Clyde Cooperative Association - Executive Summary |
EXECUTIVE SUMMARY CLYDE COOPERATIVE ASSOCIATION SALT FORK, OKLAHOMA For further information contact: General Manager Risk Management Plan - EXECUTIVE SUMMARY 1. The Facility Policy The owners, management, and employees of Clyde Cooperative Association (Salt Fork) are committed to the prevention of any accidental releases of anhydrous ammonia. If an accidental release should occur, the facility is prepared to work with the local fire company, or other authorities, to mitigate any release and minimize the impact of the release to people and the environment. 2. Facility Information 7 Anhydrous ammonia is received, stored, and distributed for direct application for crop production nutrients. 7 The maximum quantity stored would be 95,837 pounds in our two 11,000 gallon storage tanks . 3. The worst-case release scenario and the alternative release scenario. a. The worst-case release scenario would be the release of the total contents of a storage tank (or tank car) released as a g as over 10 minutes. The maximum quantity released would be 47,918 pounds, which represents the volume of the largest storage tank at 85 percent capacity as limited by design standards. The distance to the endpoint (point of dispersion to 200 ppm) is 1.50 miles. b. The alternative release scenario based on the five-year accident history (or the most likely potential incident) is a release from a break in a transfer hose. The distance to the endpoint (point of dispersion to 200 ppm) is .83 miles. 4. The accidental release prevention program The facility has implemented the provisions of "Safety Requirements for the Storage and Handling of Anhydrous Ammonia, Kk-611.1", published by The American National Standards Institute, Inc., and the standards of the U.S. Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111, "Storage and handling of Anhydrous Ammonia". 5. The Five-year Accident History a. There have been no accidental releases of anhydrous ammonia in the past five years that: 7 Have caused any deaths, injuries, or significant property damage at the facility; nor 7 To our knowledge, have resulted in offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 6. The Emergency Response Program The facility has: a. A written Emergency Action Plan, in accordance with OSHA standard, 29 CFR 1910.38; b. Provided state and local authorities the emergency planning and community right-to-know information as required under SARA Title III (EPCRA). c. A written emergency response program, in accordance with OSHA standard 29 CFR 1910.120, including pre-emergency planning and employee training. 7. Planned Changed to Improve Safety Safety improvement is an on-going process at the facility. Periodic evaluations are performed to assess the maintenance of safe conditions. There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. NH3 RISK MANAGEMENT PROGRAM CLYDE COOPERATIVE ASSOCIATION SALT FORK, OKLAHOMA TABLE OF CONTENTS SECTION 1: EMERGENCY RESPONSE Anhydrous Ammonia Accidental Release Procedures Incident Diary First Aid For Exposure To Anhydrous Ammonia Sara 304 SECTION 2: PREVENTION PROGRAM Safety Information Material Safety Data Sheets (MSDS) NH3 Hazard Review (What If) Operating Procedures For The Transfer Of Anhydrous Ammonia Training Maintenance Compliance Audits Incident Investigation SECTION 3: HAZARD ASSESSMENT Off-Site Consequence Analysis Toxic Worst Case Scenario Map Degadis Table For Worst Case Scenario Off-Site Consequence Analysis Toxic Alternative Release Scenario Map Degadis Table For Alternative Release Scenario Review And Update Documentation SECTION 4: FIVE-YEAR HISTORY OF ACCIDENTAL RELEASES History SECTION 5: MANAGEMENT SYSTEM Management System SECTION 1 EMERGENCY RESPONSE ANHYDROUS AMMONIA ACCIDENTAL RELEASE PROCEDURES CLYDE COOPERATIVE ASSOCIATION SALT FORK, OKLAHOMA 1. Notify t he emergency coordinator. 2. Remain calm, assess the situation and use extreme caution. 3. Close any valves between the tank and the source of the leak if it can be done without entering areas where there are concentrations of anhydrous ammonia. * Wind speed and direction and relative humidity will directly affect whether or not this can be done safely. 4. Secure the area. * If assistance is needed, call the fire department, law enforcement, EMS, and Triangle Insurance Company: ** Lamont Fire Department (580) 388-4466 ** Lamont Police Department (580) 388-4466 ** Pond Creek EMS (580) 532-4599 ** Triangle Insurance Company 1-800-894-5020 5. Refer to the Material Safety Data Sheet (MSDS) for anhydrous ammonia. A MSDS for anhydrous ammonia can be found in the Safety Information section of this Risk Management Plan. 6. Remove injured persons ONLY if this can be accomplished without injury to yourself or others. 7. Block off all accesses to the emergency area. 8. E vacuate people from areas that may be affected by the emergency. 9. Detour motorists from downwind areas. 10. THE FOLLOWING PROCEDURES SHOULD BE ATTEMPTED ONLY BY TRAINED PERSONNEL WHEN CLASS A HAZARDOUS MATERIALS SUITS ARE NOT AVAILABLE: * Approach the incident from upwind if possible, and use a water fog curtain as a barrier between personnel and the source of the leak. ** Personnel must wear self-contained breathing apparatus (SCBA) and protective clothing. * Close the valves between the tank and the leak to stop the flow of ammonia. ** REMEMBER: Keep the water fog curtain between the personnel and the source of the leak. * If the leak cannot be shut off by closing valves, consider positioning fire streams downwind with the nozzles set on a fog pattern to absorb the escaping ammonia vapors. ** When possible, unmanned monitor nozzles should be used when fire streams are used downwind. 