Warren Lapp & Son - Executive Summary |
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General Executive Summary for Anhydrous Ammonia Storage Warren Lapp & Son Farms, Inc. Coshocton, OH 43812 1. Accidental Release Prevention and Emergency Response Policies The primary function of Lapp Farms is to act as a agricultural crop farming facility. The primary purpose of the Anhydrous Ammonia facility is to act as storage of Ammonia for use as an agricultural feedstock. By virtue of the toxic effects associated with ammonia, it is necessary to observe certain safety precautions in handling ammonia to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as the health of our co-workers, and to reduce the threat to nearby members of the community. We are strongly committed to employee, public and environmental safety. Safety at our facility depends upon the manner in which we handle ammonia as well as on the various safety devices incorporated into the design of our equipment. Furthermore, comprehensive training received by our employe es adds to the inherent safety of our storage facility. Our emergency response program is based upon the American National Standards Institute's Safety Requirements for the Storage and Handling of Anhydrous Ammonia and Title 29 Code of Federal Regulation, OSHA 1910 Standard for Anhydrous Ammonia . In addition to the presence of appropriate controls to prevent possible releases of propane, if a release does occur, we are coordinated with the Walhonding Valley Fire Department, which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled The primary purpose of this facility is to store Anhydrous Ammonia for use as an agricultural feedstock. Ammonia arrives at our facility via truck transport and is stored in two storage tanks. This facility has equipment for unloading transports and equipment to load farm cart containers. Access to this site is restricted to authorized fac ility employees, authorized management personnel and authorized contractors. The regulated substance handled at this facility is Anhydrous Ammonia. The maximum amount of ammonia that can be stored at this plant is 137,280.00 lb. 3. The Worst Case Release Scenario and the Alternative Release Scenario, Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario We have calculated worst case release scenarios based on the NPGA-EPA approved TNO-Multi energy method. For alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for ammonia involves a catastrophic release from the largest container resulting in a Boiling Liquid Expanding Vapor Explosion, or BLEVE. The scenario involves the release of 82,368 lb. of ammonia. It is ass umed that the entire quantity is released as a liquid which flashes rapidly into vapor, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather, the maximum distance of 5.10 miles was obtained corresponding to a toxic endpoint. The alternative release scenario involves a release from ammonia piping resulting from a pullaway from the truck stanchion, resulting in a toxic release. In this scenario 101 lb. of ammonia is released in 10 minutes. The release is also controlled by active mitigation measures that include excess flow valves, backflow check valves, and positive shutoff valves. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 for 40 seconds is 0.10 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR p art 68 of the EPA. This facility was designed and constructed in accordance with ANSI Document K61.1/CGA G-2.1. The following sections briefly describe the release prevention program that is in place at our stationary source. Safety Information Lapp Farms, Inc. maintains a detailed record of written safety information, which describes the chemical hazards, operating parameters and equipment designs associated with all aspects of our distribution facility. Hazard Review A checklist methodology is used to carry out hazard reviews at our facility. The reviews focus on operating procedures, equipment functions and handling practices to identify possible hazards. The studies are undertaken by qualified personnel with extensive knowledge of facility operations and are revalidated at a regular interval of three years. Any findings related to the hazard reviews are addressed in a safe and timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Lapp Farms, Inc. maintains written operating procedures. These procedures address various modes of operation such as Inspection, Maintenance, and Transfer Operations as well as Emergency Response and Personal Protective Equipment Requirements. The information is regularly reviewed and is readily accessible to operators involved with the processes. Training Lapp farms, Inc. has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided as needed. Maintenance Lapp Farms, Inc. carries out documented maintenance checks on process equipment to ensure proper functioning. Maintenance activities are carried out by qualified personnel with previous training in these pra ctices. Furthermore, personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Compliance Audits Lapp Farms, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Lapp Farms, Inc. promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of ammonia. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from recurring. All reports are retained for a minimum of 5 years. 5. Five-year Accident History Lapp Farms, Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Lapp Farms, Inc. maintains a written emergency response plan to deal with accidental releases of ammonia. The plan includes all aspects of emergency response including handling leaks, emergencies, basic medical treatment, and notification of local emergency response agencies and the public. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Coshocton County Emergency management Agency is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various eleme nts of our accidental release prevention program. Increased Inspection, Maintenance, and Training are some of the major steps we want to take to improve safety at our facility. These changes shall be implemented by June 1, 2000. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: David Lapp Signature: Title: Partner Date signed: |