Powell Simplot Soilbuilders - Executive Summary
Risk Management Program - Data Elements |
For further information concerning this executive summary or other elements of the Risk Management Program please contact Jim Grauberger, Unit Manager.
303 South Bent
P.O. Box 565
Powell, WY 82401
1. Policies and Guidelines
It is the policy of the J.R. Simplot Company (Policy Statement EN 01.1) to manufacture, handle, store and dispose of all substances safely and in compliance with the requirements of federal, state and local environmental laws while reducing the risks to human health, safety and the environment. Each manager is expected to responsibly implement this policy, and each employee is expected to comply fully with the spirit, as well as the letter of this policy. The Company will assure that the environmental, health and safety laws, regulations, and standards applicable to its products and operations are known and obeyed by employees.
It is the
policy of the Minerals and Chemicals Group of the J.R. Simplot Company (Policy Statement M & C #3) that the processing, manufacturing, storage, shipping, or disposal of products and materials shall be carried out in a manner consistent with the protection of public safety and the environment, and in full conformity with the requirements of the law.
The J.R. Simplot Company Guideline (Guideline Statement SA 01.2) states that the Company is committed to reducing incidents or occurrences in the workplace that result in human injury, illness, or death, and/or destruction or loss to the corporation's assets and to be in compliance with all laws and regulations governing workplace safety. It is, therefore, our intent to provide a safe work environment and to protect the corporation's assets. This guideline applies to all groups and separate operating entities of the J.R. Simplot Company. Emergency plans shall be developed for each operating unit outlining the practices and procedures for em
ergency medical care, fire response, evacuation, or other emergencies. Each group shall develop and implement appropriate programs for initial and ongoing safety and loss prevention training of employees.
2. Regulated Substance(s)
The substance(s) that are routinely "stored" at this facility would be Anhydrous Ammonia at or above the threshold level for the RMP.
Anhydrous Ammonia is received via rail car and reacted with phosporic acid to produce ammonium polyphosphate fertilizer. This end product is considered non-hazardous. This fertilizer is utilized for land application used in crop production.
The reactor utilized in this process is not the property of the J.R. Simplot Company. It is a private company that travels with this equipment to various states providing this service for retail fertilizer locations. All of the personel utilized in this process are employees of this private company. No employees of the J.R. Simplot Company are involved in any of this processing.
The sole reason the regulated substance is on J.R. Simplot's property is for the purpose of making this non-hazardous end product fertilizer. There is no "stationary storage" of a regulated substance under RMP.
3. Worst-Case and Alternative Release Scenario
The worst-case release scenario for Anhydrous Ammonia would be the release of the total contents of the rail tank car released as a gas over a 10 minute period. The maximum quantity released would be 145,000 pounds, which represents the volume of the largest stationary storage tank at the facility at 85 percent capacity, as limited by design standards. The distance to the endpoint (point of dispersion to 200 ppm) is 4.4 miles.
The alternative release scenario based on the five year accident history (or the most likely potential incident) is a release from a break in a transfer hose, which is estimated to release 11, 908 pounds over a release duration of 2 minutes. The distance to the endpoint (point of dispersion to 200 ppm)
is .41 miles based upon modeling by the owner of the reactor processing the regulated substance. The model utilized by this company is Cameo.
4. Accidental Release Program
This Anhydrous ammonia facility implemented the provisions of "Safety Requirements for the Storage and Handling of Anhydrous Ammonia" as published by The American National Standards Institute, Inc. (ANSI K61.1), 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 Accident History
In the past five years there have been no accidental release for this covered process at this site.
6. Emergency Response Program
This facility has developed a written emergency contingency plan (Integrated Contingency Plan). The plan addresses the regulations concerning emergency plans as mandated under: OSHA 29 CFR - 1910.38, 1910.119, and 1910.120, EPA 40 CFR - part 264 subpart D, part 265 subpart D, part 68 an
d 279.52, DOT/RSPA-FRP - 49 CFR part 194. Elements within this plan include employee training, SARA Title III reporting requirements and community right to know, pre-emergency planning, and emergency response planning.
7. Planned Changes to Improve Safety
Safety and Environmental programs are very dynamic, since this is an ongoing process, changes toward improvement are evaluated and implemented periodically. The need for improvement is identified by facility employee inputs, inspections and audits which are performed regularly at this facility.
