U. S. Agri-Chemicals, Bartow Plant - Executive Summary |
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Accidental release prevention policy: U.S. Agri-Chemicals personnel are committed to being responsible corporate citizens of the communities in which they live and work. The protection of the environment and the control of environmental matters receive top priority, support, and participation by all employees. Emergency response policy: U. S. Agri-Chemicals is committed to training and equipping it's personnel to handle incidental releases of ammonia and expects it's personnel to summon appropriate professional services to handle any incident that escalates beyond their capability. Description of the stationary source and regulated substance handled: Bartow Chemical Plant produces ammonium phosphate fertilizer. Ammonia is received by truck, pipeline, or railcar and is stored in vessels called bullets. Ammonia is combined with phosphoric acid to produce ammonium phosphate fertilizer. Accidental release prevention program: U. S. Agri-Chemicals' prevention program includes : - requirement to ensure covered process equipment are properly designed with emergency shutoff. - training of maintenance personnel and testing of critical covered process equipment. - written operating procdures and training of operators. - safety inspections, reviews, and audits of covered process equipment. Five-year accident history: On July 14, 1994, a valve was left closed during an ammonia pipeline transfer, and when the supplier commenced transfer, the transmission line over-pressurized the supply line. A relief valve popped to relieve the over-pressure allowing approximately 7,000 pounds of ammonia to escape. To prevent re-occurrence, a high pressure alarm system was installed, and an ammonia transfer check-off list was developed as a preventive measure. Emergency response program: U. S. Agri-Chemicals' emergency response program includes : - written emergency response plan. - joint emergency response excercises conducted with communit y responders. - availability of emergency response equipment. Description of worst-case release scenario: Release of entire contents of 225 ton ammonia bullet (80% full = 360,000 pounds) over a period of 10 minutes. The distance to end-point based on Degadose air dispersion modeling is 1.8 miles. Description of alternative release scenario: Vent release of 7,000 pounds of ammonia in 8 minutes as occured in July 1994. The distance to end-point based on Degadose air dispersion modeling is 0.43 miles. EPA has acknowledged that there are inherent uncertainties associated with the use of any air dispersion model. EPA also has acknowledged that consistent with sound modeling practices and the requirements specified in the rule, different models may be used as appropriate. Therefore, U. S. Agri-Chemicals elected to use a model different than the one used by EPA to generate the look-up table. |