Tanner Industries, Inc. - Executive Summary
Executive Summary |
Risk Management Plan:
Toxic Material: Ammonia
Tanner Industries, Inc.
115 Whet Stone Road
Swansea, SC. 29160
Tanner Industries, Inc.
735 Davisville Road
Southampton, PA. 18966
Corporate contact for further information:
David B. Binder
Internet Site: www.tannerind.com
E-Mail: [email protected]
Plan Revision Date: May 1, 1999
Company and Facility History:
Tanner Industries, Inc. is a third generation family owned and operated distributor of anhydrous and aqua ammonia, headquartered in Southampton, PA. The Tanner family started out in the ammonia business in 1955 with the purchase of National Ammonia Company in Philadelphia, PA. The company has grown to it's current size through the acquisition of three other ammonia companies, Bower Ammonia and Chemical Co. in 1971, Northeastern Ammonia Co. in 1985, and Hamler Industries in 1991. Th
is particular facility was established in 1996.
The mission of Tanner Industries, Inc. is to constantly improve our products and services to meet or exceed our customers needs, to distribute our products in a safe, efficient and environmentally responsible manner, and to generate a reasonable return in order to provide continuity for the business and employment for our employees.
Tanner Industries, Inc. is firmly committed to a fully effective implementation of the Risk Management Plan (RMP) as it applies to the safe distribution of ammonia. Our commitment to the Responsible Distribution Process (RDP) provides our company with an integrated health and safety, environmental, and product stewardship program that is supported by our strong corporate capabilities. Our dedication to the proper distribution and stewardship of ammonia includes involvement in emergency response training for first responders and other industry personnel to enhance the protection of our employees and communit
Tanner Industries, Inc. is a distributor of anhydrous ammonia. We are not a manufacturer. The material is transported to our facility by rail car or tank truck and then transferred from this equipment to either our on-site storage vessels or transport cargo tanks. From the storage vessels the material can be repackaged for bulk or non-bulk distribution to end-users.
The potential maximum quantity of anhydrous ammonia that could be stored at this facility on any particular day is 1,100,000 pounds. It is only on rare occasions when these potential storage quantities are actually achieved. Each storage vessel is limited by federal regulation to 85% of the maximum volume of the storage vessel. The maximum quantity handled at any particular time would occur during the transfer from a railcar to a storage tank and that quantity is 133,000 pounds.
At this facility, blending of a product we call "aqua ammonia" is also performed. This material, ammonium hydroxide, is a solutio
n of ammonia and water. In order to avoid minor releases of anhydrous ammonia vapor, our handling processes institute closed loop systems that capture the ammonia gas in water. This solution is transferred into a process vessel where the volume is increased and the ammonia concentration standardized for distribution into the commercial market. This product, even at low concentrations, is still a hazardous material due to the ammonia that vaporizes off of it.
The potential maximum quantity of aqua ammonia that could be stored at this facility on any particular day is 981,000 pounds. Again, it is only on rare occasions when the potential storage quantities are actually achieved. The maximum quantity handled at any particular time would occur during the transfer from a process vessel to a storage tank and that quantity is 87,000 pounds.
Benefits and Uses of Ammonia:
Ammonia is a basic chemical that has many common manufacturing and practical uses. The largest users of ammonia are agri
cultural industries. Ammonia itself is applied directly by farmers as a fertilizer. Some agricultural businesses combine ammonia and other chemicals and nutrients to form more complex fertilizers. Other common products that are made with ammonia include textiles, pharmaceuticals, cleaning solutions, dyes, inks and food packaging products. Ammonia is also used by some companies in various processes. Ammonia is recognized as an "ozone safe" refrigerant. This means that, unlike other refrigerants, any ammonia releases into the atmosphere will not harm the earth's ozone layer. Besides refrigeration, Ammonia is used in some common processes like drinking water purification, air and water pollution control, waste treatment, reprographics, and the heat treating or hardening of metal parts.
Potential Health Effects of Ammonia:
Even in small concentrations, ammonia is irritating to the eyes, throat and breathing passages. Accompanied with a very pungent odor, ammonia can be said to be "auto-
repulsive". These characteristics provide us with an early warning of the material's presence and force us to retreat from ammonia contaminated atmospheres. High concentrations could have more serious health effects. These could include convulsive coughing, difficult and painful breathing, eye damage and in extreme cases, death. Liquid ammonia or ammonia solution contact of the eyes or skin can produce serious chemical burns requiring prompt medical attention.
Employees and contractors who work around ammonia should take the extra precautions of reviewing Material Safety Data Sheets, wearing appropriate safety equipment and participating in special training programs as prescribed by the US Occupational Safety and Health Administration.
Safety Improvement Process:
Safety improvement is a corporate wide philosophy. Tanner Industries, Inc. continuously searches for ways to improve safety performance. Each facility has an individual safety committee comprised of site employees and ma
nagement. These committees meet on a periodic basis to review safety concerns at our sites as well as at our customer facilities. The management representatives of the site specific committee report directly to the corporate safety committee. The corporate safety committee is comprised of upper management, compliance personnel and headquarters employees that are familiar with plant processes. This committee meets on a regular basis to review accident and injury investigations, evaluate site specific issues, provide recommendations and implementation guidance. Also, qualified personnel periodically inspect and evaluate each facility to assess safety and maintenance conditions. The results of these facility inspections are reported directly to upper management and the operations department. As a whole, these systems provide Tanner Industries, Inc. with a continuous process for the identification of safety improvement opportunities thus reducing any risk to our society associated with a
release of this important chemical.
