Helena Chemical Company, Hondo Facility - Executive Summary |
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The Helena Chemical Company Hondo Facility has submitted this electronic RMP in compliance with the provision of the Clean Air Act 112(r) as codified by the U.S. Environmental Protection Agency at 40 CPR Part 68. Standards codified by the Occupational Safety and Health Administration at 29 CFR 1910.119 are not applicable to the operations at this facility because the facility is operated as a retail operation and is exempt from the OSHA standards. This electronic submittal provides conservative estimates of the offsite consequences of an accidental release of anhydrous ammonia from the Hondo Facility located at 240 Highway 173 North in Hondo, Texas. The electronic RMP summarizes the policies and procedures implemented by the Hondo Facility to minimize the likelihood of an accident. The electronic RMP also summarizes the actions that the Hondo Facility has taken to ensure that a response to a release (even though a release is unlikely) will be implemented in a proper and timely mann er. FACILITY Helena Chemical Company engages in the formulation, distribution, and sale of chemicals to customers, most of whom use Helena's products to support agricultural operations. The Hondo Facility is a retail agricultural chemical company that operates anhydrous ammonia storage tanks. Anhydrous ammonia processes at this location include storage, loading, and unloading. Loading operations occur from trucks to storage tanks, and from storage tanks to end use processes. End use processes may include fertilizer formulation and nurse tank transportation and operation. OFF-SITE CONSEQUENCE ANALYSIS Worst case and alternative consequence analyses were completed for the ammonia storage process. The worst-case scenario release for the Hondo Facility assumed that all 158,945 lbs of ammonia in the largest single storage tank were released. The release was modeled as if the ammonia tank was punctured on the side at ground level. The resulting release of ammonia was modeled as a ground level horizontal jet. The estimated distance to the toxic endpoint was 4.3 miles. The alternative (or more likely to occur) scenario assumes a violent rupture of a 3-inch line caused by an impact from a vehicle or some other source on the liquid ammonia transfer line during a major loading or unloading operation. Although this event is classified as an alternative scenario, even an accident of this type is unlikely to occur due to the safety equipment (rail guards, check valves) and operating procedures that Helena uses to safeguard ammonia transfer operations. The estimated distance to the toxic endpoint in the alternative scenario was 0.43 miles. Both the worst case and the alternative scenario are overly conservative because even a 2-minute release is unlikely to occur since check valves on the system should close immediately upon increased flow resulting from the severed transfer line. ACCIDENT PREVENTION PROGRAM The Hondo Facility complies with U.S. EPA's acc idental release prevention rule and with all applicable state codes and regulations. The Hondo Facility provides safety information relevant to the on-site ammonia processes including MSDS documentation, storage and process limits, equipment specifications, and relevant codes and standards. The Hondo Facility has conducted a hazard review to ensure that potential safety problems are identified and addressed. The Hondo Facility has developed standard and consistent operating procedures that all employees follow when working with ammonia. The Hondo Facility ensures that all of its employees working with or around ammonia participate in a training program. The training program teaches employees how to avoid and respond to accidents. Helena Chemical Company has also established integrated operation and maintenance procedures, inspection requirements and schedules, compliance audits, and incident investigation procedures. EMERGENCY RESPONSE PROGRAM Helena Chemical Company's Hondo Facility is a non-responding facility. Helena has coordinated emergency response activities with its local emergency response agency. FIVE YEAR ACCIDENT HISTORY The operation of ammonia storage at the Hondo Facility in the past five years has not resulted in any on-site deaths, injuries, or significant property damage; or off-site deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place. CONCLUSION The Risk Management Plan implemented by Helena Chemical Company at the 240 Highway 173 North, Hondo Texas Facility complies with the requirements of the Clean Air Act, Section 112(r). The RMP will be updated as the Hondo Facility adds, deletes, or changes processes. The Emergency Response Program has been coordinated with the Medina County LEPC. NOTE: Sections 4, 5, and 7 of the standard RMP produced by EPA's RMP Submit Program are not applicable to the Hondo Facility. |