Poneto Wholesale Fertilizer - Executive Summary |
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The Andersons Poneto RMP Executive Summary Source and Product Description The Andersons Poneto Wholesale Fertilizer is engaged in the handling, storage, shipping and receiving of bulk agricultural fertilizers (liquid and granular). The facility began operations in 1976 and was purchased by The Andersons, Inc. in 1987. Key personnel at the Poneto facility are Bill Wolf - Facility Manager and Randy Grandlienard - Liquid Plant Supervisor. The facility manufacturers a liquid ammonium polyphosphate fertilizer called 10-34-0 (N-P-K analysis) which is produced by combining anhydrous ammonia, phosphoric acid and water, in a controlled environment. While the process is exothermic, the resulting heat is managed through a closed-loop process that virtually eliminates the production of a steam plume. Production rates average 27,000 tons of 10-34-0 fertilizer per year. The facility occupies approximately four acres and is situated four miles west of the intersection of State Routes 1 and 218 , on the western edge of the town of Poneto. There is one residence across the road, on the south side of 218. The town of Poneto is located on the east side of the facility, across the railroad tracks. THe RMP-regulated material involved in this fertilizer manufacturing process is anhydrous ammonia. An 18,000 gallon tank is used for bulk storage of the material. When filled to the maximum 85% capacity, this tank can hold 15,300 gallons of anhydrous ammonia. This material is a gas at ambient temperature and pressure. It is a liquid when stored under pressure inside the tanks. Anhydrous ammonia is not a poison, but it is an inhalation / respiratory hazard. Ammonia is a toxic material but it has no cumulative toxic effects on the human body. However, it is acutely corrosive when it comes in contact with mucous membranes, in particular. Anhydrous ammonia is a non-flammable gas. Summary of Major Hazards The principal causes of ammonia emergencies is ruptured hoses and defective valves. The most probable time for an exposure or release to occur will be during a transfer from a delivery unit (generally a tanker truck) to the bulk storage tanks. Flexible hoses must be connected properly. Hoses on tank trucks are date-stamped are replaced by the transporter in advance of the expiration date or when defects are observed. All transfers of ammonia are observed by Anderson personnel. Transfers from the storage tanks to the processing system occur inside fixed steel pipes and are automated from the control room. No hoses are utilized in the operation. Mass meters are used to indicate the rate of flow. With elevated temperatures that occur during mid-to-late summer, the ammonia gas inside the bulk storage tank can expand, and possibly cause the relief valve to open in order to equalize the pressure inside the tank. The relief valve will reseal itself when pressure is relieved. These "events" are very short in duration - a few seconds at the most. A complete failure or burst tank is highly unlikely. The bulk storage tank was built under strict guidelines established in the ASME pressure vessel code. The tank is protected by concrete traffic barriers. All welding and structural work done on the tank or appendages are performed by certified welders. Consequences of Failure to Control the Hazards for Anhydrous Ammonia The worst case scenario for this facility was created using EPA's RMP Comp software. A complete release of the tank contents (78,795 pounds -- creating a gas / vapor cloud) in a 10 minute period, using worst case atmospheric conditions, results in a distance to endpoint of 3.30 miles. The estimated exposed population is 500 people. This distance would encompass the village of Poneto. No hospitals, prisons or sensitive environmental receptors would be affected. There are no passive mitigation systems available for this type of scenario. It is our belief that the risk of a complete release of the tank contents is infi nitesimally small. Active mitigation systems in place at this facility were designed to prevent or mitigate any attempts to empty the tank. The tank is in a protected location, and all transfer appendages are protected by concrete barriers. A more probable release situation is expressed by the alternative release scenario. We believe that a more likely release could occur from a tanker truck transfer hose failure. Prior to the excess flow valve being activated, we estimate that the maximum amount of ammonia that could escape to the atmosphere is ~ 7,789 pounds. A release of this nature would likely last for about ten minutes. Utilizing an average wind speed of 3.0 m/sec and atmospheric stability class D, the resulting distance to endpoint would be 0.20 miles. In this more realistic scenario, the only potential exposed receptors would be the residences directly across the railroad track from the facility. Explanation of How Hazard Releases are Prevented. Passive mitigation r efers to equipment, devices, or technologies that function without human, mechanical or other energy input. Passive mitigation systems in place at the Poneto facility are: ? Secondary containment dikes that meet or exceed regulatory standards. ? Bulkhead breakaway units located on the connection point to the storage tanks. If a truck driver were to drive off without disconnecting from the tank, the steel structure would cause the hose to break at the outside of the connection point. At this point, active mitigation would take effect and an excess flow valve, just to the inside of the breakaway would prevent the tank from emptying to the atmosphere. Active mitigation refers to equipment, devices or technologies that require human, mechanical or other energy input to function. Active mitigation systems in place at the Poneto facility are: ? Excess flow valves are located on all outgoing liquid and vapor valves on the storage tanks. They close automatically if the volume of gas or liquid flowing through the line exceeds the normal flow rate. They won't reopen until the downstream shutoff valve is closed and the pressure equalizes on both sides of the valve seat. Two principal causes of the excess valve closing are a ruptured hose or a broken pipe or shutoff valve downstream that is opened too quickly. ? Back check valves are located on the unloading lines of delivery trucks and are designed to ensure that the flow goes in one direction only. This prevents anhydrous ammonia from flowing to a transport tank from the storage tanks. ? Pressure-relief valves (four) are located on the top of the bulk storage tank, fixed steel piping and on the vaporizer to relieve pressure that is too great. This can be caused by elevated temperatures in the summer or overfilling. They open directly to the atmosphere at 250 psig and close when the pressure inside the tank drops