SERVICE AND SUPPLY COOPERATIVE INC - Executive Summary |
|
Executive Summary for Service and Supply Cooperative Inc. New Florence MO Facility 1. Accidental Release Prevention and Emergency Response Policies We at SERVICE AND SUPPLY COOPERATIVE INC. 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. Unforeseeably, if such a release does occur, we are completely coordinated with the New Florence Fire Department which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled Our facilitys primary activities encompass RETAIL FERTILIZER and AG CHEMICAL SALES. We have 1 regulated substances present at our facility. These substances is Anhydrous Ammonia. The regulated substances at our facility is used for Agricultural fertilizer. The maximum inventory of Ammonia is present at our facility in a maximum quantity of 95,000 lb.. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To evaluate the worst case scenariosand alternative cases we have used The Fertilizer Institutes' DEGADIS model for Worst-Case Ammonia Release. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Anhydrous Ammonia Bulk Plant. The scenario involves the release of 47,500 lb. of Ammonia in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance o f 1.7 miles is obtained corresponding to a toxic endpoint of 200ppm. One alternative release scenario will be submitted for each toxic substance present in Program 2 and Program 3 processes cumulatively. The alternative release scenario for Ammonia involves a release from the Anhydrous Ammonia Bulk Plant process. The scenario involves the release of 11908lb. of Ammonia in a gaseous form over 2 minutes. The release is also assumed to be controlled by active mitigation measures that include excess flow valve(s) and neutralization. Under neutral weather conditions, the maximum distance to the toxic endpoint of 200ppm of Ammonia is 1.2 miles. 4. 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. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119 . Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information SERVICE AND SUPPLY COOPERATIVE INC. 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 rountinely conducts facility inspections to ensure that hazards associated with our processes are identified and controlled efficiently. The inpections are undertaken by a team of qualified personnel with expertise in process operations and are revalidated. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, SERVICE AND SUPPLY COOPERATIVE INC. maintains written operating procedures. These pr ocedures 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 SERVICE AND SUPPLY COOPERATIVE INC. 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 yearly and more frequently as needed. Mechanical Integrity SERVICE AND SUPPLY COOPERATIVE INC. 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 operations are carried out by qualifi ed personnel with previous training in maintenance 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 SERVICE AND SUPPLY COOPERATIVE INC. 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 SERVICE AND SUPPLY COOPERATIVE INC.. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operatio n. Compliance Audits SERVICE AND SUPPLY COOPERATIVE INC. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. 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 SERVICE AND SUPPLY COOPERATIVE INC. 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 SERVICE AND SUPPLY COOPERATIVE INC. 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 facilitys 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. SERVICE AND SUPPLY COOPERATIVE INC. has a strict policy of informing the contractors of known potential hazards related the contractors work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History SERVICE AND SUPPLY COOPERATIVE INC. 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 SERVICE AND SUPPLY COOPERATIVE INC. carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 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. Bob Bishop is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitte d is true, accurate and complete. Name: J. Donald Broz Signature: Title: General Manager Date signed: 04/30/99 |