11. Determine if the spill or release needs to be reported. * The spill does not need to be reported to anyone other than the employer and the Oklahoma Department of Agriculture if the following conditions have been satisfied: ** The spill was cleaned up, stored, and labeled according to the MSDS. ** The spill was contained on company premises. ** The spill did not escape into the environment, i.e. air, land and/or water. * If the above conditions are not met, use the following reporting procedures: ** Determine amount released. ** If the amount of the release is 100 pounds or more, immediate telephone communication should be made to: *** The Lamont Fire Department (580) 388-4466 *** The Grant County LEPC (580) 395-2356 *** The Oklahoma Dept. of Agriculture 1-405-521-3864 *** The State DEQ 1-800-522-0206 *** National Response Center 1-800-424-8802 * When reporting a spill or release, give the following information: ** Your name and telephone number. ** Name of the chemical. ** Explain that anhydrous amm onia is considered to be an extremely hazardous substance under Section 302 of the Emergency Planning and Community Right-to-Know Act (EPCRA). ** An estimate of the amount of the substance released into the environment. ** Location of the release. ** Time of the release. ** Duration of the release. ** The medium or media (air, water, soil, etc.) into which the release occurred. ** Measures taken. ** Any known or anticipated acute or chronic health risks associated with the release. ** The names and telephone numbers of the person or persons to be contacted for further information. * Obtain the name and title of the person and/or persons that the spill or release is reported to. 12. Clean up the spill according to the procedures listed on the Material Data Safety Data Sheet (MSDS) for anhydrous ammonia. 13. As soon as practicable after a release or spill, which requires reporting, the owner or operator shall provide a written follow-up of the emergency. * U se the Emergency Release Notification SARA 304 form. * Send copies to the LEPC, DEQ and EPA. INCIDENT DIARY Use this diary to keep track of any spill or release of hazardous materials, which may be harmful to the environment or people. This diary should be filled out regardless where the spill or release happens. This diary should be kept in the company files for 5 years after the incident. This diary may also be used at accidents and/or incidents that do not directly relate to the spill or release of hazardous materials. 1. Date of the incident 2. Time of the incident 3. Location 4. Name of the Emergency Coordinator 5. What agencies were called? Fire LEPC EMS State ERC Police DEQ Sheriff NRC OHP Poison Control Center Others: 6. Names of people who called agencies: 7. Describe any instructions that were given by the agencies that were called. 8. List actions taken as a result of recommendations made by the agencies contacted. 9. List agencies that responded to the incident and the time of their arrival. 10. Who served as the Incident Commander for the responding agencies? 11. What action was taken by the responding agencies? 12. Did you agree with the actions of the responding agencies? Yes No If no, explain your disagreement: 13. Were there any injuries? Yes No If yes, how many: 14. List the names of injured employees and give a brief description of those injuries. 15. What has been done to help prevent a reoccurrence of a similar accident? 16. Comments: 17. Signed_____________________________ Date___________________________ FIRST AID FOR EXPOSURE TO ANHYDROUS AMMONIA 1. Inhalation * If inhaled, move exposed person to fresh air at once. * If breathing has stopped, perform artificial respiration. * When breathing is difficult, properly trained personnel may assist the affected person by administering oxygen. * Get medical attention at once. 2. Eye Contact * In case of contact, immediately flush eyes with large amounts of water for at least 15 minutes. Occasionally lift the lower and upper eyelids. * Get medical attention at once. 3. Skin Contact * In case of contact, immediately flush skin with water for at least 15 minutes. * If chemical penetrates through the clothi ng, immediately remove clothing and flush skin with water. * If clothing is frozen to skin, remove only after it is completely thawed. * Do not use salves or ointments on affected areas. * Get medical attention at once. EMERGENCY RELEASE NOTIFICATION 40 CFR Part 355.40, SARA 304 Facility Name ____________________________________________________________ Facility Address __________________________________________________________ __________________________________________________________ Chemical Name _________________________ _________________________________ Extremely Hazardous Substance? Yes No _____________ Estimated Quantity Released ________________________________________________ Date & Time of Release ____________________________________________________ Duration of Release _______________________________________________________ Release Medium _________________________________________________________ Known Acute/Chronic Effects _______________________________________________ _______________________________________________________________________ Precautions taken as result of release ________________________________________ _______________________________________________________________________ Actions taken to respond to and contain release _________________________________ __ _____________________________________________________________________ Contact Person(s) and Phone Number ________________________________________ _______________________________________________________________________ Reports Made: Agency Contact Time and Date Signature _______________________________________________________________ Title _______________________________________________________________ SECTION 2 PREVENTION PROGRAM SAFETY INFORMATION 1. The equipment and tank design of this anhydrous ammonia facility is in compliance with the standards set forth by the State of Oklahoma Department of Agriculture (ODA), and the plant has met the safety inspection requirements of the ODA. 2. Codes and standards that have been used to determine the proper construction and operation of this facility include the following: OSHA 1910.111, ANSI K61.1, and ASME VIII. 3. The maximum inventory storage capacity of this facility is 22,000 gal. a. In order to prevent over pressurization of the storage tanks and the nurse tanks, the companys policy states that the tanks shall not be filled more than 85% of the total capacity. Therefore, the total capacity of the storage tanks shall not exceed 18,700 gal. b. During the off season, the company maintains a minimum inventory of anhydrous ammonia for economic and safety reasons. (1) The company strives to keep the inventory of ammonia at 20% of the total capacity of the storage tanks. 