Lebanon Chemical Corporation - Baltimore - Executive Summary |
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1. Accidental release prevention and emergency response policies; The owners and senior management of Lebanon Chemical Corporation established an Environmental Policy on February 12, 1993. The management and the employees of the Baltimore plant of Lebanon Chemical Corporation have been instructed in, and subscribe to this policy and are committed to the prevention of any accidental release of Anhydrous Ammonia at the Baltimore facility. If any accidental release should occur at the facility, personnel are prepared to work with the Baltimore City LEPC and the Baltimore Fire Department or other authorities to mitigate any release and minimize the impact of the release to people and the environment. 2. The stationary source and regulatory substance handled; The primary activity at the Baltimore facility of Lebanon Chemical Corporation is the manufacture of fertilizer for sale to the agriculture user (farmer) and the Lawn & Garden user (homeowner). Anhydrous Ammonia is received, generall y by Railroad Tank Cars or occasionally by tanker trucks, stored, and used from the storage tank in the manufacture of mixed-grade fertilizers for plant nutrients.The maximum quantity of Anhydrous Ammonia stored at this facility would be 290,000 pounds (130,000 pounds in a 30,000 gallon storage tank filled to 80% capacity, which is a facility policy, and 160,000 pounds contained in a loaded Rail Tank Car). This maximum storage would only happen in rare circumstance. 3. The Worst-Case Release Scenario and the Alternate Release Scenario; a. The Worst Case Release Scenario would be the release of the contents of Anhydrous Ammonia from a fully loaded Railroad Tank Car, released as a gas, in a ten minute period. The maximum quantity of Anhydrous Ammonia released would be 160,000 pounds, which is the capacity of the Railroad cars ordered and supplied by the vendors. The distance to an end point of 200 ppm of ammonia as determined by The Fertilizer Institute's model - Degadis is 1.22 miles. This release would affect 10 residents and would affect Industrial Major Commercial and Office receptors and a National Park. The possibility of this Worst-Case Scenario occurring is extremely unlikely as the Railroad Tank car is placed in an isolated area of the facility and these Railroad Tank cars are periodically inspected according to Department of Transportation requirements. b. The Alternate Release Scenario, based on the most likely potential incident, is a release ofAnhydrous Ammonia from a break in a 2" transfer hose , during the unloading procedure, with the release discontinued in 2 minutes. The calcul ated quantity of Anhydrous Ammonia released would be 7,100 pounds. The distance to an end point of 200 ppm of ammonia as determined by The Fertilizer Institute's model Degadis is 0.56 miles. This release would not affect any residents but would affect industrial and office receptors. The possibility of this Alternate Release Scenario occurring is extremely unlikely as Baltimore personnel periodically inspect, repair, and replace involved equipment according to standard procedures as found in the "Mechanical Integrity Proceedures". 4. The General Accidental release Prevention Program; The facility has implemented the provisions of "Safety Requirements for the Storage and Handling of Anhydrous Ammonia, K-61.1" published by the American National Standard Institute, Inc.; The standard of the U.S. Occupational Safety and Health Administration (OSHA) 29 CFR 1910.111 "Storage and Handling of Anhydrous Ammonia" and OSHA 29 CFR 1910.119 Process Safety Management Standard. 5. The Five-Yea r Accident History; This facility has had no accidental releases of Anhydrous Ammonia in the last five years that have caused any deaths, injuries, or property damage on site; nor, to our knowledge, have resulted in offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 6. The Emergency Response program; This facility has: a. A written Emergency Action Plan, in accordance with OSHA standard 29 CFR 1910.38; b. Provided state and local authorities and the fire department with the emergency planning and community right-to know information as required under SARA Title III (EPCRA); c. A written response program, in accordance with the OSHA standard 29 CFR 1910.120, including pre-emergency planning and employee training. This facilitie's Emergency Response Program has been discussed with and reviewed by The Baltimore City Fire Department which annually inspects the facility. 7. Planned changes to improve safety; Safety improvement is an on-go ing process at this facility. Periodic evaluations are performed to assess the maintenance of safe practices and conditions; there are no additional specific Anhydrous Ammonia safety recommendations for implementation at this time. |