Triangle Agronomy Services, LLC (Mahnomen) - Executive Summary |
|
Executive Summary - Triangle Agronomy Services, LLC Mahnomen (Ammonia) 1. Accidental Release Prevention and Emergency Response Policies We at Triangle Agronomy Services, LLC are strongly committed to employee, public and environmental safety. This commitment is an inherent part of our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also coordinated with the Mahnomen Fire Department which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities includes support services for crop production. We have Anhydrous Ammonia stored in one 30,000 gallon tank located at our facility in Mahnomen, MN (Figure 1). The maximum amount stored is 25,800 gallons (132,767 lbs.) at the maximum fill capacity of 86%. 3. The Worst Case Release Scenario and the Alternative Release Scenarios To perform the required offsite consequence analysis for our facility, we utilized RMP Comp provided by the Environmental Protection Agency (EPA). The following paragraphs provide details of the chosen scenarios. The worst case release scenario involves a catastrophic release of the entire contents of the anhydrous ammonia storage tank (132,767 lbs.) in gaseous form over 10 minutes. At Class F atmospheric stability, 1.5 m/s windspeed and urban topography, the maximum distance of 5.2 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L (Figure 2). The alternative release scenario involves a release from a anhy drous ammonia product line. The scenario involves the release of 1280 lbs. of ammonia in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.19 miles (Figure 3). 4. The General Accidental Release Prevention Program Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Triangle Agronomy Services, LLC maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes (Appendix E). Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. Any findin gs related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Triangle Agronomy Services, LLC maintains written operating procedures. These procedures address various modes of operation and the information is regularly reviewed and is readily accessible to operators involved in the processes (Appendix B). Training Triangle Agronomy Services, LLC has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes (Appendix C). Mechanical Integrity Triangle Agronomy Services, LLC carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance o perations are carried out by qualified personnel with previous training in maintenance practices. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner (Appendix D). Management of Change Written procedures are in place at Triangle Agronomy Services, LLC to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Triangle Agronomy Services, LLC. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Triangle Ag ronomy Services, LLC has compliance audits conducted on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. If the compliance audit discover non-compliances in the system, they are promptly corrected. Employee Participation Triangle Agronomy Services, LLC truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 5. Five-year Accident History Triangle Agronomy Services, LLC has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Em ergency Response Plan Triangle Agronomy Services, LLC carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan addresses all aspects of emergency response including first aid and medical treatment, evacuations, notification of local emergency response agencies and the public (Appendix A). |