Consolidated Grange Supply Coop - Lind Fertilizer - Executive Summary |
|
Lampasas Mexican Foods, LLP is a food processing facility (SIC 2013) located at 601 East 3rd Street, Lampasas, Texas. The facility operates an ammonia refrigeration system as part of the process. Anhydrous ammonia is the RMP chemical of concern. Lampasas Mexican Foods, LLP has been at this location since 1993. The facility was operated under other ownership prior to this date. The current capacity of the system is approximately 30,000 pounds. The facility has never experienced a significant incident. The refrigeration system is designed, installed and operated in accordance with the applicable guidelines and standards of the American Society of Mechanical Engineers (ASME), the American National Standards Institute (ANSI), the International Institute of Ammonia Refrigeration (IIAR), the American Society of Heating, Refrigerating, and Air-conditioning Engineers, Inc. (ASHRAE), and the Occupational Safety and Health Administration (OSHA). Qualified outside contractors are used for construction and major repairs or modifications to the system. The system is continuously monitored and inspected by technicians that are trained, qualified, and experienced in ammonia refrigeration. Technicians are qualified in accordance with the requirements of the Refrigeration Engineers and Technicians Association (RETA). Lampasas Mexican Foods, LLP and the refrigeration staff are all current members of RETA. The system is inspected periodically for proper operation 24 hours per day. Walking inspections are conducted on intervals not longer than 4 hours. System parameters are logged in a permanent record, as are routine maintenance activities. The system is equipped with a series of redundant failsafe devices, sensors, and overrides. In the event a malfunction occurs that could result in an ammonia release, these protective devices shut the system down. The system can't be restarted until the cause of the shutdown is identified and corrected. In addition to operational training, designated technicians and management personnel on each shift have been trained as Incident Commanders in accordance with the provisions of the OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) rule as stated in 29 CFR 1910.120. A minimum of two (2) Incident Commanders is onsite at all times. Refrigeration Technicians and other staff members are also trained to respond to accidental releases of ammonia from the system. Lampasas Mexican Foods, LLP has equipment and supplies on-hand to permit trained employees to aggressively locate and control a release, should it occur. The facility conducts a full incident response drill and exercise every year. The facility has implemented a Process Safety Management Program in accordance with applicable OSHA regulations (29 CFR 1910.119). This plan is reviewed annually and updated as necessary. All significant changes to the system are reviewed in accordance with the PSM / RMP management of change provisions in the f acility's plan. The EPA requires the facility to model the potential offsite impact from a worst-case release of ammonia and an alternate release scenario. The worst-case release is based on a release from the high-pressure liquid receiver located outside the Engine Room. This could potentially release approximately 15,000 pounds of ammonia. Anhydrous ammonia is a gas at normal temperature and pressure. It may be liquefied by pressure in parts of the system. The liquid will quickly vaporize back to a gas when exposed to the atmosphere. This gas is lighter than air and rises quickly into the atmosphere with little environmental impact. Ammonia has an irritating effect on inhalation at high concentrations. Ammonia is highly water soluble. A gas cloud can be mitigated effectively with water spray. Lampasas Mexican Foods, LLP can provide water spray. Additional support can be provided by the Lampasas Fire Department. The alternate release scenario involves a release from a saf ety relief valve. This type of incident could create a gas release at a rate of approximately 100 pounds per minute (the rate recommended in the EPA's RMP Guidance for Ammonia Refrigeration document). A release from most safety release valves at the facility will result in a release of less than 100 pounds per minute. 