4. The upper pressure for the design of the tanks, pipes and hoses is 250 psi. The facility has a series of pressure relief valves installed on the tanks and on the piping which are designed to relieve excess pressure build-up. 5. The plant has excess flow valves built into the system, which are designed to automatically shut off the flow of product in the event of hose or pipe rupture or breakage. 6. The general manager shall update the safety information if a major change occurs that makes the information listed above inaccurate. NH3 HAZARD REVIEW What If WHAT IF EVENT SEQUENCES AND POTENTIAL MITAGATING CONSEQUENCES ACTION Tank Failure Complete loss of NH3 Comply with ANSI K-61 & OSHA requirements in o rder to minimize risk. Hose Rupture (partial) Release rate is below excess flow valve set point. Results in continuous release. Protect hoses from damage. Clean hoses when necessary. Replace hoses when necessary and/or required. Install shut-off valves and/or cable release quick shut-off valves. Hose Rupture (complete) Release rate exceeds excess flow valve setting. Results in short high quantity release. Protect hoses from damage. Clean when necessary. Replace hoses when necessary and/or required. Install shut-off valves and/or cable release quick shut-off valves. Valve Failure (partial) Continuous release of NH3 from failed valve resulting from valve seat or packing gland failure. Ensure only NH3 valves are installed. Perform preventive maintenance. Maintain spare valve and parts inventory. Valve Failure (complete) Continuous release of NH3 resulting from complete failure of a valve or a pressure relief valve (PRV). Ensure only NH3 valves are installed. Install PRV manifold , allowing PRVs to be replaced without emptying NH3 tank. Overfill Tank (PRV Release) Continuous release of NH3 vapor. Use 85% fixed liquid level gauge when filling tank. Train employees not to overfill tanks. Overfill Tank ( Tank Rupture) Complete loss of NH3 resulting from over pressurization and/or damaged tank. Use 85% fixed liquid level gauge when filling tanks. Train employees not to overfill tanks. Train employees not to fill tanks that have been damaged. Tanker Pulls Away Before Hoses Are Disconnected Hose rupture and/or valves are damaged. Excess flow valve will activate and stop the flow of NH3. If excess flow valve does not function, product will continue to release; and the flow rate will decrease as the tank pressure drops. A facility employee should monitor the NH3 transfer process. Tanker wheels should be chocked before transfer operations begin and removed only after all hoses have been disconnected. (continued) WHAT IF HAZARD REVIEW CONTINUED Nurse Tank Pull ed Away Before Hoses Are Disconnected Hose rupture and/or valves are damaged. Excess flow valve will activate and stop the flow of NH3. If excess flow valve does not function, product will continue to release; and the flow rate will decrease as the tank pressure drops. A facility employee should monitor the NH3 transfer process. The nurse tank wheels should be chocked, the hitch safety chain disconnected, and the hitch pin pulled before transfer operations begin. Once the hoses have been disconnected the hitch pin can be replaced, the safety chain re-attached, and the chocks removed. Physical Damage To Valves, Hoses, and Piping Continuous release of vapor or liquid from damaged equipment. Install safety barriers (bumper poles) to protect equipment from damage. Valve Not Properly Closed Continuous low quantity release from valve that is not properly closed (i.e. ice on valve seat). Shut valves with sufficient torque to seat properly. Corrosion Of Piping Continuous low quantity relea se from pin hole in piping. Include piping system in preventive maintenance program. Vandalism Release of NH3 from valve opened by vandal. Ensure that valves are in the off position and locked. Earthquake Or Tornado Damage to valves, piping, and tank. Ensure that all valves are in the off positions and locked when the plant is not in use. Make improvements as necessary to reduce the risk of damage. Inspect for damage and repair before operating. Flooding Floodwater could damage compressor and hydrostatic pressure relief valves. Ensure that all valves are in the off position and locked when the plant is not in use. Inspect the entire system after floodwaters have receded. Ensure that entire system is functional and free of water. Traffic Accident Damage to piping or valves from vehicle impact. Install safety barriers (bumper poles) to protect equipment from damage. OPERATING PROCEDURES FOR THE TRANSFER OF ANHYDROUS AMMONIA FILLING NURSE TANKS BY COMPRESSOR 1. Check the emergenc y first aid water container to make sure it is full of clean water. 2. Place a full-face respirator with an anhydrous ammonia canister in close proximity of the transfer procedures in case of an emergency. 3. Park the nurse tank in a position for ease of filling next to the nurse tank loading riser. a. Make sure the hoses easily reach the valves. 4. Set the brake on the towing vehicle and turn-off the engine. 