Tanner Industries, Inc. - Executive Summary

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Executive Summary 
Risk Management Plan: 
Toxic Material: Ammonia 
  Tanner Industries, Inc.  
  2320 South Avenue 
  Council Bluffs, IA.,  51501 
Corporate Headquarters: 
  Tanner Industries, Inc. 
  735 Davisville Road 
  Third Floor 
  Southampton, PA 18966 
Corporate contact for further information: 
  David B. Binder 
  Telephone: 215-322-1238 
  Fax: 215-322-7791 
  Internet Site: www.tannerind.com 
  E-Mail: [email protected] 
Plan Revision Date:   May 1, 1999 
Company and Facility History: 
Tanner Industries, Inc. is a third generation family owned and operated distributor of anhydrous and aqua ammonia, headquartered in Southampton, PA. The Tanner family started out in the ammonia business in 1955 with the purchase of National Ammonia Company in Philadelphia, PA. The company has grown to it's current size through the acquisition of three other ammonia companies, Bower Ammonia and Chemical Co. in 1971, Northeastern Ammonia Co. in 1985, and Hamler Industries in 19 
91. This particular facility was acquired from Hamler Industries in 1991. 
The mission of Tanner Industries, Inc. is to constantly improve our products and services to meet or exceed our customers needs, to distribute our products in a safe, efficient and environmentally responsible manner, and to generate a reasonable return in order to provide continuity for the business and employment for our employees.  
Tanner Industries, Inc. is firmly committed to a fully effective implementation of the Risk Management Plan (RMP) as it applies to the safe distribution of ammonia. Our commitment to the Responsible Distribution Process (RDP) provides our company with an integrated health and safety, environmental, and product stewardship program that is supported by our strong corporate capabilities. Our dedication to the proper distribution and stewardship of ammonia includes involvement in emergency response training for first responders and other industry personnel to enhance the protection of  
our employees and community neighbors.  
Tanner Industries, Inc. is a distributor of anhydrous ammonia. We are not a manufacturer. The material is transported to our facility by rail car and transferred to cargo tank trucks for bulk distribution to the end-users of the material. 
The potential maximum quantity of anhydrous ammonia that could be stored at this facility on any particular day is 194,675 pounds. This capacity represents materialin a full railcar in addition to a full cargo transport tank. It is only on rare occasions when these potential storage quantities are actually achieved.   
Benefits and Uses of Ammonia: 
Ammonia is a basic chemical that has many common manufacturing and practical uses. The largest users of ammonia are agricultural industries. Ammonia itself is applied directly by farmers as a fertilizer. Some agricultural businesses combine ammonia and other chemicals and nutrients to form more complex fertilizers. Other common products that are made with ammonia i 
nclude textiles, pharmaceuticals, cleaning solutions, dyes, inks and food packaging products. Ammonia is also used by some companies in various processes. Ammonia is recognized as an "ozone safe" refrigerant. This means that, unlike other refrigerants, any ammonia releases into the atmosphere will not harm the earth's ozone layer. Besides refrigeration, Ammonia is used in some common processes like drinking water purification, air and water pollution control, waste treatment, reprographics, and the heat treating or hardening of metal parts. 
Potential Health Effects of Ammonia: 
Even in small concentrations, ammonia is irritating to the eyes, throat and breathing passages.  Accompanied with a very pungent odor, ammonia can be said to be "auto-repulsive". These  characteristics provide us with an early warning of the material's presence and force us to retreat from ammonia contaminated atmospheres.  High concentrations could have more serious health effects. These could include convulsi 
ve coughing, difficult and painful breathing, eye damage and in extreme cases, death. Liquid ammonia or ammonia solution contact of the eyes or skin can produce serious chemical burns requiring prompt medical attention. 
Employees and contractors who work around ammonia should take the extra precautions of reviewing Material Safety Data Sheets, wearing appropriate safety equipment and participating in special training programs as prescribed by the US Occupational Safety and Health Administration. 
What Tanner Industries, Inc. Does to Keep Us Safe: 
Prevention Policy Statement: 
The owners, management and employees of Tanner Industries, Inc. are committed to the prevention of accidental releases of ammonia. Our company has implemented the standards of the US Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia" as well as the published provisions of the American National Standards Institute's (ANSI), K61.1, "Safety Requirements 
for the Storage and Handling of Anhydrous Ammonia". 
