Ramsdell F&M, Ltd - Executive Summary |
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EXECUTIVE SUMMARY ANHYDROUS AMMONIA THE ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES AT OUR FACILITY. This facility complies with the 1989 ANSI K6 1.1 "Safety Requirements for the Storage and Handling of Anhydrous Ammonia". In addition, it is our policy to adhere to all applicable federal, state, and local laws. Part of the mission of Ramsdell F&M, Ltd. is "To provide for the safety of our employees, our customers and the general public". In order to fulfill this mission, Ramsdell F&M is a member of Terra Industry's Safety, Health, and Environmental Programs (SHEP) and employees a Safety & Compliance Officer to maintain and administer comprehensive safety and environmental programs and procedures. Terra International EHS field safety services supervisors support and assist Ramsdell F&M, Ltd. in its safety program by providing training and updates to the the Safety and Environmental Manual. Our facility is required to conduct an internal audit utiliz ing checklist survey forms that are reviewed regularly and updated as necessary to ensure all applicable federal, state, and local regulations are covered. This audit process includes specific requirements for the safe handling and storage of anhydrous ammonia. In addition, the Safety & Compliance officer is trained to monitor the day to day safe work activities, maintain the required regulatory record keeping, conduct regular safety meetings, insure employees are trained and acts as the location's contact with the Terra International EHS group. A DESCRIPTION OF OUR FACILITY AND THE REGULATED SUBSTANCES HANDLED. This facility is a wholesale farm supply distribution center as such we store and distribute a wide variety of pesticides and fertilizers. 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 use anhydrous ammonia only on a seasonal basis in mixi ng our liquid fertilizer blends. Our facility does not retail or wholesale out anhydrous ammonia therefore we do not store or ship this product in nurse tanks. Anhydrous ammonia is stored in 2 stationary storage tank(s) [2 @ 5,985 gallons in water capacity] on site. The maximum storage capacity of stationary storage tanks is 52,300 pounds of anhydrous ammonia. Therefore, the total facility anhydrous ammonia storage capacity for our facility is 52,300 pounds. The largest single storage vessel at our facility contains 26,150 pounds. THE WORST CASE SCENARIO TOXICS - AMMONIA (Anhydrous) Our worst case scenario is the loss of the total contents of one 5,985 gallon storage tank; released as a gas over 10 minutes, resulting in total vaporization. The maximum quantity released would be 26,150 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 Ramsdell F&M, Ltd. has never had a release of a n entire stationary storage tank. ALTERNATIVE RELEASE SCENARIOS 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 pipe failure requiring a manual shut down should the excess flow valves not engage. 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 Ramsdell F&M, Ltd. has not had a release of this type from any distribution 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 (2 9 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. Load out risers used for the purpose of filling the nurse tanks are protected by excess flow valves. Hoses have been removed from the risers as our facility no longer distributes anhydrous in nurse tanks. 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 regu lations is questioned. The training 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 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, 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 . This complies with the requirement for our facility to be included in the community emergency response plan prepare d under EPCRA and coordinated with our LEPC. In addition, Ramsdell F&M, Ltd. an Emergency Response and Contingency Plan the 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 proper safe handling procedures for ammonia. Ammonia equipment is regularly inspected and maintained. The Terra International EHS staff review and update training and maintenance procedures routinely to ensure our facility meets or exceeds all applicable regulatory requirements and industry standards. |