5. Chock the wheels on the nurse tank. 6. Disconnect the safety tow chains from the towing vehicle. a. Always disconnect the safety chain before removing the hitch pin or the ball hitch. (1) Injuries have occurred where this procedure has not been followed. 7. Pull the hitch pin or remove the ball hitch from the ball on the towing vehicle. a. This procedure will help prevent an accidental pull away. 8. The operator shall check the condition of all of his/her personal protective equipment (PPE) before starting the transfer process. 9. The operator shall wear tight fitting safety goggles, a long sleeve shirt, and gloves made of rubber or other material impervious to anhydrous ammonia. a. It is considered a good safety practice to wear a full-face shield over the goggles to help protect the face. b. The gloves should have cuffs long enough to extend approximately half way up the forearm of the wearer. (1) The ends of the glove cuffs should be folded out approximately one half an inch to provide a catch basin to inhibit liquid from running down the wearers arms when the hands are in a position higher than the persons elbow. 10. Check the hoses for defects, and make sure the hoses are free of kinks. a. When a kink does occur, hold the valve opening away from the body, out of line of bystanders, and step over the hose twisting the body and hose simultaneously in the direction of the kink. (1) CAUTION: Never take hold of the valve hand wheel while handling anhydrous ammonia hose. (2) CAUTION: Do not attempt to throw a kink out of a hose U NWIND IT! 11. Remove the weather caps from the liquid and vapor valves on the nurse tank and check the gaskets in the valves. a. Make sure the valve gaskets are in place. b. Clean dirty gaskets. c. Replace any gaskets that are worn or damaged. 12. Connect both the liquid fill hose and the vapor return hose to their respective valves on the nurse tank. a. Tighten the connections by hand. (1) CAUTION: Do not use a wrench to tighten the connections. (2) CAUTION: Never attempt to stretch a hose. Move the nurse tank closer to the riser if necessary. 13. After making the connections check to make sure all bleeder valves are closed. 14. Open the liquid and vapor hose-end valves. 15. Slowly open the liquid fill and the vapor return valves on the nurse tank. 16. Visually inspect the hose for knots or swelling and hose couplings for leaks. a. Repair leaks and replace hoses, if necessary, before proceeding with the loading of the nurse tank. (1) CAUTION: If a fitting leak s and cannot be tightened by hand, shut off the hose-end valve and the nurse tank valve. Open the bleeder valve to relieve the pressure trapped between the two valves. Then disconnect the hose, determine the cause of the leak, and correct the situation. 17. Slowly open the liquid and vapor valves on the nurse tank riser. a. CAUTION: Opening the liquid valve from the storage tank too rapidly may cause an excess flow valve to close. (1) Should the excess flow valve close, it may be opened by closing the liquid valve on the riser for about one minute or until an audible click is heard. Now slowly open the liquid valve. 18. Open the vapor valve on the storage tank. 19. Set the 4-way valve to pull vapor from the nurse tank into the storage tank. a. NOTE: Adjust any by-pass or manifold valve in the system so that the vapor will travel to the storage tank from the compressor. 20. Observe the gauges on the compressor. Three conditions can exist; they are handled as follows: a. Wh en there is equal pressure on each gauge, open the liquid valve on the storage tank and start the compressor. b. If the pressure is higher on the storage tank gauge, open the liquid valve on the storage tank and allow the ammonia to flow until the difference in pressure is not more than 5 to 10 pounds. Start the compressor. Maintain sufficient pressure differential to ensure a steady flow of liquid ammonia. c. If the pressure in the nurse tank is higher than in the storage tank, equalize the vapor pressure in the two tanks, open the liquid valve on the storage tank, and start the compressor. Maintain a sufficient pressure differential to ensure a steady flow of liquid ammonia. 21. Partially open the fixed liquid level gauge on the nurse tank until you hear vapor escaping. a. This gauge should remain partially open during the filling operation until a white fog appears which indicates that the proper liquid level has been reached. (1) CAUTION: Do not overfill the nurse tank. (2) CAUTION: Never leave a nurse tank while it is being filled. 22. Once the tank has reached the proper liquid level, close the liquid hose-end valve immediately. 23. Close the fixed liquid level gauge. 24. Stop the compressor. 25. Close the nurse tank liquid fill and vapor return valve on the nurse tank. 26. Close the vapor hose-end valve and close the liquid and vapor valves on the nurse tank riser. 27. Open the bleeders on the hose-end valves (both liquid and vapor) to relieve the pressure on the valve couplings. 28. When the pressure has been relieved, disconnect the hoses and replace the weather caps on the nurse tank valves. 29. Place the hoses on the rack. a. CAUTION: Handle each hose by the valve body, not the valve wheel. Keep the open end away from the body and out of line of bystanders. 30. Make sure the liquid transfer hose used to fill the applicator is secure and both valves are closed. 31. Re-connect the hitch and fasten the safety chain to the towing veh icle. 32. Remove the wheel chocks. 33. Inspect the nurse tank, undercarriage, hitch, tires, loadout hose, etc. for any damage and perform any necessary maintenance to ensure the tank is safe for delivery. 34. Make sure the first aid water container on the nurse tank is full of clean water. 35. If you are going to leave the plant unattended, be sure to lock all valves, the pump cabinet, and electrical disconnect switches. 