Poole Chemical - Texline, TX - Executive Summary

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Poole Chemical - Texline, TX 
Executive Summary - Anhydrous Ammonia 
Accidental Release Prevention and Emergency Response Policies: 
This facility complies with the ANSI K 61.1 "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. 
This location is required to conduct its 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. 
This location has a "site safety coordinator".  The coordinator is given training to monitor the day to day safe work activities, maintain the required regulatory record keeping, conduct regular safety meetings and conduct employee training.  The site safety coordinator acts as the location's emergency contact. 
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 fertilizers including anhydrous ammonia.  Anhydrous ammonia is received by truck and/or rail, is handled and stored  on-site, and is a substance regulated by the EPA requiring us to comply with the Risk Management Program.  We sell anhydrous ammonia to grower customers. The customer applies the ammonia into the soil as a source of nitrogen fertilizer for growing agricultural crops.  Ammonia is also used for blending into mixed grade fertilizers for crop production nutrients. 
The facility maintains approximately 76 1,000 gallon nurse tanks for customer delivery. Our combined storage capacity in nurse tanks is 357,200 pounds. Anhydrous ammonia is stored in 2 stationary storage tanks: B @ 30,000 gallons; and,  C @ 12,000 gallons on site.  The maximum storage capacity of the stationary storage tanks is 196,000 pounds of anhydrous ammonia. In addition, anhydrous ammonia may be stored temporarily in a rail car.  The maximum quantity of anhy 
drous ammonia that may be stored in a rail car is 160,000 pounds.  Therefore, the total facility anhydrous ammonia storage capacity is 713,200 pounds.  The largest single vessel at our facility contains 160,000 pounds. 
Worst Case Scenario: 
Our worst case scenario is the loss of the total contents of the rail car, when filled to the greatest amount allowed (85% of capacity), released as a gas over 10 minutes, resulting in total vaporization.  The maximum quantity released would be 160,000 pounds.  According to DEGADIS modeling, this release (distance from point of dispersion to 200 ppm) would have off-site impact.  It should be noted that the industry has never had a release of an entire stationary anhydrous ammonia storage tank from any distribution facility. 
Alternative Release Scenario: 
The most common alternative release scenario from our facility would not reach an end point off-site.  The alternative release scenario modeled for the purpose of this plan is a 2-minute release 
from a rail car representing a valve and hose failure requiring a manual shut down.  The total amount of anhydrous ammonia released in this scenario would be 27,000 pounds.  This release scenario (distance from point of dispersion to 200 ppm) would have off-site impact.  It should be noted that Poole Chemical has not had a release of this type from any distribution facility. 
General Accidental Release Prevention Program and Chemical-Specific Prevention Steps: 
The anhydrous ammonia system is designed, installed and maintained in accordance with ASTM standards and ASME codes.  This facility complies with the ANSI K 61.1 standards, OSHA (29 CFR 1910.111), EPA's Accidental Release Prevention Rule, and all applicable federal, state and local codes and regulations. 
Our ammonia system is protected from major releases by internal excess flow valves, relief valves, and manual shutoffs.  The load-out risers used fo the purpose of filling the nurse tanks are protected by excess flow valves t 
o immediately stop the flow of ammonia if a line or hose fails.  All main storage tank valves and riser 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 according to the guidelines in the ANSI standards. 
Training is provided to all employees, dealing with a process, 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. 
Five-year Accident History: 
There have been no accidents involving anhydrous ammonia that caused deaths, injuries, property or environmental damage, including evacuations on or off-site, as defined by the RMP regulation. 
Emergency Response Program: 
In the event of an emerge 
ncy 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 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 prepared under EPCRA and coordinated with our LEPC. 
In addition, Poole Chemical Co. Inc. has an Emergency Response and Contingency Plan for this facility that complies with the requirements of OSHA (29 CFR 1910.38 and 1910.1200). 
The plan includes provisions for public notification, 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 will continue to provide our employees with ongoing annual training to ensure that they are current with safe ammonia transfer and handling procedures.  We will also provide regular inspection and maintenance on all of the ammonia equipment.
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