Hamilton Farm Bureau Cooperative, Inc. - Martn, MI - Executive Summary |
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Executive Summary 1. The Facility Policy The management, employees and board of directors of the Hamilton Farm Bureau Cooperative, Inc. are committed to the prevention of any accidental releases of anhydrous ammonia. If an accidental release should occur, the facility is prepared to work with the local fire department, or other authorities, to mitigate any release and minimize the impact of the release to people and the environment. 2. Facility Information 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 and rail, is handled and stored on-site, and is a substance regulated by the EPA requiring us to comply with the Risk Management Program. We sell anhydrous ammonia to grower customers in either 500 gallon applicators, 1,000 gallon, or 1,500 gallon nurse tanks. The customer applies the ammonia into the soil as a source of nitrogen fer tilizer for growing agricultural crops. This facility maintains approximately six 500-gallon applicators, sixty-six 1,000-gallon nurse tanks and two 1,500-gallon nurse tanks for customer delivery. Our combined storage capacity in nurse tanks is 336,240 pounds. Anhydrous ammonia is stored in two stationary storage tanks (1 @ 30,000 gallons; 1 @ 18,000 gallons) on site. The maximum storage capacity of the stationary storage tanks is 224,000 pounds of anhydrous ammonia. In addition, anhydrous ammonia may be stored temporarily in up to one rail car. The maximum quantity of anhydrous ammonia that may be stored in rail cars is 160,000 pounds. The largest single storage vessel at our facility contains 160,000 pounds. 3. The worst-case release scenario and the alternative release scenario for Anhydrous Ammonia. a. Our worst-case scenario is the loss of the total contents of the 80 ton rail car, when filled to the greatest amount allowed (85% of capacity), released as a gas over 10 minute s, resulting in total vaporization. The maximum quantity released would be 160,000 pounds. According to DEGADIS modeling, this release (distance from point of dispersion to 200 ppm) would have off-site impact. It should be noted that we have never had a release of an entire stationary anhydrous ammonia storage tank from any distribution facility. b. The most common alternative release scenario from our facility would not reach an end point off-site. The alternative release scenario modeled for the purpose 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 27,000 pounds. This release scenario (distance from point of dispersion to 200 ppm) would have off-site impact. It should be noted we have not had a release of this type from any distribution facility. 4. The accidental release prevention program. The anh ydrous ammonia system is designed, installed, and maintained in accordance with ASTM standards and ASME codes. This facility complies with the ANSI K 61.1 standards (1989), OSHA (29 CFR 1910.111), EPA's Accidental Release Prevention Rule, and all applicable federal, state, and local codes and regulations. Our ammonia 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 riser 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 according to the guideline s 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. 5. The Five-year Accident History. There have been no accidents involving anhydrous ammonia that cused deaths, property or environmental damage, evacuations on or off-site. There has been one incident that resulted in an injury to an employee. The incident involved a release of approximately 10 pounds of ammonia from a valve. As the operator opened a valve, ammonia came into contact with his skin causing a mild burn. We immediately reviewed our ammonia transfer and loading operating procedures with all employees who operate ammonia equipment to ensure safe operating procedures were being followed. 6. 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 we have an Emergency Response and Contingency Plan that complies with the requirements of OSHA (29 CFR 1910.38 and 1910.1200). The plan includes provisions for public notification, intial medical care, evacuations, and LEPC coordination. 7. 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 safe ammonia transfer and handling procedures. We will also provide regular inspection and maintenance on all of the ammonia equipment. |