Goodpasture, Inc. Cactus Location - Executive Summary

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             Risk Management Plan (RMP) - Ammonia 
                      Executive Summary 
              Goodpasture, Inc., Cactus Location 
                        Cactus, Texas 
 
 
 1. Accidental Release Prevention and Emergency Response Policies 
We at Goodpasture, Inc. in Cactus are strongly committed to employee, public, and environmental 
safety.  This commitment is an inherent part of our comprehensive accidental release prevention 
program that covers areas such as design, installation, operating procedures, maintenance, and 
employee training associated with the processes at our facility.  It is our policy to implement 
appropriate controls to prevent possible releases of regulated substances.  If such a release does 
occur, our trained emergency response personnel are at hand to control and mitigate the effects of 
the release.  We also coordinate our response efforts with the Cactus Fire Department, which 
provides add 
itional emergency response expertise. 
 
 2. Stationary Source and Regulated Substances Handled 
Our facility's primary activities include support services for crop production.  We have anhydrous 
ammonia stored in a 30,000-gallon tank at our facility in Cactus (Figure 1).  The maximum amount 
stored is 25,500 gallons (131,223 pounds) at the maximum fill capacity of 85%. 
 
 3. Worst Case Release and Alternative Release Scenarios 
We utilized RMP PRO for the worst case and alternate case scenarios of the required offsite 
consequence analysis for our facility.  The following details these scenarios. 
 
The worst case release scenario involves a catastrophic release of the entire contents of the  
anhydrous ammonia storage tank (131,223 pounds) in gaseous form over a 10-minute period.  At 
Class F atmospheric stability, 1.5 m/s wind speed, and urban topography, the maximum distance to 
a toxic endpoint of 0.14 mg/L is 5.2 miles (Figure 2).  The estimated population within a 5.2-mile 
radius of this  
facility is 2,500. 
 
The alternative release scenario involves a release from an anhydrous ammonia product line.  The 
scenario involves the release of 7,995.83 pounds of ammonia in a gaseous form over a period of 30 
minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 
mg/L of ammonia is 0.31 mile (Figure 3).  The estimated population within a 0.31-mile radius of the 
facility is 500. 
 
 4. General Accidental Release Prevention Program 
Our facility has taken all the necessary steps to comply with the EPA's accidental release prevention 
requirements as set forth in 40 CFR part 68.  The following sections briefly describe the elements 
of the release prevention program that is in place at our stationary source. 
 
 
Process Safety Information 
Goodpasture, Inc. maintains a detailed record of safety information that describes the chemical 
hazards, operating parameters, and equipment designs associated with all processes (Appendix D). 
 
Process Hazard Analy 
sis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are 
identified and controlled effectively.  Any findings from the hazard analysis are addressed in a 
timely manner. 
 
Operating Procedures 
Goodpasture, Inc. maintains written operating procedures to ensure that activities within our covered 
processes are conducted safely.  These procedures address various modes of operation; the 
information is regularly reviewed and is readily accessible to operators involved in the processes 
(Appendix B). 
 
Training 
Goodpasture, Inc. has a comprehensive training program in place to ensure that employees who are 
operating processes are competent in the operating procedures associated with these processes. 
 
Mechanical Integrity 
Goodpasture, Inc. conducts documented maintenance checks on process equipment to ensure proper 
operation.  Maintenance checks are conducted by qualified personnel with previous training in 
maintenance practices.  Examples of process 
equipment that would receive maintenance checks 
include:  pressure vessels, storage tanks, piping systems, relief and vent systems, emergency 
shutdown systems, controls, and pumps.  Any equipment deficiencies identified by the maintenance 
checks are corrected in a safe and timely manner (Appendix C). 
 
Management of Change 
Written procedures are in place at Goodpasture, Inc. to manage changes in process chemicals, 
technology, equipment, and procedures.  Process operators, maintenance personnel or other 
employees whose job tasks are affected by a modification in process conditions are promptly notified 
of the modification and offered training to deal with it. 
 
Pre-startup Reviews 
Goodpasture, Inc. routinely conducts pre-startup safety reviews related to new processes and 
modifications in established processes.  These reviews are conducted to confirm that construction, 
equipment, and operating and maintenance procedures are suitable for safe startup prior to placing 
equipment into operat 
ion. 
 
Compliance Audits 
Goodpasture, Inc. conducts compliance audits on a regular basis to determine whether the plan's 
provisions, set out under the 40 CFR part 68, are being implemented.  Any non-compliance issue 
discovered during the audit is promptly corrected. 
 
 
Employee Participation 
Goodpasture, Inc. truly believes that process safety management and accident prevention is a team 
effort.  Company employees are strongly encouraged to express their views concerning accident 
prevention issues and to recommend improvements.  In addition, our employees have access to all 
information created as part of the facility's implementation of the RMP, particularly information 
resulting from process hazard analyses. 
 
 5. Five-year Accident History 
Goodpasture, Inc. has had an excellent record of preventing accidental releases over the last 5 years.  
Due to our stringent release prevention policies, no accidental release has occurred during this 
period. 
 
 6. Emergency Response Plan 
Goodpasture 
, Inc. maintains a written emergency response plan to deal with accidental releases of 
hazardous materials.  The plan addresses all aspects of emergency response including first aid and 
medical treatment, evacuations, and notification of local emergency response agencies and the public 
(Appendix A).
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