36. Weigh the tank. 37. The tank is now ready for delivery. OPERATING PROCEDURES FOR THE TRANSFER OF ANHYDROUS AMMONIA FILLING NURSE TANKS BY LIQUID PUMP 1. The procedures for filling a nurse tank by liquid pump is similar to the procedures for filling a nurse tank by a compressor. a. The main difference is that when the tank has reached the proper liquid level you need to follow these procedures: (1) Stop the pump. (2) Close the liquid riser valve. (3) Close the 85% fixed liquid level gauge. (4) Continue with procedures from the compressor procedur es. OPERATING PROCEDURES FOR THE TRANSFER OF ANHYDROUS AMMONIA FILLING THE LAST NURSE TANKS BY LIQUID PUMP 1. At the close of the day or if filling operations are to be discontinued for several hours, the following procedures should be followed once the nurse tank has reached the proper liquid level: a. Stop the pump immediately. b. Close the liquid and vapor valves on the riser. c. Lift the liquid hose connected to the nurse tank liquid fill valve and drain the liquid ammonia into the nurse tank. d. Close the liquid hose-end valve and the liquid fill valve on the nurse tank. e. Close the vapor hose-end valve and the vapor return valve on the nurse tank. f. Open the bleeders on the nurse tank valves to relieve the pressure on the valve couplings. g. Disconnect both hoses and place them on the riser rack. h. Replace the valve weather caps. i. Close all liquid and vapor valves on the storage tank. j. Lock all valves, the pump cabinet, and electrical disconnect switches. OPERATING PROCEDURES FOR THE TRANSFER OF ANHYDROUS AMMONIA UNLOADING TANK CARS BY COMPRESSOR Railroad tank cars are equipped with two valve connections located in the dome on top of the car. The two liquid valves are positioned inside the dome in line with the length of the car. The vapor valves inside the dome are located at a 90-degree angle to the axis of the car. 1. Check the emergency first aid water container to make sure it is full of clean water. 2. Place a full-face respirator with an anhydrous ammonia canister in close proximity of the transfer procedures in case of an emergency. 3. Spot the tank car correctly in relation to the unloading riser. 4. Set the hand brake on the railroad car. 5. Chock the wheels on the tank car. 6. Set up the STOP TANK CAR CONNECTED sign on the siding at least 25 feet form the end of the car nearest the switch. a. If the siding has two openings to the main line, a sign is needed at each end. 7. The operator shall check the condi tion of all of his/her personal protective equipment (PPE) before starting the transfer process. 8. The operator shall wear tight fitting safety goggles, a long sleeve shirt, and gloves made of rubber or other material impervious to anhydrous ammonia. a. It is considered a good safety practice to wear a full-face shield over the goggles to help protect the face. b. The gloves should have cuffs long enough to extend approximately half way up the forearm of the wearer. (1) The ends of the glove cuffs should be folded out approximately one half an inch to provide a catch basin to inhibit liquid from running down the wearers arms when the hands are in a position higher than the persons elbow. 9. Check the hoses for defects, and make sure the hoses are free of kinks. 10. Place the tools, tank car nipples and hose ends on the deck of the tank car. a. NOTE: If there is no loading riser platform to permit direct access to the platform around or adjacent to the tank car dome or if the riser platform is too low or far away, the operator should never attempt to carry the nipples, the hoses or most tools while he/she is climbing the ladder on the tank car. (1) Several loose items, such as the nipples, tools, etc. may be placed together in a bucket and hoisted up to the dome by using a rope. (2) The rope should also be used to lower these items back down once the job is complete in order to help prevent damage to them from tossing. 11. Remove the pin from the tank car dome and open the cover. 12. Inspect the interior of the dome. a. If there is a leak, put on a gas mask and try to determine the cause. (1) Most leaks are small and can be stopped. (2) If the leak is excessive, call the supplier for instructions. b. CAUTION: Always keep your head and body out of line of the safety relief valve, which is situated in the center of the dome. 13. Remove the plugs from the valve openings. 14. Clean the treads on the tank car nipples, apply thread compound, and s crew the nipples into the valves. a. Do not cross thread the nipples. b. Tighten by hand as much as possible; then tighten with a pipe wrench. 15. Connect the liquid hoses to the nipples in the tank car liquid valves and the vapor hose to the nipple in the tank car vapor valve. 16. Make sure the bleeder valves are closed. 17. Open the tank car liquid valves very slowly just enough to pressurize the hose. 18. Check the liquid hoses and all the connections for defects and/or leaks. a. Defective hoses and leaking connections shall be repaired before proceeding with the unloading procedures. 19. If no defects or leaks are apparent, slowly open both tank car liquid valves. a. CAUTION: Opening the liquid valve from the storage tank too rapidly may cause an excess flow valve to close. (1) Should the excess flow valve close, it may be opened by closing the liquid valves on the tank car for about one minute or until an audible click is heard. Now slowly open the liquid valve. 20 . Follow the same procedure for the vapor line. 21. Open the liquid valve slowly on the tank car unloading riser. 22. Open the vapor valve on the tank car riser. Check the pressures on the tank car and the storage tank. 23. CAUTION: As the lines are opened, recheck all hoses, nipples and connections for defects and leaks. 