Waterloo Ag Center - Executive Summary |
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The Andersons Waterloo Wholesale & Retail RMP Executive Summary Source and Product Description The Andersons Waterloo Wholesale & Retail Fertilizer facility is engaged in the handling, storage, shipping and receiving of bulk agricultural fertilizers (liquid and granular), pesticides and miscellaneous farm supplies. This facility has been operated by The Andersons, Inc. since the fall of 1998. The facility manager is Terry Bechman. The facility occupies approximately 11 acres and is situated 3 miles east of the town of Waterloo and southwest of the intersection of Hwy 6 and CR 47. The facility is adjacent to the Dekalb-Agra Grain Elevator on the west side of the property. There is one neighbor to the west, about a < mile. There is one residence across the road to the south and one directly across the road to the east. The nearest residence to the north is < mile. The only RMP-regulated material at this facility is anhydrous ammonia. One 26,000 gallon tank is used for bulk storag e of the material. When filled to the maximum 85% capacity, this tank can hold 22,100 gallons of anhydrous ammonia. This material is a gas at ambient temperature and pressure. It is a liquid when stored under pressure inside the tanks. Anhydrous is not a poison, but it is an inhalation / respiratory hazard. Ammonia is a toxic material but it has no cumulative toxic effects on the human body. However, it is acutely corrosive when it comes in contact with mucous membranes, in particular. Anhydrous ammonia is a non-flammable gas. Summary of Major Hazards The principal causes of ammonia emergencies are ruptured hoses and defective valves. The most probable time for an exposure or release to occur will be during a transfer from a delivery unit (generally a tanker truck) to the bulk storage tank or a transfer from the loading station to the nurse wagons. Flexible hoses must be connected properly. Hoses on tank trucks are date-stamped are replaced by the transporter in advance of t he expiration date or when defects are observed. All transfers of ammonia are observed by Anderson personnel. Transfers from the storage tanks to the processing system or loading stations occur inside fixed steel pipes and are controlled manually. With elevated temperatures that occur during mid-to-late summer, the ammonia gas inside the bulk storage tank can expand, and possibly cause the relief valve to open in order to equalize the pressure inside the tank. The relief valve will reseal itself when pressure is relieved. These "events" are very short in duration - a few seconds at the most. A complete failure or burst tank is highly unlikely. The bulk storage tanks were built under strict guidelines established in the ASME pressure vessel code. The bulk anhydrous ammonia storage tank is protected by concrete traffic barriers. All welding and structural work done on the tank or appendages are performed by certified welders. Consequences of Failure to Control the Hazards fo r Anhydrous Ammonia The worst case scenario for this facility was created using EPA's RMP Comp software. A complete release of the tank contents (120,000 pounds -- creating a gas / vapor cloud) in a 10 minute period, using worst case atmospheric conditions, results in a distance to endpoint of 4.70 miles. The estimated exposed population is 7,000 people. This distance would encompass the town of Waterloo, it's schools, government offices and surrounding residences. No hospitals, prisons or sensitive environmental receptors would be affected. There are no passive mitigation systems available for this type of scenario. It is our belief that the risk of a complete release of the tank contents is infinitesimally small. Active mitigation systems in place at this facility were designed to prevent or mitigate any attempts to empty the tank. The tank is in a protected location, and all transfer appendages are protected by concrete barriers. A more probable release situation is express ed by the alternative release scenario. We believe that a more likely release could occur from a tanker truck transfer hose failure. Prior to the excess flow valve being activated, we estimate that the maximum amount of ammonia that could escape to the atmosphere is 2575 pounds. A release of this nature would likely last for about five minutes. Utilizing an average wind speed of 3.0 m/sec and atmospheric stability class D, the resulting distance to endpoint would be 0.40 miles. In this more realistic scenario, the only potential exposed receptors would be the residences directly adjacent to the facility and possibly the traffic along Highway 6 and County Rd. 47. Active mitigation systems were included in the alternative case scenario. They are listed in the next section. Explanation of How Hazard Releases are Prevented. Passive mitigation refers to equipment, devices, or technologies that function without human, mechanical or other energy input. Passive mitigation systems in place at the Waterloo facility are: 7 Bulkhead breakaway units located on the connection point to the storage tanks. If a truck driver were to drive off without disconnecting from the tank, the steel structure would cause the hose to break at the outside of the connection point. At this point, active mitigation would take effect and an excess flow valve, just to the inside of the breakaway would prevent the tank from emptying to the atmosphere. Active mitigation refers to equipment, devices or technologies that require human, mechanical or other energy input to function. Active mitigation systems in place at the Waterloo facility are: 7 Excess flow valves are located on all outgoing liquid and vapor valves on the storage tanks. They close automatically if the volume of gas or liquid flowing through the line exceeds the normal flow rate. They won't reopen until the downstream shutoff valve is closed and the pressure equalizes on both sides of the valve seat. Two principal cause s of the excess valve closing are a ruptured hose or a broken pipe or shutoff valve downstream that is opened too quickly. 