Tanner Industries, Inc. is a member of the National Association of Chemical Distributors (NACD) and committed to the Responsible Distribution Process (RDP). This process is an initiative of the NACD and its member companies designed to provide a system which promotes continuous improvement in the health, safety and environmental performance of all its members. It is designed to be sensitive and responsive to the public concerns about the chemical industry. 
As a member of the NACD, Tanner Industries, Inc. is committed to the continuous improvement in the chemical distribution industry's responsible management of chemicals. We pledge to manage our business according to the Codes of Management Practice of the Responsible Distribution Process. These codes pertain to: 
  1) Risk Management. 
  2) Compliance Review and Training. 
  3) Carrier Selection. 
  4) Handling and Storage. 
  5) Job Procedures and Training. 
  6) Waste Management 

  7) Emergency Response and Public Preparedness. 
  8) Community Outreach. 
  9)Product Stewardship. 
Tanner Industries, Inc. is the recipient is the Chemical Education Foundation's 1996 Product Stewardship Award - Chemical Distributor Category, for exhibiting excellence in fostering chemical product stewardship. 
Tanner Industries, Inc. uses a variety of safety equipment and specialized procedures to prevent accidental releases of anhydrous ammonia. In support of our policy, the following is a typical list of safety equipment and systems employed at this facility.  
  a) Pressure relief valves are employed on all storage, transfer and delivery equipment to handle unexpected increases in pressure. Per their operational design, these valves will reset after relieving only the excess pressure. Depending on their situational placement in the process, these valves may be designed to relieve pressures caused from either vapor or liquid. 
   b) Excess flow shut off devices are incorpor 
ated through out the process as prescribed by federal regulation. These valves are designed to stop the flow of liquid material any time their rated flow capacity is exceeded. These valves are designed to prevent the catastrophic release attributed to a storage tank line or valve break. 
  c) Regular facility and equipment inspections ensure safe and proper operating conditions. 
  d) Employees are trained in start-up, operation, shut-down and maintenance of all equipment. The facility has a copy of the Standard Operating Procedures that are required to perform these tasks and employees are required to follow these procedures and encouraged to reference them as needed. 
 e) Employees and contractors receive extensive health care and safety training pursuant to all applicable regulatory and corporate guidelines. 
 f) Investigation of any accident or injury with the development and implementation of corrective action plans in order to prevent reoccurrences at any of our facilities. 
 g) Routine audits and inspections are performed by both Tanner Industries, Inc. management and outside agencies to ensure safe and correct procedures are employed, and to identify areas where safety can be improved. 
 h) Coordination of planning efforts with Local Emergency Planning Committees (LEPCs), fire departments and Haz-Mat Units. 
Safety Improvement Process: 
Safety improvement is a corporate wide philosophy.  Tanner Industries, Inc. continuously searches for ways to improve safety performance. Each facility has an individual safety committee comprised of site employees and management. These committees meet on a periodic basis to review safety concerns at our sites as well as at our customer facilities. The management representatives of the site specific committee report directly to the corporate safety committee. The corporate safety committee is comprised of upper management, compliance personnel and headquarters employees that are familiar with plant processes. This commi 
ttee meets on a regular basis to review accident and injury investigations, evaluate site specific issues, provide recommendations and implementation guidance.  Also, qualified personnel periodically inspect and evaluate each facility to assess safety and maintenance conditions. The results of these facility inspections are reported directly to upper management and the operations department. As a whole, these systems provide Tanner Industries, Inc. with a continuous process for the identification of safety improvement opportunities thus reducing any risk to our society associated with a release of this important chemical. 
Accidental Releases in Perspective: 
Worst Case Release Scenario (Full Potential Release)   .......160,000 pounds of anhydrous ammonia. 
Alternate Release Scenario (More Likely release)          .......     150   pounds of anhydrous ammonia. 
Largest Actual Release in Last Five years (Historical)   .......      0      pounds of anhydrous ammonia. 
Release scenarios wer 
e modeled using the "Aerial Locations of Hazardous Atmospheres (ALOHA)" software developed by the US Environmental Protection Agency. Off-site receptors have been identified using "LandView III" software developed by the US Department of Commerce, Bureau of Census.   
