Helena Chemical Company, Buckeye, Arizona - Executive Summary |
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Helena Chemical Company (Helena) owns and operates an agricultural chemical dealership near Buckeye, Maricopa County, Arizona (Facility). The Facility stores and distributes agricultural chemicals to the local agricultural community. Helena is committed to the prevention and minimization of accidental releases of potentially hazardous chemicals. It is the policy of the Facility to adhere to all applicable federal, state and local regulations. To meet their commitment to prevention, Helena has implemented an EPA Risk Management Plan (EPA RMP) to address regulatory requirements from Section 112(r) of the clean Air Act (CAA). Based on the regulatory requirements, a Program Level 2 Prevention Program has been prepared for the Facility operations. It is anticipated that in the future the Facility will store a maximum quantity of about 364,800 pounds of anhydrous ammonia (CAS No. 7664-41-7). The RMP submittal threshold quantity for anhydrous ammonia is 10,000 pounds. It is anticipate d that the ammonia will be stored in two 30,000 gallon co-located storage tanks and up to 16 portable 1000 gallon tanks. This RMP is a presumptive filing for the above described process. This EPA RMP includes a review of potential hazards associated with ammonia at the Facility, operational procedures, maintenance procedures, and employee training. Safety reviews are communicated to the employees to reduce the possibility of an accidental release. To minimize the hazards presented by an accidental release to Facility employees or the public, Helena has prepared an emergency response plan that coordinates the actions of Facility employees with local emergency responders. The Buckeye Valley Fire Department is the emergency first responder for the Facility and three Facility employees are part time members of this fire department. The Facilities emergency response program is based upon the EPA Emergency Planning and Community Rght to Know Act regulations, Federal and State OSHA Emerg ency Action Plan and Hazwoper regulations, U. S. DOT Hazardous Materials and Emergency Response regulations, other state regulations, the industry's Pre-Fire Planning Program, and internal company policies and procedures. This information has been provided to local emergency response agencies. There have been no reportable accidents or releases at the Facility involving ammonia in the past five years. As described above this RMP is a predictive filing. In accordance with 40 CFR 68.25 the hypothetical worst-case release scenario has been evaluated. An alternate release scenario using the parameters described in 40 CFR 68.28 and the EPA's Off-Site Consequence Analysis guidance document was evaluated. These analyses indicated that in the event of a hypothetical catastrophic release, regulated chemicals could migrate off the Facility site and potentially pose a threat to the surrounding community. Toxic Endpoing concentrations (TEs) for the regulated chemical, piblished in the EPA regulations were used for this evalustion. These scenarios are summarized below. Anyhdrous Ammonia Storage Worst Case Scenario - Failure of the two co-located storage tanks could potentially release up to 273,600 pounds of anhydrous ammonia. The analysis assumes that the entire contents of both tanks is released as a liquid at a rate of 27,400 pounds per minute. The liquid is assumed to vaporize soon after contact with ambient air. Air dispersion modeling estimates the TE for ammonia could hypothetically extend downwind as far as 8.9 miles. Anhydrous Ammonia Storage Alternate Release Scenario - Failure of a 1-inch transfer hose or pipe. The contents of the hose and storage tank (about 5,700 pounds) would be released for approximately 3 minutes until the tank was empty. The resulting spilled liquid material would then vaporize after contact with ambient air. Air dispersion modeling estimates the TE for ammonia could extend downwind as far as 0.8 miles. Based on Helena's policy, safety meetings for employees are conducted on a continuing basis and ongoing safety improvements are routinely adopted. Additional employee training and preventative maintenance programs will be implemented in response to the results of internal auditing procedures, process changes, or changes in the regulated substances handled at the Facility |