Woodworth, Inc. - Executive Summary |
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1. Accidental release prevention and emergency response policies It is the policy of the facility to adhere to federal, state, and local rules and regulations. The facility complies with the OSHA requirements for the handling of anhydrous ammonia and the OSHA process management standard. The facility engages its employees in ongoing training about their responsibilities in implementing compliance programs. If an emergency should occur it is our policy to notify the Detroit Fire Department and request that they respond to the emergency. 2. The stationary source and regulated substance handled The facility heat treats steel. Heat treating introduces anhydrous ammonia into controlled ovens that contain the metal parts to be treated. The facility stores anhydrous ammonia in a bulk tank. 3. The worst-case release scenario and the alternative release scenario including administrative controls and mitigation measures The facility's worst-case scenario is the release of the contents o f the tank when filled to the maximum allowed under written administrative controls (approximately 34,000 lbs of ammonia; approximately 6,800 gallons). According to EPA's look up tables the maximum distance to the endpoint is 2.2 miles. The alternative release scenario is a release through a transfer line that connects the tank with the transfer hose of the anhydrous ammonia delivery truck that loads the tank. In this scenario, the liquid contained in the transfer line empties out, and the check valve closes, limiting the loss to the contents of the line (approximately 75 pounds). The attendent will then close the main loading valve at the tank. According to EPA's look up tables the maximum distance to the endpoint is 0.1 miles. 4. The general accidental release prevention program and chemical-specific prevention steps The facility complies with the USEPA's accidental release prevention rule and with applicable state and local codes and regulations. The anhydrous ammonia tank has been designed, installed and maintained in accordance with ANSI standards and state and local law. Facility personnel have been trained in accordance with safe handling procedures developed by Tanner Industries, the supplier of both the tank and the anhydrous ammonia to the facility. Handling of the material by by the facility does not occur until after the delivery truck has backed up to the transfer loading pipe, the transfer hose has been attached by the delivery truck operators, inspection by the both truck and facility operators has occured, and the load has been accepted by the facility. Delivery truck operators are trained by the supplier. Transfer operations (and later transferring to heat treat processes) are monitored and follow a written standard operating procedure (SOP). 5. Five-year accident history We have not had an accident involving anhydrous ammonia that caused deaths, injuries, property or environmental damage, evacuations or sheltering in place. 6. The emer gency response program In the event of an emergency, it is our policy to notify the Detroit Fire Depratment and request that they respond to the emergency. We have discussed this policy with the fire deprtment; the Fire Marshall has inspected our tank. 7. Planned changes to improve safety The facility trains its personnel on a regular basis. Safety training is modified based upon revised federal, state and local rules and regulations. The safety of plant systems is upgraded continuously as new equipment is installed. |