Agro Distribution, L.L.C. - Anthon, IA - Executive Summary
Agro Distribution, L.L.C. - ANTHON, IA |
Certification Statement for a Correction to the Risk Management Plan, Program 2, Anhydrous Ammonia
To the best of the undersigned's knowledge, information and belief formed after reasonable evaluation and by actual knowledge of the facility and process, these corrections and/or administrative changes are true, accurate and complete.
______________________________ Steve McElrath
Signature Print Name
EPA Facility ID# 1000 0011 4994
EXECUTIVE SUMMARY- AnhydrousAmmonia
THE ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES:
This facility complies with the 1989 ANSI K 61.1 "Safety Requirements for the Storage and Handling of Anhydrous Ammonia". In addition, it is our policy to adhere to all applicable federal, state and local laws.
Agro's Corporate M
ission states "to provide for the safety of our employees, our customers and the general public". In order to fulfill this mission, Agro provides a corporate EHS group to maintain and administer comprehensive safety and environmental programs and procedures. EHS field safety service supervisors audit and monitor facility compliance with the safety standards of the company.
All locations are required to conduct their own internal audit utilizing checklist survey forms that are reviewed regularly and updated as necessary to ensure all applicable federal state and local regulations are covered. The EHS group conducts comprehensive annual audits at every location to measure regulatory compliance including those governing the safe handling and storage of anhydrous ammonia. The field supervisors require a timely written response with the completion date of all recommendations resulting from the audits.
Each location has a "site safety coordinator" as an extension of the EHS group. These
coordinators are given training to monitor the day to day safe work activities, maintain the required regulatory record keeping, conduct monthly safety meetings, conduct employee training and act as the location's contact with the corporate EHS group. The site safety coordinators act as the location emergency contact.
A DESCRIPTION OF OUR FACILITY AND THE REGULATED SUBSTANCES HANDLED:
This facility is a wholesale farm supply distribution center. We store and distribute a wide variety of pesticides and fertilizers including anhydrous ammonia. Anhydrous ammonia is received by truck, handled and stored on-site. Ammonia is a substance regulated by the EPA requiring us to comply with the Risk Management Program. We sell anhydrous ammonia to grower customers in 1,000 gallon nurse tanks. The customer applies the ammonia into the soil as a source of nitrogen fertilizer for growing agricultural crops.
This facility maintains twenty-three (23) 1,000-gallon nurse tanks for customer delivery
. Our combined storage capacity in nurse tanks is 100,000 pounds. Anhydrous ammonia is stored in 2 stationary storage tank(s) [2 @ 12,000 gallon] on site. The maximum storage capacity of stationary storage tanks is 110,000 pounds of anhydrous ammonia. Therefore, the total facility anhydrous ammonia storage capacity for our facility is 210,000 pounds. The largest single storage vessel at our facility contains 56,000 pounds.
THE WORST CASE SCENARIO:
Our worst case scenario is the loss of the total contents of the 12,000 gallon storage tank, when filled to the greatest amount allowed (85% of capacity), released as a gas over 10 minutes, resulting total vaporization. The maximum quantity released would be 56,000 pounds. According to DEGADIS modeling, the release (distance from point of dispersion to 200 PPM) would have off-site impact. It should be noted that Agro has never had a release of an entire stationary storage tank from any distribution facility.
ALTERNATIVE RELEASE SCENARIO:
The most common alternative release scenario from our facility would not reach an end-point off-site. The alternative release scenario modeled for the purposes of this plan is a 2-minute release from a stationary storage tank representing a valve and hose failure requiring a manual shut down. The total amount of anhydrous ammonia released in this scenario would be 12,000 pounds. This release scenario (distance from point of dispersion to 200 PPM) would have an off-site impact. It should be noted that Agro has never had a release of this type from any distribution facility.
THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS:
The ammonia system is designed, installed and is maintained in accordance with ASTM standards and the ASME codes. This facility complies with the ANSI K 61.1 standards (1989), OSHA (29 CFR 1910.111), EPA's Accidental Release Prevention Rule as well as all applicable federal, state and local codes and regulations.
nia system is protected from major releases by internal excess flow valves, check valves, relief valves, manual shutoffs and emergency shutoff valves. The load-out risers used for the purpose of filling the nurse tanks are protected by excess flow valves and fill line breakaways to immediately stop the flow of ammonia if a line or a hose fails. All main storage tank valves and the riser load valves are locked when not in use.
Our ammonia system is inspected on a regular basis with maintenance and preventive maintenance scheduled and documented. Liquid and vapor valves, hoses, excess flow valves, gauges, and relief valves are replaced when necessary and/or according to the guidelines in the ANSI standards.
Training is provided to all employees at least annually, whenever there is a change in the process or whenever competency with the regulations is questioned. The training consists of classroom lecture, current videos, testing and certification and on the job training.
There has been no accidents involving anhydrous ammonia that caused deaths, injuries, property or environmental damage including evacuations on or off-site.
THE EMERGENCY RESPONSE PROGRAM:
In the event of an emergency involving our ammonia system, it is our policy to notify the local community fire department and request that they respond to the emergency. In preparation for this, we have coordinated with all of the local response agencies by providing information and facility tours to ensure that they are familiar with and properly prepared for an incident at our facility. This will help to ensure that our community has the strategy for responding to and mitigating the threat posed by an ammonia release. This complies with the requirement for our facility to be included in the community emergency response plan prepared under EPCRA and coordinated with our LEPC.
In addition, Agro has an Emergency Response and Contingency Plan for each facility that complies with th
e requirements of OSHA (29 CFR 1910.38 and 1910.1200). The plan includes public notification, provisions for initial medical care, evacuations and LEPC coordination.
PLANNED CHANGES TO IMPROVE SAFETY:
We do not plan to make any changes to the physical site. We will continue to provide our employees with ongoing annual training to ensure that they are current with all of the safe ammonia transfer and handling procedures, and provide regular inspection and maintenance on all of the ammonia equipment.