24. Open the vapor valve on the storage tank. 25. Slowly open the liquid valve on the storage tank. 26. Observe the liquid level gauge on the storage tank. a. Check this gauge from time to time while filling the storage tank. b. CAUTION: Do not overfill the tank. 27. Set the 4-way valve for unloading into the proper storage tank. 28. Observe the gauges on the compressor. Three conditions can exist: a. If the pressure is higher on the railroad tank car than on the storage tank, as indicated by the gauges on the compressor, allow the liquid to flow into the storage tank. When the pressure differential between the tank car and the storage tank is 5 to 1 0 pounds, start the compressor. Maintain a sufficient pressure differential to ensure a steady flow of liquid ammonia. b. When the pressure on the railroad tank car is equal to the pressure on the storage tank, start the compressor. Maintain a sufficient pressure differential to ensure a steady flow of liquid ammonia. c. If the pressure on the storage tank is higher than the tank car, equalize the vapor pressure on the two tanks, and start the compressor. Maintain a sufficient pressure differential to ensure a steady flow of liquid ammonia. d. CAUTION: (1) If the gauge on the suction side of the compressor drops to zero, stop the compressor and determine the cause. (a) It could be the liquid trap is full of liquid or a closed valve on the suction side. * Follow the trouble shooting instructions of the compressor manufacturer. (2) Do not overfill the tank. (a) Observe the variable liquid level gauge, as well as the fixed liquid level gauge from time to time. 29. Do not try to unload the ammonia too fast or the excess flow valves in the tank car will close and stop the unloading operation. a. If this should happen, it will be indicated by no flow of liquid through the unloading line flow indicator, if there is one, or by a noticeable increase in the discharge pressure at the compressor. (1) If this should happen, stop the compressor, close the liquid valves on the tank car for about one minute or until a fairly audible click is heard, indicating that the excess flow valves have opened. b. Now open the liquid valves slowly and resume the unloading of the tank car. c. A pressure differential of 10-20 psig should normally be sufficient to unload a tank car fast as is possible. 30. Continue unloading operations until the liquid transfer is completed. 31. There are several ways to determine when the tank car is empty: a. The liquid hose will start to surge. b. The pressure gauges on the compressor will equalize. c. The liquid level gauge in the st orage tank will bounce if it is of the float type due to the bubbling of vapor up through the liquid ammonia. d. The final check is to open the sample valve in the tank car dome. (1) If the material escaping is not readily visible, all of the liquid has been unloaded from the tank car. (2) If a heavy white fog appears, the car still contains some liquid ammonia. (a) In this case, continue the operation of the compressor with all of the valves set for unloading and recheck the sample valve from time to time until there is no longer evidence of liquid in the tank car. 32. Shut off the compressor. VAPOR RECOVERY FROM THE TANK CAR 1. With the compressor stopped, close the liquid valve on the tank car riser and on the tank car. 2. Make sure the vapor valves on the tank car riser and on the tank car are fully open. 3. Close the valve in the vapor lines entering the storage tank. 4. Open the valve in the vapor recovery line entering the liquid line that leads to the storage tank. 5 . Change the 4-way valve on the compressor to pull the vapor from the tank car and force it into the liquid line entering the storage tank. 6. Start the compressor. 7. Shut off the compressor when the pressure in the tank is reduced to about 40 psig. 8. Close the valve in the vapor recovery line entering the liquid line that leads to the storage tank. 9. Close the liquid valve on the storage tank. 10. Close the vapor line on the tank car riser. 11. Close the vapor valve on the tank car dome. 12. Relieve the pressure on the hoses leading from the tank car riser to the tank car by opening the bleeder valves. 13. When there is no longer pressure on the hose connections, disconnect both the liquid and vapor lines. 14. Remove the nipples from both the liquid and vapor valves and replace the valve plugs. a. Be sure the slip tube gauge cover is in place. 15. Close the tank car dome cover. 16. Place the locking pin in place. 17. Remove the hose ends, the car nipples, and the to ols from the deck of the car. 18. Place the hoses on their respective racks. 19. Store the car nipples and tools. 20. Remove the wheel chocks. 21. Remove the STOP TANK CAR CONNECTED sign(s). 22. Schedule the railroad car immediately to the destination indicated on the waybill. OPERATING PROCEDURES FOR THE TRANSFER OF ANHYDROUS AMMONIA UNLOADING TRANSPORT TRUCKS BY LIQUID PUMP 1. Check the emergency first aid water container to make sure it is full of clean water. 2. Place a full-face respirator with an anhydrous ammonia canister in close proximity of the transfer procedures in case of an emergency. 3. Spot the transport truck correctly in relation to the unloading riser. 4. Set the hand brakes on the transport truck. 5. Chock the wheels on the truck. 6. The operator shall check the condition of all of his/her personal protective equipment (PPE) before starting the transfer process. 7. The operator shall wear tight fitting safety goggles, a long sleeve shirt, and glo ves made of rubber or other material impervious to anhydrous ammonia. a. It is considered a good safety practice to wear a full-face shield over the goggles to help protect the face. b. The gloves should have cuffs long enough to extend approximately half way up the forearm of the wearer. (1) The ends of the glove cuffs should be folded out approximately one half an inch to provide a catch basin to inhibit liquid from running down the wearers arms when the hands are in a position higher than the persons elbow. 