1.1.a. Facility Name:
J.R. Simplot Company, d.b.a. Simplot Soilbuilders
303 South Bent
P.O. Box 565
Powell, Park County, WY 82435
1.1.b. Parent Company:
J.R. Simplot Company
P.O. Box 27
Boise, ID 83707
1.1.c. Not Applicable:
1.2. RMP Facility Identifier: _ _ _ _ _ _ _
1.3. EPA Identifier: _ _ _ _ _ _ _ _ _ _ _ _
1.4.a. Facility Dun and Bradstreet Number: Not Applicable
1.4.b-c. Dun and Bradstreet Number, P
arent Company: 00-907-3511
1.5.h-i. Latitude and Longitude
h. Latitude: 44.7513967 i. Longitude: 108.7554333
1.5.j. Method for Determining Latitude and Longitude:
Code: G0 GPS - Unspecified
1.5.k. Description of Location Identified by Latitude and Longitude:
Code: ST Storage Tank
1.6.a. Owner/ Operator: J.R. Simplot Company, d.b.a. Simplot Soilbuilders
1.6.b. Phone: 307-754-4833 (Business)
1.6.c-h. Simplot Soilbuilders
303 South Bent
P.O. Box 565
Powell, WY 82435
1.7.a-b. Name and Title of Person Responsible for Part 68 Implementation:
John Meiners, Vice President and/or Pat Avery, Director of Regulatory Affairs
1.8.a-b. Name and Title of the Emergency Contact:
Jim Grauberger, Unit Manager
1.8.c-e. Telephone and 24-hour Numbers of Emergency Contact:
Phone: Office: 307-754-4833 Home: 307-754-4731
1.9.a. Facility or Parent Company E-Mail Address: (optional)
1.9.b. Facility Public Contact Phone Number: (optional)
1-800-635-9444 ext. 2778 - Rick Phillips
1.9.c. Facility or Parent Company WWW Homepage Address: (optional)
1.10. LEPC: (optional)
1.11. Number of Full-time Employees: 6 (add part time to get full time equivalent).
1.12.a-c. Covered by:
OSHA PSM: NO
EPCRA Section 302:YES
CAA Title V Permit:NO
1.13. OSHA Star or Merit Ranking: (optional)
1.14 Last Safety Inspection Date: April 1999
1.15. Last Safety Inspection Performed by: EPA\State Department of Agriculture
1.16. Will this RMP involve Predictive Filing?
1.17 Process Specific Information:
1.17.a. Program Level: Level 2
1.17.b. NAICS Code: 42291 (replaces SIC 5191)
Chemical: Anhydrous Ammonia
CAS number: 7664-41-7
TOXICS: WORST CASE
2.1.a. Chemical Name: Anhydrous Ammonia
2.1.b. Percent Weight of Chemical in Mixture: Not Applicable
2.2. Physical State: Gas liquified by pressure
Based On: RMP Comp
2.4. Scenario: Gas release
2.5. Quantity Released: (Total Tank Volume in pounds): 145,000
2.6. Release Rate: ((pounds/minute) Tank Volume/10 min.): 14,500
2.7. Release Duration: 10 minutes
2.8. Wind Speed: 1.5 meters/second
2.9. Stability Class: F
2.10. Topography: Urban
2.11. Distance to Endpoint: 4.4 Miles
2.12. Residential Population within Endpoint Radius: 7,200 (rounded to second digit).
2.13. Public Receptors:
2.14. Environmental Receptors: None
2.15. Passive Mitigation Considered: None
2.16. Graphics file name: (optional) if submitting GIF or JPEG files illustrating each release scenario. None
Toxics: Alternative Release
3.1.a. Chemical: Anhydrous Ammonia
3.1.b. Percent Weight of Chemical in Mixture: Not Applicable
3.2. Physical State: Gas liquified by pressure
3.3. Results Based On: Cameo
fer Hose Failure
3.5. Quantity Released: 11,908 pounds from a 2 inch hose
3.6. Release Rate: 5,954 pounds/minute
3.7. Release Duration: 2 minutes
3.8. Wind Speed: 3 meters/second
3.9. Stability Class: D
3.10. Topography: Urban
3.11. Distance to Endpoint: .41 Miles
3.12. Residential Population within Endpoint Radius: 2,500 (rounded to second digit).
3.13. Public Receptors:
3.14. Environmental Receptors: None
3.15. Passive Mitigation Considered: None
3.16. Active Mitigation Considered:
Excess Flow Valve
Emergency Shutdown System
3.17. Graphics file name: (optional): None
Flammables: Worst Case - Section 4 - Not Applicable
Flammables: Alternative Releases - Section 5 - Not Applicable
Five Year Accident History
No reportable accidents for this covered process within the last 5 years.