1. Facility Accidental Release Policy: The owners, managemnet , and employees of Consolidated Grange Supply Cooperative, 318 West First, Lind Washington 99341, with branch operations at 404 West First, Lind Washington 99341 and 1306 1st. Street, Ritzville, Washington 99169 are committed to the prevention of any accidental release of anhydrous ammonia and aqua ammonia. If an accidental release should occur, the facility is prepared to work with the local fire department, and/or other authorities to mitigate any release and minimize the impact of the release to people and the environment. A detailed emergency reponse plan has been developed and will be implemented in the event of an accidential release. 2. Facility Information: *The primary activity at the Lind Fertilizer Facility is the storage, blending and sale of fertilizers to farmers. *Anhydrous ammonia and aqua ammonia are received, stored, and distributed for direct application for fertilizers for crop production nutrients. *At Lind the anhydrous ammonia is received by tanker truck and put into a 25,000-gallon above ground storage tank. The maximum quantity of anhydrous ammonia at Lind storage @ 85% of capacity is 21,250 gallons @ 5.15 pounds per gallon = 109,400 pounds. *At Lind the aqua ammonia is received by tanker truck and put into 2 - 15,000 gallon aqua ammonia above ground storage tanks. The maximum quantity of aqua ammonia at the Lind Fertilizer Facility is 30,000 gallons filled to 95% capacity 28,500-gallons @ 7.6 pounds per gallon = 216,600 pounds. The maximum storage in a single 15,000-gallon storage tank @ 95% of capacity is 14,250 gallons = 108,300 pounds. 3. The Wo rst-Case Release Scenario and Alternative Release Scenario: a. Anhydrous Ammonia Worst-Case and Alternative Release Scenarios - The worst-case release scenario for the Lind Fertilizer Facility is failure of the largest storage tank when filled to the greatest amount would release 109,400 pounds of anhydrous ammonia, which represents the volume of the largest storage tank (21,250 gallons) at 85% capacity as limited by regulations. The distance to the endpoint (point of dispersion to 200 PPM) is 1.45 miles rural. The alternative release scenario, based on the most likely potential incident is a release from 2-inch diameter pipe. The distance to the endpoint ( point of dispersion to 200 PPM) 11,900 pounds is .60 miles. b. Aqua Ammonia Worst-Case and Alternative Release Scenarios - The worst-case scenario for the Lind Fertilizer Facility is failure of the largest storage tank (15,000-gallons) when filled to the greatest amount would release (95%) 108,300 pounds of 20% aqua ammonia. The distance to the endpoint (point of dispersion to 200PPM) is .52 miles (Rural). The alternate release scenario, based on the most likely potential incident is a release of 2000 gallons (15,200 pounds) from a 15,000-gallon tank. The distance to the endpoint (point of dispersion to 200 PPM) is .20 miles (rural). 4. Accidental Release Prevention Program: Anhydrous Ammonia and Aqua Ammonia - The facility has implemented the provisions of the "Safety Requirement for Storage and Handling of Anhydrous Ammonia, K-61.1" published by the American National Standards Institute, Inc.; and the standards of the U.S. Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111 "Storage and Handling of Anhydrous Ammonia." 5. Five-Year History: There have been no accidental releases or near misses of anhydrous ammonia or aqua ammonia in the past five years. 6. The Emergency Response Program: The facility's emergency response program was written in accordance with the following reg ulations: * OSHA 29 CFR 1910.38; * OSHA 29 CFR 1910.120; and 7. Planned Changes to Improve Safety: Safety improvements are an on-going process at the facility. Periodic evaluations are performed to assess the maintenance of safe conditions. There are no additional specific planned changes to the anhydrous ammonia, or aqua ammonia processes at the facility. On March 15, 1999 during information gathering for the Risk Management Plan an inspection of the facilities was made, as well as a review of present training programs and operating procedures. As a result several new programs and procedures were written and put into place later in 1999. During the review and additional research for this Program 3 Report additional procedures are being added to the operating procedures. These additions include Safe Welding Procedures and Hot Work Permit, Contractors Safety Agreement and Review, and a Checklist for Process Hazard Analysis. It has always been the policy of this company to invo lve employees in making decisions for safety of operations and for upgradeing of safety requirements, however we will develop a written plan for employee participation. |