Millard Feed Mill - Executive Summary |
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Risk Management Plan Millard Feed Mill - Elkhorn, WI Prepared for: Mr. Robert Cook Millard Feed Mill W 6406 County Road A Elkhorn, WI 53121-2929 Prepared by: Liesch Environmental Services, Inc. 6000 Gisholt Drive, Suite 203 Madison, WI 53713 (608) 223-1532 JN: 71055.00 August 26, 1999 James J. Fleischmann David Macdonald Project Manager/Air Services Principal CERTIFICATION STATEMENTS To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate and complete. In addition, the undersigned certifies that for the purposes of this initial Risk Management Plan submittal the individuals responsible for operating and maintaining the ammonia storage vessel have the knowledge, skills and abilities to safely carry out their duties and responsibilities. This certification is provided in lieu of specific training and competency testing provisions set forth i n the data elements, as provided in 40 CFR S. 68.54. Signature Print Name Title Date EXECUTIVE SUMMARY Accidental Release Prevention Policies Millard Feed Mill will work to prevent accidental releases of toxic substances that could result in a safety hazard to the public or to the workers at the Facility. Millard Feed Mill will work with Occupational Safety & Health Administration (OSHA), U.S. Environmental Protection Agency (USEPA), and the Local Emergency Planning Committee (LEPC) contacts, including both fire department HAZMAT and the Walworth County Emergency Management Department, to minimize the potential for any accidental release and to help assure that the facility is prepared to respond in the event of an accidental release. The emphasis of this Risk Management Plan is on anhydrous ammonia, the currently regulated substance identified within the federal regulations. However, Millard Feed Mill has procedures in place to h elp minimize the chance of accidents related to other potentially hazardous substances stored or handled on site. If an accidental release were to occur, it is the policy of Millard Feed Mill to notify the appropriate emergency contacts. The City of Elkhorn has a HAZMAT response unit that acts as a primary responder in the event of a release of ammonia. Millard Feed Mill would use their emergency response plan as a guide to direct the company's response. The facility maintains a response plan to cover potential releases of ammonia as required by the RMP rules. Description of Facility and Regulated Substance(s) Millard Feed Mill operates a facility that markets anhydrous ammonia. Anhydrous ammonia is used as a nitrogen source by farmers in the region to promote crop growth. Millard Feed Mill stores a maximum of 79,113 pounds (15,302 gallons) of ammonia in any one storage vessel considering administrative limits at 85% of the physical storage vessel capacity to maintain a safe v apor space above the liquid surface. A second, smaller storage vessel that also stores anhydrous ammonia has and administrative limit of 52,742 lbs of ammonia. Each of these storage vessels represents a separate regulated process since the two tanks are not anticipated to interact as part of any accidental release and are therefore not represented as one combined process. Anhydrous ammonia is stored on-site in excess of the threshold value of 10,000 lbs, identified under the Risk Management Plan (RMP) listing rule, and the substance is therefore included in this Risk Management Plan. The Court of Appeals for the District of Columbia has acted with a "stay of action" regarding propane storage RMP filings, thus the RMP at this time addresses only the ammonia storage. The Off-site Consequence Analysis (OCA) provided an estimated distance to the listed 0.14 mg/l endpoint of concern identified by U.S. EPA. Worst-Case Release Scenario Description The Worst-case Release Scenario mode ling included the following: Substance Scenario Treatment Ammonia Release to the Atmosphere Winds at 1.5 m/s, nighttime F stability class The Worst-case Scenarios modeled meet the specifications described in the EPA Off-site Consequence Analysis Guidance (April 1996 and April 1999) and 40 CFR Part 68 (the RMP rules), assuming a 10-minute release of the entire contents of the storage vessel. Worst-case Scenario modeling uses highest air temperatures and associated stored ammonia temperature, coupled with conservative nighttime wind speed and stability class assumptions. Alternative Release Scenario Description The Alternative Release Scenario was selected by evaluating several more typical events and considering the resulting impact with more typical release rates and atmospheric conditions. The Alternative Release Scenario was identified using the more conservative of the evaluated scenarios. The Alternative scenarios included the following: Substance Scenario Treatment Ammonia Release at actual modeled rate Winds at 4.56 m/s, D stability class The Alternative case considers typical circumstances using the highest of individual average monthly temperature based on a review of the 50-year average conditions for July (the warmest month) from Madison's Truax field National Weather Service reporting station. The EPA concentration simulation approach applied based on OCA guidance uses a conservative treatment of data with a 3.0 m/s wind speed. Additional information on the estimates of the distance to the endpoint and the population potentially affected are contained in the Offsite Consequence Analysis report. Results of Off-site Consequence Analysis The Off-site Consequence Analysis resulted in the following predicted distances to the endpoints and population potentially affected for an accidental release of ammonia: Distance to Endpoint (mi.) Residential Population Worst-case Scenario 5.1 5,405 Alternative Scenario 1.4 334 The estimated residential population potentially affected is derived using procedures described in EPA's Off-site Consequence Analysis Guidance. These procedures conservatively include the entire area inside of a circle described using the storage vessel at the center and the distance to the endpoint as the radius. Since typical events affect only a relatively narrow sector of this circle, and only a portion of the population would be present at the time, this estimate clearly represents an upper bound for the potentially impacted residential population. General Accidental Release Program and Prevention Steps Millard Feed Mill complies with EPA's Accident Prevention Provisions set forth in 40 CFR Part 68 and applicable state and local codes and regulations. The facility also meets the EPCRA planning requirements for ammonia storage. Related discussion on the prevention initiatives is provided with the data elements in Section 8 of this plan. Five-Year Accident History No reportable incidents related to ammonia storage have occurred in the past five years. Emergency Response Program In the event of an emergency involving propane or ammonia storage vessels, Millard Feed Mill will notify the Elkhorn Fire Department HAZMAT unit. The emergency response plan (prepared for propane releases under 40 CFR Part 68) will be used for response activity guidance by Millard Feed Mill. Because Millard Feed Mill is not a primary responder to any ammonia release, no formal classroom training for response plans (HAZWOPER, 40-hr, etc.) is required. However, the facility limits the number of individuals that handle ammonia at the facility and provides in-house training for these individuals on proper operating and maintenance procedures for ammonia storage. Planned Changes to Improve Safety The RMP includes changes, developed in recent years, which have already been implemented to improve safety at the facility. This includes the use of "pop-off valve s" which close off the flow of ammonia from the storage vessel should a transfer line or valve be severed or malfunction causing a sudden drop in the storage pressure. The facility has been regularly inspecting valves and other equipment with a major inspection occurring at the beginning of each season to determine any equipment that needs maintenance or replacement. The facility regularly performs maintenance or rebuilding of pumps at least yearly, or sooner if needed. The new employees receive on-the-job training from senior personnel regarding equipment safety measures before operating the equipment. No new changes to the safety plans are anticipated. \\LIESCH\SYS\Shared\7105500\ExecSum.doc |