Farmers Union Oil Company - Executive Summary
Risk Management Plan (RMP) - Ammonia |
Farmers Union Oil Company
Lawton, North Dakota
1. Accidental Release Prevention and Emergency Response Policies
We at Farmers Union Oil Company in Lawton 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. If such a release does
occur, our trained emergency response personnel are at hand to control and mitigate the effects of
the release. We also coordinate our response efforts with the Lawton Fire Department, which
ides additional emergency response expertise.
2. Stationary Source and Regulated Substances Handled
Our facility's primary activities include support services for crop production. We have anhydrous
ammonia stored in a 26,000-gallon tank at our facility in Lawton (Figure 1). The maximum amount
stored is 22,100 gallons (113,726.6 pounds) at the maximum fill capacity of 85%.
3. Worst Case Release and Alternative Release Scenarios
We utilized RMP PRO for the worst case and alternate case scenarios of the required offsite
consequence analysis for our facility. The following details these scenarios.
The worst case release scenario involves a catastrophic release of the entire contents of the
anhydrous ammonia storage tank (113,726.6 pounds) in gaseous form over a 10-minute period. At
Class F atmospheric stability, 1.5 m/s wind speed, and urban topography, the maximum distance to
a toxic endpoint of 0.14 mg/L is 4.8 miles (Figure 2). The estimated population within a 4.8-mile
us of this facility is 125.
The alternative release scenario involves a release from an anhydrous ammonia product line. The
scenario involves the release of 7,616.42 pounds of ammonia in a gaseous form over a period of 30
minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14
mg/L of ammonia is 0.31 mile (Figure 3). The estimated population within a 0.31-mile radius of the
facility is 35.
4. General Accidental Release Prevention Program
Our facility has taken all the necessary steps to comply with the EPA's accidental release prevention
requirements as set forth in 40 CFR part 68. The following sections briefly describe the elements
of the release prevention program that is in place at our stationary source.
Process Safety Information
Farmers Union Oil Company maintains a detailed record of safety information that describes the
chemical hazards, operating parameters, and equipment designs associated with all processes
cess Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are
identified and controlled effectively. Any findings from the hazard analysis are addressed in a
Farmers Union Oil Company maintains written operating procedures to ensure that activities within
our covered processes are conducted safely. These procedures address various modes of operation;
the information is regularly reviewed and is readily accessible to operators involved in the processes
Farmers Union Oil Company has a comprehensive training program in place to ensure that
employees who are operating processes are competent in the operating procedures associated with
Farmers Union Oil Company conducts documented maintenance checks on process equipment to
ensure proper operation. Maintenance checks are conducted by qualified personnel with previous
training in ma
intenance practices. Examples of process equipment that would receive maintenance
checks include: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency
shutdown systems, controls, and pumps. Any equipment deficiencies identified by the maintenance
checks are corrected in a safe and timely manner (Appendix C).
Management of Change
Written procedures are in place at Farmers Union Oil Company to manage changes in process
chemicals, technology, equipment, and procedures. Process operators, maintenance personnel or
other employees whose job tasks are affected by a modification in process conditions are promptly
notified of the modification and offered training to deal with it.
Farmers Union Oil Company routinely conducts pre-startup safety reviews related to new processes
and modifications in established processes. These reviews are conducted to confirm that
construction, equipment, and operating and maintenance procedures are suitabl
e for safe startup prior
to placing equipment into operation.
Farmers Union Oil Company conducts compliance audits on a regular basis to determine whether
the plan's provisions, set out under the 40 CFR part 68, are being implemented. Any non-
compliance issue discovered during the audit is promptly corrected.
Farmers Union Oil Company 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, particularly
information resulting from process hazard analyses.
5. Five-year Accident History
Farmers Union Oil Company has had an excellent record of preventing accidental releases over the
last 5 years. Due to our stringent release prevention policies, no accidental r
elease has occurred
during this period.
6. Emergency Response Plan
Farmers Union Oil Company maintains 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, and notification of local emergency response agencies and
the public (Appendix A).