an extension of the EHS group. These coordinators are trained to monitor the day to day safe work activities, maintain the required regulatory record keeping, conduct monthly safety meetings, conduct employee training and act as the location's contact with the corporate EHS group. The site safety coordinators act as the location emergency contact. A DESCRIPTION OF OUR FACILITY AND THE REGULATED SUBSTANCES HANDLED: This facility is a wholesale farm supply distribution center. We store and distribute a wide variety of pesticides and fertilizers including anhydrous ammonia. The facility also sells liquefied petroleum gas (propane) to customers for home winter heating and to farms for grain drying and livestock heating needs. Anhydrous ammonia is received by truck, is handled and stored on-site and is a regulated toxic substance by the EPA requiring us to comply with the Risk Management Program. We sell anhydrous ammonia to grower customers in either 1,000 gallon, 1,450 gallon, or 2,000 gallon nurse tanks. The customer applies the ammonia into the soil as a source of nitrogen fertilizer for growing agricultural crops. This facility maintains approximately forty (40) 1,000-gallon nurse tanks, four (4) 2,000 gallon nurse tanks and seven (7) 1450-gallon nurse tanks for customer delivery. Our combined storage capacity in nurse tanks is 272,000 pounds. Anhydrous ammonia is stored in two 12,000 gallon stationary storage tanks on site. The maximum storage capacity of stationary storage tanks is 112,000 pounds of anhydrous ammonia. Therefore, the total facility anhydrous ammonia storage capacity for our facility is 384,000 pounds. The largest single storage vessel at our facility contains 56,000 pounds. Propane is received by truck, is handled and stored on-site. Propane is a regulated flammable substance by the EPA requiring us to comply with the R isk Management Program. Our storage consists of 30,000 gallon storage tank and associated appurtenances. The single storage vessel contains 110,000 pounds of propane. THE WORST CASE SCENARIO: TOXICS - AMMONIA Our worst case scenario is the loss of the total contents of the 12,000 gallon storage tank, released as a gas over 10 minutes, resulting in total vaporization. The maximum quantity released would be 56,000 pounds. According to DEGADIS modeling, this release (distance to point of dispersion to 200 PPM) would have off site impact. It should be noted that Terra has never had a release of an entire stationary storage tank from any distribution facility . FLAMMABLES - PROPANE Our worst case scenario would involve the loss of the entire contents of the 30,000 gallon propane tank, when filled to the greatest amount allowed (85% AT 60F), resulting in a vapor cloud explosion with a 1 psi end point. According to the modeling provided in the "Risk Management Program Guidance for Propan e Storage Facilities" October 1998, which uses EPA's Offsite Consequence Analysis, the release would have an off site impact. It should be noted that Terra has never had a release of an entire stationary storage tank from any distribution facility. ALTERNATIVE RELEASE SCENARIOS ALTERNATE RELEASE FOR TOXICS - AMMONIA The most common alternative release scenario(s) for ammonia from our facility would not reach an end-point off-site. The alternative release scenario modeled for the purposes of this plan is a 2-minute release from a stationary storage tank representing a valve and hose failure requiring a manual shut down. The total amount of anhydrous ammonia released in this scenario would be 12,000 pounds. This release scenario (distance to point of dispersion to 200 PPM) would have off site impact. It should be noted Terra has not had a release of this type from any distribution facility. ALTERNATE RELEASE FOR FLAMMABLES -PROPANE Our most common alternate release scenario(s) fro m our facility for propane would not reach an end point off site. The alternate release scenario modeled for this plan is a process pipe break. A two (2) inch pipe would release approximately 76,000 pounds over a total of ten minutes based on the model guidance. This release would have an off-site impact. It should be noted Terra has not had a release of this type from our facility. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS: AMMONIA The ammonia system is designed, installed and is maintained in accordance with ASTM standards and the ASME codes. This facility complies with the ANSI K 61.1 standards (1989), OSHA (29 CFR 1910.111), EPA's Accidental Release Prevention Rule as well as all applicable federal, state and local codes and regulations. Our ammonia system is protected from major releases by internal excess flow valves, check valves, relief valves, manual shutoffs and emergency shutoff valves. The load-out risers used for the pu rpose of filling the nurse tanks are protected by excess flow valves and fill line breakaways to immediately stop the flow of ammonia if a line or a hose fails. All main storage tank valves and riser load valves are locked when not in use. Our ammonia system is inspected on a regular basis with maintenance and preventive maintenance scheduled and documented. Liquid and vapor valves, hoses, excess flow valves, gauges, and relief valves are replaced when necessary and/or according to the guidelines in the ANSI standards. Training is provided to all employees at least annually, whenever there is a change in the process or whenever competency with the regulations is questioned. The training consists of classroom lecture, current videos, testing and certification and on the job training. PROPANE The propane system is designed, installed and is maintained in accordance with ASTM standards and the ASME codes. This facility complies with the NFPA #58 standards (1989), OSHA (29 CFR 1910.11 0), EPA's Accidental Release Prevention Rule as well as all applicable federal, state and local codes and regulations. Our propane system is protected from major releases by internal excess flow valves, check valves, relief valves, manual shutoffs and emergency shutoff valves. The load-out risers used for the purpose of filling vehicles are protected by excess flow valves and fill line breakaways to immediately stop the flow of propane if a line or a hose fails. All main storage tank valves and riser load valves are locked when not in use. Our propane system is inspected on a regular basis with maintenance and preventive maintenance scheduled and documented. Liquid and vapor valves, hoses, excess flow valves, gauges, and relief valves are replaced when necessary and/or according to the guidelines in the NFPA standards. Training is provided to all employees at least annually, whenever there is a change in the process or whenever competency with the regulations is questioned. The trai ning consists of classroom lecture, current videos, testing and certification and on the job training. FIVE-YEAR ACCIDENT HISTORY: There has been no accidents involving anhydrous ammonia or propane that caused deaths, injuries, property or environmental damage including evacuations on or off-site. THE EMERGENCY RESPONSE PROGRAM: In the event of an emergency involving our ammonia system or our propane system, it is our policy to notify the local community fire department and request that they respond to the emergency. In preparation for this, we have coordinated with all of the local response agencies by providing information and facility tours to ensure that they are familiar with and properly prepared for an incident at our facility. This will help to ensure that our community has the strategy for responding to and mitigating the threat posed by an ammonia release or propane explosion. This complies with the requirement for our facility to be included in the community emergency response plan prepared under EPCRA and coordinated with our LEPC. In addition, Terra has an Emergency Response and Contingency Plan for each facility that complies with the requirements of OSHA (29 CFR 1910.38 and 1910.1200). The plan includes public notification, provisions for initial medical care, evacuations and LEPC coordination. PLANNED CHANGES TO IMPROVE SAFETY: We do not plan to make any changes to the physical site. We provide our employees ongoing annual training to ensure that they are current with all of the proper transfer and safe handling procedures for ammonia and propane. Ammonia and propane equipment are regularly inspected and maintained. Our corporate EHS staff review and update training and maintenance procedures routinely to ensure our facility meets or exceeds all applicable regulatory requirements and industry standards. |