Ashby Equity Association - Executive Summary |
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Executive Summary -Ashby Equity Association (Ammonia) Ashby, MN 1. Accidental Release Prevention and Emergency Response Policies We at Ashby Equity Association 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 Ashby Fire Department which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's pri mary activities includes support services for crop production. We have Anhydrous Ammonia stored in a 26,000 gallon tank at our facility located in Ashby (Figure 1). The maximum amount stored is 22,100 gallons (113,726.6 lbs.) at the maximum fill capacity of 85%. 3. The Worst Case Release Scenario and the Alternative Release Scenarios To perform the required offsite consequence analysis for our facility, we utilized RMP PRO for the worst case and alternate case scenarios. 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 (113,726.6 lbs.) in gaseous form over 10 minutes. At Class F atmospheric stability, 1.5 m/s windspeed and an urban topography, the maximum distance of 4.8 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L (Figure 2). The alternative release scenario involves a release from a anhydrous ammonia product lin e. The scenario involves the release of 7995.83 pounds. of ammonia in a gaseous form over 30 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.31 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 Ashby Equity Association 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 findings related to the hazard an alysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Ashby Equity Association 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 Ashby Equity Association 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 Ashby Equity Association maintains 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 operations 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 Ashby Equity Association 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 Ashby Equity Association routinely conducts pre-startup safety reviews related to new processes and to modifications in established processes. 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 Ashby Equity Association has compliance audits conducted on a regular basis to determine whethe r 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 Ashby Equity Association 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, particularly information resulting from process hazard analyses. 5. Five-year Accident History Ashby Equity Association 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. Emergency Response Plan Ashby Equity Association carries a written emergency response plan to deal with accidental rele ases of hazardous materials. The plan addresses all aspects of emergency response including first aid and medical treatment, evacuations, and notification of local emergency response agencies and the public (Appendix A). |