below this pressure. ? An emergency shutoff switch, located along the side of the ammonia storage tank activates the emergency shutoff valves on the discharge side of the ammonia pump. ? An ample supply of water is available near the bulk storage tank from a nearby water tank and a nearby 25,000 sq. ft. pond to help knock down a vapor cloud. There is also an adjacent water well. ? Spill control kits are located at the facility and include sorbent material, shovels, PPE and disposal containers. ? Operator and truck drivers supervise all anhydrous transfers to and from the bulk storage tank Prevention Program Preventive maintenance is an integral piece of this facility's hazard management program. All hoses, tanks, valves and storage units are inspected at least monthly, and usually daily during the production season. A good PM program is our strongest defense against a release of anhydrous ammonia. All hose replacements are documented in the maintenance files. Records of all maintenance tasks performed on the tank or appendages are also on file. This facility uses Paul Akars, Inc ., an Indianapolis, Indiana firm, for all welding and construction performed on the tank. The Poneto processing plant undergoes a complete ammonia inspection by a third party at least every four years. See "Steps Taken to Address Hazards" for more information on prevention measures and identification. Management System (see "Steps Taken to Address Hazards") Equipment maintenance All equipment maintenance is formally documented. See the "Prevention Program" section for further explanation. Training All employees receive annual training on anhydrous ammonia, emergency action plan and spill procedures, and hazard communication. Documentation and attendance rosters are on file at the facility. Contractors All contractors receive a "contractor safety review" prior to performing work at the facility. During this review, they are informed of any potential hazards at the facility, emergency procedures, site-specific safety rules and the ability to request an MSDS for any product a t any time. Steps Taken to Address Hazards The Andersons Poneto Wholesale Fertilizer facility has many systems in place for hazard assessment and mitigation. The Safety Department performs annual hazard management audits at the facility. The audits include a physical walk through of the entire facility and a review of all EPA, OSHA and DOT paperwork and training documentation. Action items are noted and recommendations are made. The audits consist of five major topical areas: Safety & Health, Environmental, Fire Protection & Security, Administrative and Housekeeping & Storage. Issues are documented in a report and sent to the facility manager and upper management. Updates on action item status must be made within 30 days and 6 months of receiving the report. A Process Hazard Analysis (PHA) has been made at the Poneto facility, as part of their Process Safety Management Program. The analysis was performed in 1996 and will be updated every 3 years, or as changes in the process are made. A full PHA assessment will be conducted at Poneto in 1999. PHA's were performed using the "what-if" technique and analyzed all aspects involved in the production of 10-34-0 fertilizer. The evaluation team included representatives from the corporate Safety Department, group Management and Operations employees. Each "what-if" situation was discussed and possible causes were listed. Unless otherwise noted, situations were evaluated under the assumption that safety controls were in effect. Potential consequences were listed and given a rating of 1 - 5 for severity and likelihood; with "1" being the worst case and "5" being "none or very low". When plotted, a risk value was assigned from 1 - 10; again with "1" being the worst and most critical item and "10" being of least consequence. Finally, results were evaluated and prioritized. Formal investigations are performed for all environmental or safety incidents. Documentation is kept on file at the facility and the corpor ate Safety Department. A formal Management of Change (MOC) system is administered by the Engineering Department. A form is filled out whenever a change is made to the 10-34-0 production system. Forms are routed from the facility operator to the Engineering and Safety Departments for review and remarks. A copy of the completed is form is sent back to the operator. Monthly Safety Committee meetings allow employees to discuss any concerns they may have with the operation of the facility. Issues are documented and assigned to employees for follow-up. Records of all meetings are kept at the facility. The Poneto facility also participates in a "best practices" task force meeting at least three times a year to discuss production and quality issues, as well as training and methods for continuous improvement of the process. Operators and management, together with representatives from the Safety and Engineering Departments spend the day discussing any and all issues related to the produc tion of 10-34-0 and aqua ammonia. Response Action in the Event of a Release In the event of a burst hose or defective valve, employees are instructed to shut down the conversion process and, if possible, approach the shutoff valve from upwind and attempt to turn it off. For an uncontainable release, employees will immediately call the police and fire department or other first responders, as appropriate. All employees, customers and contractors are to be evacuated to an upwind location. Once the response team has arrived, we will work in concert with them to close the valves between the tank and the leak. In the meantime, a steady spray of water will deluge the ammonia gas plume and knock it to the ground, while chemically binding any free ammonia. The employees are instructed to make emergency phone calls in this order: the facility Manager, 911, the corporate Safety Department emergency phone number, the Indiana Emergency Response hotline and the Indiana Department of Environm ental Management emergency phone number. All applicable contact names and numbers are found in the facility spill and emergency response plan. Communication procedures with responders The local fire department is invited to tour the Poneto facility on an annual basis. Facility management, employees and fire department personnel have jointly discussed the location of the anhydrous ammonia and response procedures on a regular basis. They know the location of all emergency shutoff valves and on-site response equipment. We believe that a strong relationship with first responders is our best defense. The LEPC and state regulatory agencies receive a copy of our hazardous materials storage information, every February, in accordance with our community right to know obligations. A copy of the Poneto Emergency Action Plan is on file with the LEPC and the local fire departments. |