Shelton Wilder Plant Foods, Inc. - Executive Summary |
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1. MANAGEMENT SYSTEM John Wilder III heads the management team overseeing the development, implementation, and integration of the Risk Management Program Requirements (Section 112 (r) of the Clean Air Act). 2. PREVENTION PROGRAM 1.1. SAFETY INFORMATION 1.1.1. MSDS Material Data Safety Sheets are available to all employees and are located in the main hallway of the office in a plastic holder on the wall. 1.1.2. Maximum Intended Inventory The maximum intended inventory is 15,400 gallons of ammonia (65,882 pounds). 1.1.3. Safe Conditions Equipment for handling the high pressures associated with anhydrous ammonia meet the design guidelines provided by the American National Standards Institute (ANSI). Parts and contact surfaces are designed to withstand a minimum working pressure of 250 psi. Welding on ammonia piping must be done by a welder with appropriate ASME-based welding qualifications. Tanks are never filled to more than 85% full to prevent a situation of the vapor pressu re in the tank to rise to a potentially dangerous level. Anhydrous ammonia boils at minus 28F and must be kept under pressure to be stored as a liquid above this temperature. Ammonia is corrosive to certain metals such as copper and zinc. Galvanized pipe is not used for storing ammonia because it contains zinc. Proper hoses will be used (reinforced with nylon or stainless steel) and stamped with maximum working pressure, manufacturer's name, and expiration date. 1.1.4. Equipment Specifications Equipment specifications for the storage tanks, piping, etc., are maintained by John Wilder, III. 1.2. HAZARD REVIEW Major hazards that could occur include the following: toxic release, fire, explosion, overpressurization, corrosion, overfilling, equipment failure, and a tornado. No recommendations for any changes in procedures or operations resulted in the identification of these hazards. Every precaution is used to prevent damage if these hazards were to occur, including continual maintenance and inspection. In the event that a hazard were to occur, emergency response is in place to minimize any impacts. Process controls and equipment used to prevent or limit releases include the following: relief valves, check valves, manual shutoffs, automatic shutoffs, bypass pumps, and grounding equipment. 1.3. OPERATING PROCEDURES Operating procedures are mostly communicated verbally to employees and are overseen by management. Specific questions may be addressed by John Wilder. 1.4. TRAINING Employee training is conducted while on the job. Proper filling procedures, safe equipment handling procedures, and hazards and emergency response are all communicated to the new employee at the beginning of his or her employment. New employees are monitored and questioned to ensure that they understand proper equipment usage and the hazards associated with their duties. 1.5. MAINTENANCE All equipment is continuously monitored while on the job and any maintenance issues are immediately addressed. Before using ammonia equipment, a walk-around inspection to locate any defects is performed and any defective parts are immediately repaired or replaced. Pressure relief valves and hoses are also inspected. Weekly meetings serve to summarize maintenance activities and to keep employees updated and informed. Any person responsible for maintenance of the ammonia equipment is trained and aware of the associated hazards. 1.6. COMPLIANCE AUDITS Compliance Audits (reviewing the prevention program and documentation into a report with findings and corrective actions, if any) are to be conducted by a process knowledged person at a minimum of three years intervals. 1.7. INCIDENT INVESTIGATION An incident is a situation that resulted in or could have resulted in a catastrophic release. When an incident occurs, an investigation within 48 hours of the incident will be initiated. The investigation summaries will be retained for five years. The investigation sum mary report will include incident date, investigation date, incident description, contributing factors, and resulting recommendations. 3. EMERGENCY RESPONSE PROGRAM In the event of an emergency, all employees will immediately report to the office if accessible. If not, the scale box located at the north of the property will serve as a meeting location. All employees will immediately be accounted for. John Wilder will serve as the facility emergency coordinator. If he is unavailable and the situation calls for immediate response, the Fayette County Emergency Response Agency will be contacted initially and then the facility emergency coordinator will be contacted. The alternate coordinator is Mike Vanstory. An intercom system and hand held radios are onsite to serve as emergency communication devices. Emergency breathing apparatus are located in the office for ammonia leaks or accidents. Emergency equipment will be inspected periodically by the facility emergency coordinator. Employees are trained in emergency response at the beginning of their employment and are reminded periodically at regular meetings. If there are any significant modifications to inventory or operating procedures, employees shall be notified as soon as possible. A facility map indicating where chemicals are stored and an aerial view of the facility are provided as Appendix A. A facility information sheet is also included as part of this Appendix identifying phone numbers of contacts and hazardous chemicals onsite. 3.1. EMERGENCY HEALTH CARE Material Safety Data Sheets are located on the main hallway wall in the office. Contact with the skin or eyes by ammonia might result in tissue damage by a combination of dehydration, caustic action, and freezing. In the event that skin is exposed to ammonia, move to a safe area and flush the exposed area with fresh water. Remove any contaminated clothing and do not apply creams or ointments to the skin. If ammonia comes in contact with the eyes, flush with water for at least 15 minutes. Inhalation of ammonia is easily detected because of the pungent odor and may not require treatment, but the victim should be moved to a safe area. Provide CPR if the victim is not breathing. If ingestion of ammonia has occurred, contact a doctor immediately and have the victim drink large amounts of water. After administering any emergency first aid, contact a health professional. 4. HAZARD ASSESSMENT There were no reportable accidents in the last 5 years. Worst Case Release Scenario and Alternative Release Scenario assumptions and calculations are presented in Appendix B. Also included are the modeling results that computed the distance to the endpoint using EPA's RMPCompTM . The Worst Case Release Scenario predicted a distance to the endpoint of 6.0 miles with a release of 38,502 lb of ammonia (the largest tank). 4,319 people were predicted to be effected; and residences, schools, and a prison are within the radius of the circ le. The wind speed was assumed to be 1.5 meters/second, the air temperature was 77F, and the stability class was assumed to be F. The Alternative Release Scenario predicted a distance to the endpoint of 0.19 miles with a release of 412 lb of ammonia (assuming 2 inch diameter pipe failure with 10 minute release). Four people were predicted to be effected, and residences are within the radius of the circle. The wind speed was assumed to be 3 meters/second, the air temperature was 77F, and the stability class was assumed to be D. |