8. Check the hoses for defects, and make sure the hoses are free of kinks. 9. Connect the liquid hose to the transport liquid valve and to the liquid valve of the plant transport unloading connector. 10. Connect the vapor hose to the vapor valve on the transport truck and to the vapor valve on the plant truck transport connector. 11. Open the liquid and vapor valves on the storage tank. 12. Open the valve on the storage tank connecting the by-pass line to the spring-load ed by-pass valve on the pump. 13. Observe the liquid level gauge on the storage tank. a. This gauge should be checked from time to time while filling the storage tank. (1) Caution: Do not overfill the tank. 14. Open the liquid and vapor valves on the plant transport connections. 15. Visually inspect the hose for knots or swelling and hose couplings for leaks. a. Repair leaks and replace hose, if necessary, before proceeding with the unloading of the transport truck. 16. Slowly open the liquid valve on the tank truck. a. Note: Opening the liquid valve too rapidly may cause the excess flow valve to close. 17. Observe the pressures on the storage tank and the tank truck. Three conditions can exist. They are handled as follows: a. If the pressure in the tank truck is considerably higher, allow the pressure to force the liquid ammonia into the storage tank until there is a 5 to 20 pound pressure differential. Open the vapor valve on the transport truck and start the pu mp. b. If the pressure is higher in the storage tank than in the transport truck, open the vapor valve on the transport truck and allow the pressure to equalize. Then start the pump. c. If the pressures in the two tanks are nearly equal, open the vapor valve on the transport truck and start the pump. 18. Never leave the area while filling a tank. 19. Check the progress of unloading from time to time by observing the liquid level gauges on the transport truck and the storage tank. 20. If there is a flow indicator in the liquid line, this will aid I determining if the transport truck is empty. 21. Positive indication of complete removal of liquid ammonia is to open the bleeder valve on the plant liquid transport connector or the transport truck liquid hose: a. If the bleeder spews liquid ammonia and a white fog appears, continue unloading operations. b. If only ammonia vapor is released from the bleeder valve, the transport is empty. 22. Stop the pump. 23. Close the fixed liq uid level gauge on the storage tank. 24. Close the liquid and vapor valves on the storage tank. 25. Close the valve on the storage tank connecting the by-pass line to the spring-loaded by-pass valve on the pump. 26. Close the liquid and vapor valves at the plant transport connections. 27. Close the liquid and vapor valves on the transport truck. 28. Open the bleeder valves on the hose connections and bleed down both the liquid and vapor hoses. 29. Disconnect the hoses. 30. Remove the wheel chocks from the transport truck wheels. 31. The unloading has been completed. TRAINING 1. The company shall ensure that each present or newly assigned employee has been trained or tested competent in the operating procedures that pertain to their duties. 2. The training shall consist of the following: a. An overview of the process and operating procedures. b. Specific safety and health hazards. c. Emergency operations including shutdown. d. Safe work practices applicable to the em ployees job tasks. 3. Employees shall receive training when any of the following apply: a. The employee is newly assigned to the facility. b. When operating procedures or processes change. c. Refresher training shall be provided to each employee at least every three years, and more often if necessary, to ensure that the employee understands and adheres to the current operating procedures of the process. MAINTENANCE 1. Employees shall implement and follow procedures to maintain the on-going mechanical integrity of the equipment recommended by the equipment vendor. Procedures found in Federal or state regulations or industry codes may also be used as the basis for stationary source maintenance procedures. 2. Each employee involved in maintaining the on-going mechanical integrity of the process equipment shall be trained on the following: a. How to perform job tasks in a safe manner. b. The hazards of the process. c. How to avoid or correct unsafe conditions. d. T he procedures applicable to the employees job tasks. 3. Any maintenance contractor shall ensure that each contract maintenance employee is trained to perform maintenance procedures. 4. The general manager shall ensure that inspections and/or tests are performed on the process equipment. a. Inspections and testing shall follow recognized and generally accepted good engineering practices. b. The frequency of the inspections and tests shall be consistent with applicable manufacturer recommendations, industry standards and codes, good engineering practices, and prior operating experience. COMPLIANCE AUDITS 1. The general manager shall certify that the company has evaluated compliance with the provisions of the Risk Management Plans (CCA 112(r)) at least every three years to verify that the procedures and practices developed under the rule are adequate and are being followed. 2. The compliance audit shall be conducted by at least one person knowledgeable in the process. 3. The ge neral manager shall develop a report of the audit findings. 4. The general manager shall promptly determine and document an appropriate response to each of the findings of the compliance audit and document that deficiencies have been corrected. 5. The general manager shall retain the two most recent compliance audit reports. 