PREISTER AG SUPPLY - Executive Summary |
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Executive Summary for Ammonia (Anhydrous) Storage and Retail Facilities Accidental Release Prevention and Emergency Response Policies We at Preister Ag Supply are strongly committed to employee, public and environmental safety. This commitment is demonstrated by 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. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Supplier of Ammonia to farmers and distributors of agricultural chemicals. We have 1 regulated substance present at our facility. This substance is Ammonia (anhydrous). Ammonia (anhydrous) is used for the fertilization of field crops such as corn or sorghum. The Worst Case Release Scenario(s) and the Alternat ive Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's RMP*Comp(TM). The following paragraphs provide details of the chosen scenarios. The worst case release scenario involves a catastrophic release from Anhydrous Ammonia storage and resale. In this scenario 120000 lb. of Ammonia (anhydrous) is released. The toxic liquid released is assumed to form a 1-cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. The released quantity has been limited to 45% of the maximum capacity of the source by a system of administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.7 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario for Ammonia (anhydrous) involves a release from An hydrous Ammonia storage and resale. The scenario involves the release of 40000 pounds of Anhydrous Ammonia. Toxic liquid is assumed to be released, forming a 1-cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. The release is assumed to be controlled by excess flow valve(s). These active mitigation systems have the effect of closing off flow when the flow exceeds the normal operational rates. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.6 miles. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 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. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the r elease prevention program that is in place at our stationary source. Process Safety Information Preister Ag Supply maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is the checklist method. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 6 months. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 10/05/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, Preister Ag Supply maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Preister Ag Supply 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. Refresher training is provided at least every 2 years and more frequently as needed. Mechanical Integrity Preister Ag Supply 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. Qualified personnel carry out maintenance operations with previous training in mainte nance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Preister Ag Supply to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 08/13/1999. 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 Preister Ag Supply. The most recent review was performed on September 16, 1999. 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 Preister Ag Supply conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 08/26/1999. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Preister Ag Supply promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation Preister Ag Supply 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. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Preister Ag Supply has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. Five-year Accident History Preister Ag Supply has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release preventio n policies, only one accidental release has occurred during this period. The one accidental release of a regulated substance from our facility within the last 5 years took place on 04/10/1997 and involved Ammonia (anhydrous). No deaths or injuries occurred as a result of this accident, onsite or offsite. Emergency Response Plan Preister Ag Supply carries a written emergency action plan to deal with accidental releases of hazardous materials. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. We are part of the Platte Co. LEPC (Local Emergency Planning Committee) with which emergency response is coordinated. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention p rogram. Improved lighting at the unloading and transfer sites, expanded operating area for equipment, and some new equipment are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by January 1, 2000. |