Prevention Program - Section 7 - Program 3 - Not Applicable
Prevention Program - Pro
8.1. NAICS Code for Process: 42291
8.2. Chemical Name(s): Anhydrous Ammonia
8.3. Safety Information: Following is,
(1) Material Safety Data Sheet(s) for Anhydrous Ammonia
(2) Maximum Inventory Storage Capacity for Anhydrous Ammonia (Anhydrous Ammonia - 56% filling density).
(3) Safe upper pressure design of tank, pipes, and hoses.
(4) Equipment and tank design specifications.
(5) Codes and Standards used to design, build, and operate the process.
(6) ASME, OSHA 1910.111
8.3.a. Most recent review or revision of Safety Information date: 5/1/1999
We have provided safety information concerning anhydrous ammonia; however, as previously stated. The regulated substance, Anhydrous Ammonia, is reacted with Phosphoric Acid to produce a non-hazardous fertilizer. All actions related to this processing are conducted by the owner of the mobile reactor that process this material. No employees of the J.R. Simplot Company are involved in any of this process.
All Simplot Soilbuilder em
ployees are trained under applicable OSHA regulations such as hazard communications and personal protective equipement as well as HM-126(f) under 49 CFR.
8.3.b.1-8 Federal or State regulations or Industry design codes and standards used to demonstrate compliance with safety information requirement.
OSHA (29 CFR 1910.111)
Comments (how codes and standards are being used to demonstrate compliance): _____________________________________________________
8.4. Hazard Review:
Simplot Soilbuilders at Powell have reviewed our actions in the event of an emergency related to the regulated substance of Anhydrous Ammonia. We would evacuate if necessary, notify appropriate agencies and assist with scene securement.
All hazard review for the process of the reactor is the responsibility of the company that owns this reactor. No emplo
yees of the J.R. Simplot Company operates any portion of this equipment.
8.4.a. Date of completion of the last Hazard Review or Update: 5/1/1999
8.4.b. Expected date of completion of any changes resulting from Review: Not-Applicable
8.4.c. Major Hazards:
8.4.d. Process Controls:
Alarms and Procedures
Excess Flow Device
8.4.e. Mitigation Systems:
8.4.f. Monitoring/detection Systems:
8.4.g. Changes since last Process Hazard Analysis Update:
None required/recommended (PHA Team recommends no change).
8.5. Date of the most recent review or revision of operating procedures:
Again, all operating procedures are the responsibility of the company owning this mobile reactor. No employees of the J.R. Simplot Company operate any portion of this equipment.
(a). Date of most recent review or revision of trainin
g program: 5/14/1999
(b). Type of training provided: Emergency evacuation
On the Job
(c). Type of competency testing used:
Training done by Simplot Soilbuilders cover OSHA requirements such as hazard communications, personal protective equipment, emergency response awareness and HM-126(f) under 49 CFR concerning the regulated substance, Anhydrous Ammonia.
All maintenance would be the requirement of the company that owns this reactor equipment or the rail car. Employees of the J.R. Simplot Company will not perform any maintenance on this reactor. No employee of the J.R. Simplot Company will perform any maintenance on any rail tank car containing anhydrous ammonia either. The owner of this tank car would be responsible for this function.
(a). Date of the most recent review or revision of maintenance procedures
(b). Date of the most recent equipment inspection or test
(c). Equipment that was inspected or tested: _______________________
8.8.a-b. Compliance Audits: Conducted at least every three years.
(a). Date of the most recent compliance audit: ______________________
(b). Expected date of completion of any changes resulting from the compliance audit.
8.9.a-b. Incident Investigation: For any incident which resulted in, or could reasonably resulted in a catastrophic release of a regulated substance.
(a). Date of the most recent incident investigation: __________________
(b). Expected date of completion of any changes resulting from the investigation.
8.10. Date of the most recent change that triggered a review or revision of safety information, the hazard review, operating or maintenance procedures, or training: Date: ____________________
9.1.a. Is your facility Included in the Community Emergency Response (ER) Plan: Yes
9.1.b. Does your Faci
lity have a Written Emergency Response (ER) Plan:
9.2. Does the facility ER plan include specific actions to be taken in response to an accidental release of a regulated substance(s):
9.3. Does the facility ER Plan include procedures for informing the public and local agencies responsible responding to accidental releases:
9.4. Does the facility ER Plan include information on emergency health care:
9.5. Date of the most recent review or update of the emergency response plan: Date: 5/1/1999
9.6. Date of the most recent Emergency Response Training for Facilitie's Employees: Date: 5/1/1998
9.7.a-b. Name and Phone Number of the local agency(s) with which the plan is coordinated:
Powell Fire Department Phone: 307-754-2211
9.8.a-g. Subject to other State or Federal Emergency Plan requirements:
State EPCRA Rules/Law