Rydman & Fox Inc - Anderson Indiana - Executive Summary |
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CERTIFICATION STATEMENT FOR THE RMP PROGRAM 2 ANHYDROUS AMMONIA To the best of the undersigned's knowledge, information and belief formed after reasonable evaluation and by actual knowledge of the facility and process, the information is true, accurate and complete. ___________________________ _______________________________ Signature Print Name ___________________________ _______________________________ Title Date Date EXECUTIVE SUMMARY--AMMONIA THE ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES AT OUR FACILITY. This facility complies with the 1989 ANSI K 6.1 "Safety Requirements for The Storage and Handling of Anhydrous Am monia" In addition, it is our policy to adhere to all applicable federal, state and local laws. Rydman & Fox's Mission State " To provide for the safety of our employees, our customers and the general public". In order to fullfill this mission, Rydman & Fox, Inc. provides a corporate EHS group to maintain and administer comprehensive safety and environmental programs and procedures. EHS field safety services supervisor's audit and monitor facility compliance with the safety standards of the company. This facility maintains approximately 27, 1,000-gallon nurse tanks and 6, 1,500-gallon nurse tanks for customer delivery. Our combined storage capacity in nurse tanks is 166,800 pounds. Anhydrous Ammonia is stored in one stationary storage tank (s) [1@18,000 gallon], on site. 84,060 pounds of anhydrous ammonia is the maximum storage capacity of stationary storage tanks. In addition, anhydrous ammonia that may be stored temporarily in up to 2 rail cars. The maximum quantity anhydr ous ammonia that may be stored in rail cars is 373,600 pounds. Therefore, The total facility anhydrous ammonia storage capacity for our faciltiy are 624,000. The largest single storage vessel at our faciltiy contains 186,800 pounds. THE WORST CASE SCENARIO. Our worst case scenario is the loss of the total contents of the 40,000 gallon storage tank, when filled to greatest amount allowed (85 % capacity), released as a gas over 10 minutes, resulting total vaporization. The maximum quantity released would be 187,000 pounds. According to DEGADIS modeling, this release (distance to point of dispersion to 200 PPM) would have off site impact. It should be noted that Rydman & Fox, Inc. has never had a release of this type from our facility. ALTERNATIVE RELEASE SCENARIO. The most common alternative release scenario(s) from our facility would not reach an end-point off site. The alternative release scenario modeled for the purpose of this plan is a 2-minute release from a stationary st orage tank representing a valve and hose failure requiring a manual shut down. The total amount of anhydrous ammonia released in this scenario would be 27,000 pounds. (for rail). This release scenario (distance to point of dispersion to 200 PPM) would have off site impact. It should be noted Rydman & Fox, Inc. has not had a release of this type from our faciltiy. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC STEPS. The ammonia system is designed, installed and is maintained in accordance with ASTM standards and the ASME codes. This facility complies with the ANSI K61.6 standards (1989), OSHA (29 CFR 1910.111), EPA's Accidental Release Prevention Rule as well as all applicable federal, state and local codes and regulations. Our ammonia system is protected from major releases by internal excess flow valves. check valves, relief valves, manual shutoffs and emergency shutoff valves. The load-out risers used for the purpose of filling the nurse tanks are protected by excess flow valves to immediately stop the flow ammonia if a line or a hose fails. All of the main storage tank valves and the riser load valves are locked when not in use. Our ammonia system is inspected on a regular basis with maintenance and preventive maintenance scheduled and documented. Liquid and vapor vlaves, hoses, excess flow valves, gauges, and relief valves are replaced when necessary and/or according to the guidelines in the ANSI standards. Our location is required to conduct our own internal audit utilizing checklist survey forms that are reviewed regularly and updated as necessary to ensure all applicable federal state and local regulations ar covered. The EHS group conducts comprehensive annual audits to measure regulatory compliance including those governing the safe handling and storage of anhydrous ammonia. Our location has a 'site safety coordinator' as an extension of the EHS group. The coordinator is given training to monitor the day to day safe work activities, maintain the required regulatory record keeping, conduct regular safety meetings, conduct employee training and act as the location's contact with the corporated EHS group. The ammonia operations person acts as the location emergency contact. A DESCRIPTION OF OUR FACILITY AND THE REGULATED SUBSTANCES HANDLED. This facility is a retail farm supply distribution center as such we store and distribute a wide variety of pesticides and fertilizers including Anhydrous Ammonia. Anhydrous Ammonia is received by truck and rail, is handled and store on-site and is a regulated substance by the EPA requiring us to comply with the Risk Management Program. We sell anhydrous ammonia to grower customers in either 1,000 gallon or 1,500 gallon nurse tanks. The customer applies the ammonia into the soil as a source of nitrogen fertilizer for growing agricultural crops. Ammonia may also be used for blending into mixed grade fertilizer for crop production nutrients. Training i s provided to all employees at lease annually, whenever there is a change in the process or whatever competency with the regulations is questioned. The training consists of classroom lecture, current videos, testing and certification and on the job training. FIVE-YEAR ACCIDENTA HISTORY. There has been no accidents involving anhydrous ammonia that caused deaths, injuries, property or environmental damage including evacuations on or off site. THE EMERGENCY RESPONSE PROGRAM. In the event of an emergency involving our ammonia system, it is our policy to notify the local community fire department and request that they respond to the emergency. In preparation for this, we have coordinated with all of the local response agencies by providing information and facility tours to ensure that they are familiar with and properly prepared for an incident at our facility. This will help to ensure that our community has the strategy for responding to and mitigating the threat posed by an ammonia release. This complies with the requirement for our facility to be inlcuded in the community emergency response plan prepared under EPCRA and coordintated with our LEPC. In additon Rydman & Fox, Inc. has an Emergency Response and Contingency Plan for our facility that complies with requirements of OSHA (29 CFR 1910.38 and 1910.1200). The plan includes public notification, provisions for initial medical care, evacuations and LEPC Coordination. PLANNED CHANGES TO IMPROVE SAFETY. As the State of Indiana makes changes and follow through with the ANSI, K 61.1-1989 additional standards, our facility will also follow through with changes. We will continued to provide our employees with ongoing annual training to ensure that they are current with all of the safe ammonia transfer and handling procedures, and provide regular inspections and maintencance on all of the ammonia equipment. |