Helena Chemical Company, Merkel Facility - Executive Summary
The Helena Chemical Company Merkel Facility has submitted this electronic RMP in compliance with the provisions of the Clean Air Act 112(r) as codified by the U.S. Environmental Protection Agency at 40 CFR Part 68. The processes described in this RMP have not yet been constructed at the time this plan was prepared, but will be constructed in the near future. Standards codified by the Occupational Safety and Health Administration at 29 CFR 1910.119 are not applicable to the operations at this facility because the facility is operated as a retail operation and is exempt from the OSHA standards. This electronic submittal provides conservative estimates of the offsite consequences of an accidental release of anhydrous ammonia from the Merkel Facility located at 226 County Rd. 287, Merkel, TX 79536. The electronic RMP summarizes the policies and procedures implemented by the Merkel Facility to minimize the liklihood of an accident. The electronic RMP also summarizes the actions that t |
he Merkel Facility has taken to ensure that a response to a release (even though a release is unlikely) will be implemented in a proper and timely manner.
Helena Chemical Company engages in the formulation, distribution, and sale of chemicals to customers, most of whom use Helena's products to support agricultural operations. The Merkel Facility is retail agricultural chemical company that operates anhydrous ammonia storage tanks. Anhydrous ammonia processes at this location include storage, loading, and unloading. Loading operations occur from rail cars and trucks to end use processes. End use processes may include fertilizer formulation and nurse tank transportation and operation.
OFF-SITE CONSEQUENCE ANALYSIS
Worst case and alternative consequence analyses were completed for the ammonia storage process. The worst case scenario release for the Merkel Facility assumed that all the contents in the largest single storage tank were released. The release was modeled as
if the ammonia tank was punctured on the side at ground level. The resulting release of ammonia was modeled as a ground level horizontal jet.
The alternative (or more likely to occur) scenario assumes a rupture of a 3-inch line caused by an impact from a vehicle or some other source on the liquid ammonia transfer line during a major loading or unloading operation. Although this event is classified as an alternative scenario, even an accident of this type is unlikely to occur due to the safety equipment (rail guards, check valves) and operating procedures that Helena uses to safeguard ammonia transfer operations.
Both the worst case and alternative scenario are overly conservative because even a 2-minute release is unlikely to occur since check valves on the system should close immediately upon increased flow resulting from the severed transfer line.
ACCIDENT PREVENTION PROGRAM
The Merkel Facility complies with U.S. EPA's accidental release prevention rule and with all applicable
state codes and regulations. The Merkel Facility RMP provides safety information relevant to the on-site ammonia processes including MSDS documentation, storage and process limits, equipment specifications, and relevant codes and standards. The Merkel Facility has conducted a hazard review to ensure that potential safety problems are identified and addressed. The Merkel Facility has developed standard and consistent operating procedures that all employees follow when working with ammonia. The Merkel Facility ensures that all of its employees working with or around ammonia participate in a training program. The training program teaches employees how to avoid and respond to accidents. Helena Chemical Company has also established integrated operation and maintenance procedures, inspection requirements and schedules, compliance audits, and incident investigation procedures.
EMERGENCY RESPONSE PROGRAM
Helena Chemical Company's Merkel Facility is a non-responding facility. Helena ha
s coordinated emergency response activities with its local emergency response agency.
FIVE YEAR ACCIDENT HISTORY
Anhydrous ammonia operations at the Merkel Facility are new, thus, there have been no on-site deaths, injuries, or significant property damage; or off-site deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place, in the past five (5) years.
The Risk Management Plan implemented by Helena Chemical Company at the Merkel Facility complies with the requirements of the Clean Air Act, Section 112(r). The RMP will be updated as the Merkel Facility adds, deletes, or changes processes. The Emergency Response Program has been coordinated with the Taylor County LEPC.
NOTE: Sections 4, 5, and 7 of the standard RMP produced by EPA's RMP Submit Program are not applicable to the Merkel Facility.