6. The following types of inspections may be used to help re-enforce the compliance audit procedures: * In-house inspections: ** Daily, weekly, monthly, annual. *** Check-off sheets. * State Department of Agriculture inspections. * State or Federal Environmental Agency inspections. * Any other inspections or audits that would apply to this area of concern. INCIDENT INVESTIGATION 1. The general manager shall investigate each incident, which resulted in, or could reasonably have resulted in a catastrophic release. 2. An incident investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident. 3. A summary shall be prepared at the conclusion of the investigation, which includes at a minimum: * Date of the incident. * Date investigation began. * A description of the incident. * The factors that contributed to the incident. * Recommendations resulting from the investigation. 4. The general manager shall promptly address and resolve the investigation findings and recommendations. * Resolutions and corrective actions shall be documented. 5. The findings shall be reviewed with all affected personnel whose job tasks are affected by the findings. 6. Investigation summaries shall be retained for five years. 7. The Incident Diary, which is found in the Emergency Response section of this document, can be a good resource for gathering information during an incident investigation. SECTION 3 HAZARD ASSESSMENT HAZARD ASSESSMENT OFFSITE CONSEQUENCE ANALYSIS TOXIC WORST CASE SCENARIO 1. Chemical name: * Anhydrous Ammonia 2. Physical state: * Gas 3. Results based on: * Degadis Model 4. Scenario: * Toxic gas release 5. Quantity: * 11,000 gal. 6. Amount released: * 47,918 lbs. 7. Release rate: * 4,791 lbs./min. 8. Release duration: * 10 min. 9. Wind Speed: * 1.5 m/sec. 10. Stability Class: * F 11. Topography: * Rural 12. Distance to endpoint: * 1.5 miles 13. Residential population: * 20 people 14. Public receptors: * Office Building, Residents 15. Environmental receptors: * None Observed 16. Passive mitigation: * None DEGADIS TABLE 1 TFI Worst Case Anhydrous Ammonia Release: Summary of Results Distance to 200 ppm, miles, for Roughness: Amount Released (lb) Rural Agricultural Urban 10,000 0.72 0.48 0.31 20,000 0.99 0.65 0.43 30,000 1.19 0.80 0.53 40,000 1.36 0.90 0.61 50,000 1.50 1.01 0.67 60,000 1.63 1.10 0.74 70,000 1.76 1.17 0.80 80,000 1.89 1.24 0.83 90,000 2.00 1.31 0.89 100,000 2.10 1.37 0.92 110,000 2.22 1.44 0.98 120,000 2.32 1.48 1.02 130,000 2.41 1.54 1.06 140,000 2.50 1.59 1.10 150,000 2.59 1.65 1.13 160,000 2.66 1.69 1.18 170,000 2.73 1.79 1.21 HAZARD ASSESSMENT OFFSITE CONSEQUENCE ANALYSIS TOXIC ALTERNATIVE RELEASE SCENARIO 1. Chemical name: * Anhydrous Ammonia 2. Physical state: * Gas 3. Results based on: * Degadis Model 4. Scenario: * Transfer hose failure 5. Quantity released: * 11,908 lbs. 6. Release rate: * 5,954 lbs./min. 7. Release duration: * 2 min. 9. Wind Speed: * 3.0 m/sec. 10. Stability Class: * D 11. Topography: * Rural 12. Distance to endpoint: * 0.83 miles 13. Residential population: * 5 people 14. Public receptors: * Office Building, Residents 15. Environmental receptors: * None Observed 16. Passive mitigation: * None 17. Active mitigation: * Excess flow valves & pressure relief valves Degadis Table II TFI Alternate Case Release of Anhydrous Ammonia: Pipe Leaks at 3 m/s Wind Speed, D Stability: Summary of Results Nominal Pipe Diameter Inches Release Rate Lb/min Mass Released Lb* Distance to Threshold, miles, for Roughness: Rural Agricultural Urban 1 1,450 2,901 0.47 0.32 0.22 1.5 3,563 7,127 0.68 0.48 0.33 2 5,954 11,908 0.83 0.60 0.41 3 13,319 26,638 1.14 0.83 0.59 4 23,182 46,364 1.45 1.04 0.75 * Assumes release is stopped through human intervention after 2 minutes REVIEW AND UPDATE 1. The general manager shall review and update the offsite consequence analyses at least once every five years. 2. If changes in processes, quantities stored or handled, or any other aspect of the stationary source might reasonably be expected to increase or decrease the distance to the endpoint by a factor of two or more, the general manager shall complete a revised analysis within six months of the change and submit a revised risk management plan. DOCUMENTATION 1. The general manager shall maintain the following records on the offsite consequence analyses: a. For worst-case scenarios, a description of the vessel and substance selected as a worst case, assumptions and parameters used, and the rationale for selection; assumptions shall include the use of any administrative controls and any passive mitigation that were assumed to limit the quantity that could be released. Documentation shall include the anticipated effect of the controls and mitigation on the release quantity and rate. b. For alternative release scenarios, a description of the scenarios identified, assumptions and parameters used, and the rationale for the selection of specific scenarios; assumptions shall include use of any administrative controls and any mitigation that were assumed to limit the quantity that could be released. Documentation shall include the effect of the controls and mitigation on the release quantity and rate. c. Documentation of estimated quantity released, release rate, and duration of release. d. Methodology used to determine distance to endpoints. e. Data used to estimate population and environmental receptors potentially affected. SECTION 4 FIVE YE AR HISTORY OF ACCIDENTAL RELEASES FIVE YEAR HISTORY OF ACCIDENTAL RELEASES Due to the Clyde Coops commitment to environmental safety, the facility located at Salt Fork, Oklahoma has not experienced an accidental release in the last five years. SECTION 5 MANAGEMENT SYSTEM MANAGEMENT SYSTEM 1. The general manager shall have the overall responsibility for the development, implementation, and integration of the risk management program elements. 2. When responsibility for implementing individual requirements of this part is assigned to persons other than the general manager the positions of these people shall be documented and the lines of authority defined through an organization chart or similar document. |