A. T. & CW, Inc. - Executive Summary |
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A. T. & CW, Inc. Risk Management Plan - Executive Summary 1. The accidental release prevention policy at A. T. & CW, Inc. involves, but is not limited to technologies, procedures, and management practices. All applicable procedures of the ANSI K-61.1 - 1989 "Safe Requirements for the Storage and Handling of Anhydrous Ammonia," as adopted by the Iowa Department of Agriculture and Land Stewardship (IDALS), are adhered to. Our emergency response policy involves the preparation of response plans which are tailored to our facility and to the emergency response services available in our community, and is in compliance with the EPA Emergency Response Program requirements. 2. Our facility is in the business of selling anhydrous ammonia to farm customers as a form of nitrogen fertilizer. Our facility has one anhydrous ammonia storage tank with a maximum capacity of 30,000 gallons, water capacity. Our location includes anhydrous ammonia storage tanks, nurse tank filling risers, electric al panels, lighting, and anhydrous ammonia safety equipment. Our facility is manned seasonally during normal business hours. 3. The off-site consequence analysis includes two anhydrous ammonia release scenarios, identified as "worse-case release" and alternative scenario". The first scenario is defined by EPA and states that "the owner or operator shall assume that the maximum quantity in the largest vessel is released as a gas over 10 minutes due to an unspecified failure. The alternative scenario is defined as more likely to occur than the worst-case release scenario. The worst-case release scenario at A. T. & CW, Inc. involves a failure of the anhydrous ammonia storage tank with the capacity of 135,915 pounds of anhydrous ammonia. The off-site consequence analysis for this scenario was performed by using pre-defined EPA guidelines in RMP-Comp version 1.05 software. EPA mandated meteorological conditions were determined by using RMP-Comp version 1.05 for both the worst-ca se release scenario and the alternative release scenario. When atmospheric dispersion modeling for the worst-case release scenario was performed using RMP-Comp assumptions, a distance to toxic endpoint of 4.4 miles was used. An estimate of residential population potentially affected of 2937 was obtained by using 1990 population census figures. The alternative scenario involves the rupture of a 2-inch inside diameter anhydrous transport transfer hose for a time period of 2 minutes. Two minutes release time assumes human intervention and excess flow valves stop the release. When atmospheric dispersion modeling for alternative scenario releases was performed using RMP-Comp assumptions, a distance to toxic endpoint of 0.5 miles was used. An estimate of residential population potentially affected of 25 was obtained by using 1990 census figures. 4. The accidental release prevention plan for A. T. & CW, Inc. is based on the following key elements: a. annual training of all personnel required to handle ammonia and what to do in an emergency b. facility constructed and maintained according to ANSI K61.1-1989 standards adopted by IDALS in Iowa c. use of usual anhydrous ammonia safety equipment d. use of effective operating procedures according to Agricom's anhydrous ammonia safety procedures handbook and training videos e. annual inspections by IDALS of storage tanks, piping for leaks, nurse tanks, applicators, transfer risers, riser hoses, safety equipment, pressure relief valve records, etc. f. A. T. & CW, Inc. site inspections by the manager at least once per year 5. No accidental releases of anhydrous ammonia have occurred at this facility in the past five years. 6. This facility has an emergency response program, which has been coordinated with the Indianola Fire Department, which is a member of the Warren County LEPC (Local Emergency Planning Committee) in Iowa. Emergency operations an d response procedures are reviewed annually and include a site visit of the facility by the Indianola Fire Department. 7. Changes to improve safety at this facility are completed as required by rule change and/or methods to increase safety and/or efficiency of operations. |