Worst Case Scenario 
Tanner Industries, Inc considered a 160,000 pound release of anhydrous ammonia as the worst case scenario. The release event resulted from the entire contents of the largest vessel, in this case a cargo tank truck, emptying in 10 minutes. Since ammonia is stored as a liquid under pressure, the release would result in a dual-phase flow. Dual-phase flow means that the material would simultaneously flow as a gas and a liquid and then vaporize into a gas. The dual-phase flow was automatically considered by the software for this scenario. Liquid ammonia spills also undergo a phenomenon known as "auto-refrigeration". This is an effect that is demonstrated by a decrease in the internal temperature of an ammon 
ia pool due to vaporization. This characteristic essentially decreases the vaporization rate of an ammonia pool. Thus, the vapor cloud from a liquid release would diminish over time and the endpoint would be dynamic. An increased effect could be expected if the release were to occur within an area that limited the exposed surface of the pool. Neither the  auto-refrigeration property of ammonia or any other mitigating factors were a consideration used in this scenario.  
The off-site area impacted by the release could experience ammonia concentrations of 200 parts per million (ppm). Please refer Section 2, Worst Case Release Scenario of the Risk Management Plan for further information. 
Alternate Case Release Scenario 
Tanner Industries, Inc considered a conservative alternate case scenario. We selected a release amount of 150 pounds of anhydrous ammonia, which is 150% of the maximum amount released at any of our facilities based on our five year accident history. We applied this conserv 
ative scenario to all of our facilities for the following reasons: 
  a) All of our facilities store and handle anhydrous ammonia. 
  b) All of our facilities use the same basic processes in their operation. 
  c) The potential for this amount to be released at any of our facilities does exist. 
  d) Some of our facilities do not have a history of accidental releases. 
The scenario was performed considering the total 150 pounds of ammonia released as a gas. No mitigating factors were assumed for this scenario.  
The off-site area impacted by the release could experience ammonia concentrations of 200 parts per million (ppm). Please refer Section 3, Alternative Case Release Scenario of the Risk Management Plan for further information. 
Five Year Accident History: 
There have been no unintentional releases of anhydrous ammonia at the Tanner Industries, Inc., Council Bluffs, IA. facility in the past five years that meet the US EPA Risk Management Program (RMP) defined reporting requirements 

The following is a list of all unintentional ammonia releases at our facility that have been reported to federal, state and local authorities in the past five years under the requirements of US Environmental Protection Agency's Superfund Amendments and Reauthorization Act (SARA) Title III, Emergency Planning and Community Right to Know Act (EPCRA).  None of these releases, to our knowledge, resulted in any adverse impacts to the community, the environment or our employees. 
Quantity Released (Anhydrous)     1994      1995      1996     1997     1998     1999 (1st Qtr.) 
Greater than 1,000 pounds               0             0            0           0           0            0 
100   to 1,000 pounds                       0             0            0           0           0            0 
10 to 100 pounds                              0             0            0           0           0            0 
Less than 10 pounds                        0             0            0           0         
  0            0 
Emergency Response Procedures: 
Emergency Response Policy Statement: 
The owners, management and employees of Tanner Industries, Inc. are prepared to cooperate with local 
emergency responders and other authorities to mitigate any release and minimize the impact of any release 
to the community, the environment, and our employees. To be prepared for any potential chemical 
accidents, our company communicates regularly with the Local Emergency Planning Committee (LEPC) 
and local fire departments.  
The facility has a written emergency action plan in accordance with US Occupational Health and Safety 
Administration (OSHA) standard 29 CFR 1910.38. We have provided state and local authorities the 
Emergency Planning and Community Right to Know (EPCRA) information as required by the US 
Environmental Protection Agency's SARA Title III standard. Also, our company has a Emergency 
Response Program, in accordance with OSHA standard 29 CFR 1910.120 (q), including pre-emergency 
ing and employee, customer and, public emergency responder training programs that are specific to 
anhydrous and aqua ammonia. 
Sheltering in place is considered to be a proven method for protecting people in the event of an accidental 
release. To shelter-In-Place do the following: 
    1) Move inside immediately (building or vehicle). 
    2) Close all windows and doors. 
    3) Turn off ventilation systems. 
    4) Go into and seal a room (use tape, towels etc. to seal doors and windows if possible). 
    5) Use radio, phone, etc. for communications.
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