7 Back check valves are located on the unloading lines of delivery trucks and are designed to ensure that the flow goes in one direction only. This prevents anhydrous ammonia or propane from flowing to a transport tank from the storage tanks. 7 Pressure-relief valves are located on the top of the bulk storage tanks, fixed steel piping and on the vaporizer to relieve pressure that is too great. This can be caused by elevated temperatures in the summer or overfilling. They open directly to the atmosphere at 250 psig and close when the pressure inside the tank drops below this pressure. 7 An emergency shutoff cord, located along the side of the tank shuts the valve off. 7 An ample supply of water is available near the bulk storage tank from a 15,000 gallon tank nearby and three water well hookups; one at the loading station and two nearby. 7 Spill control kits are located at the facility and include sorbent material, shovels, PPE and disposal containers. 7 Operator and truck drivers supervise all anhydrous transfers to and from the bulk storage tank Prevention Program Preventive maintenance is an integral piece of this facility's hazard management program. All hoses, tanks, valves and storage units are inspected at least monthly, and usually daily during the production season. A good PM program is our strongest defense against a release of anhydrous ammonia. All hose replacements are documented in the maintenance files. Records of all maintenance tasks performed on the tank or appendages are also on file. This facility uses outside contractors for all welding and construction performed on the tank. The Waterloo facility recently completed an ammonia system inspection by a third party in February of 1999. See "Steps Taken to Address Hazards" for more information on prevention measures and identification. Management System (see "Steps Ta ken to Address Hazards") Equipment maintenance All equipment maintenance is formally documented. See the "Prevention Program" section for further explanation. Training All employees receive annual training on anhydrous ammonia, emergency action plan and spill procedures, and hazard communication. Documentation and attendance rosters are on file at the facility. Contractors All contractors receive a "contractor safety review" prior to performing work at the facility. During this review, they are informed of any potential hazards at the facility, emergency procedures, site-specific safety rules and the ability to request an MSDS for any product at any time. Steps Taken to Address Hazards The Andersons Waterloo Wholesale Fertilizer facility has several systems in place for hazard assessment and mitigation. The Safety Department performs annual hazard management audits at the facility. The audits include a physical walk through of the entire facility and a review of all EPA , OSHA and DOT paperwork and training documentation. Action items are noted and recommendations are made. The audits consist of five major topical areas: Safety & Health, Environmental, Fire Protection & Security, Administrative and Housekeeping & Storage. Issues are documented in a report and sent to the facility manager and upper management. Updates on action item status must be made within 30 days and 6 months of receiving the report. Monthly Group meetings and plant inspections allow employees to discuss any concerns they may have with the operation of the facility. Issues are documented and assigned to employees for follow-up. Records of all meetings are kept at the facility. Response Action in the Event of a Release In the event of a burst hose or defective valve, employees are instructed to shut down the conversion process and, if possible, approach the shutoff valve from upwind and attempt to turn it off. For an uncontainable release, employees will immediately call th e police and fire department or other first responders, as appropriate. All employees, customers and contractors are to be evacuated to an upwind location. Once the response team has arrived, we will work in concert with them to close the valves between the tank and the leak. In the meantime, a steady spray of water will deluge the ammonia gas plume and knock it to the ground, while chemically binding any free ammonia. The employees are instructed to make emergency phone calls in this order: the facility Manager, 911, the corporate Safety Department emergency phone number, the Indiana Emergency Response hotline and the Indiana Department of Environmental Management emergency phone number. All applicable contact names and numbers are found in the facility spill and emergency response plan. Communication procedures with responders The local fire department is invited to tour the Waterloo facility on an annual basis. The last visit was July of 1998. Facility management, employee s and fire department personnel have jointly discussed the location of the anhydrous ammonia and response procedures on a regular basis. They know the location of all emergency shutoff valves and on-site response equipment. We believe that a strong relationship with first responders is our best defense. The LEPC and state regulatory agencies receive a copy of our hazardous materials storage information, every February, in accordance with our community right to know obligations. A copy of the Waterloo Emergency Action Plan is on file with the LEPC and the local fire departments. |