What Tanner Industries, Inc. Does to Keep Us Safe:
Prevention Policy Statement:
The owners, management and employees of Tanner Industries, Inc. are committed to the prevention of accidental releases of ammonia. Our company has implemented the standards of the US Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia" as well as the published provisions of the American National Standards Institute's (ANSI), K61.1, "Safety Requirements for the Storage and Handling of Anhydrous Ammonia".
Tanner Industries, Inc. is a member of the National Association of Chemical Distributors (NACD) and committed to the Responsible Distribution Process (RDP). This process is an initiative of the NACD and its member companies designed to provide a system which promotes continuous improvement in the health, safety and environmental performance of all its members. It is designed to be sensitive and responsive to
the public concerns about the chemical industry.
As a member of the NACD, Tanner Industries, Inc. is committed to the continuous improvement in the chemical distribution industry's responsible management of chemicals. We pledge to manage our business according to the Codes of Management Practice of the Responsible Distribution Process. These codes pertain to:
1) Risk Management.
2) Compliance Review and Training.
3) Carrier Selection.
4) Handling and Storage.
5) Job Procedures and Training.
6) Waste Management.
7) Emergency Response and Public Preparedness.
8) Community Outreach.
Tanner Industries, Inc. is the recipient is the Chemical Education Foundation's 1996 Product Stewardship Award - Chemical Distributor Category, for exhibiting excellence in fostering chemical product stewardship.
Tanner Industries, Inc. uses a variety of safety equipment and specialized procedures to prevent accidental releases of anhydrous ammonia. In supp
ort of our policy, the following is a typical list of safety equipment and systems employed at this facility.
a) Pressure relief valves are employed on all storage, transfer and delivery equipment to handle unexpected increases in pressure. Per their operational design, these valves will reset after relieving only the excess pressure. Depending on their situational placement in the process, these valves may be designed to relieve pressures caused from either vapor or liquid.
b) Excess flow shut off devices are incorporated through out the process as prescribed by federal regulation. These valves are designed to stop the flow of liquid material any time their rated flow capacity is exceeded. These valves are designed to prevent the catastrophic release attributed to a storage tank line or valve break.
c) Regular facility and equipment inspections ensure safe and proper operating conditions.
d) Employees are trained in start-up, operation, shut-down and maintenance of al
l equipment. The facility has a copy of the Standard Operating Procedures that are required to perform these tasks and employees are required to follow these procedures and encouraged to reference them as needed.
e) Employees and contractors receive extensive health care and safety training pursuant to all applicable regulatory and corporate guidelines.
f) Investigation of any accident or injury with the development and implementation of corrective action plans in order to prevent reoccurrences at any of our facilities.
g) Routine audits and inspections are performed by both Tanner Industries, Inc. management and outside agencies to ensure safe and correct procedures are employed, and to identify areas where safety can be improved.
h) Coordination of planning efforts with Local Emergency Planning Comm
ittees (LEPCs), fire departments and Haz-Mat Units.
Emergency Response Procedures:
Emergency Response Policy Statement:
The owners, management and employees of Tanner Industries, Inc. are prepared to cooperate with local emergency responders and other authorities to mitigate any release and minimize the impact of any release to the community, the environment, and our employees. To be prepared for any potential chemical accidents, our company communicates regularly with the Local Emergency Planning Committee (LEPC) and local fire departments.
The facility has a written emergency action plan in accordance with US Occupational Health and Safety Administration (OSHA) standard 29 CFR 1910.38. We have provided state and local authorities the Emergency Planning and Community Right to Know (EPCRA) information as required by the US Environmental Protection Agency's SARA Title III standard. Also, our company has a Emergency Response Program, in accordance with OSHA standard 29 CFR 1910.120 (
q), including pre-emergency planning and employee, customer and, public emergency responder training programs that are specific to anhydrous and aqua ammonia.
Sheltering in place is considered to be a proven method for protecting people in the event of an accidental release. To shelter-In-Place do the following:
1) Move inside immediately (building or vehicle).
2) Close all windows and doors.
3) Turn off ventilation systems.
4) Go into and seal a room (use tape, towels etc. to seal doors and windows if possible).
5) Use radio, phone, etc. for communications.
Accidental Releases in Perspective:
Worst Case Release Scenario (Full Potential Release) ....... 160,000 pounds of anhydrous ammonia.
Alternate Release Scenario (More Likely release) ....... 150 pounds of anhydrous ammonia.
Largest Actual Release in Last Five years (Historical) ....... 0 pounds of anhydrous ammonia.
Largest Actual Release in Last Five years (Historical) .......
750 pounds of ammonium hydroxide.
Release scenarios were modeled using the "Aerial Locations of Hazardous Atmospheres (ALOHA)" software developed by the US Environmental Protection Agency. Off-site receptors have been identified using "LandView III" software developed by the US Department of Commerce, Bureau of Census. Worst Case Scenario
Tanner Industries, Inc considered a 160,000 pound release of anhydrous ammonia as the worst case scenario. The release event resulted from the entire contents of the largest vessel, in this case a railcar, emptying in 10 minutes. Since ammonia is stored as a liquid under pressure, the release would result in a dual-phase flow. Dual-phase flow means that the material would simultaneously flow as a gas and a liquid and then vaporize into a gas. The dual-phase flow was automatically considered by the software for this scenario. Liquid ammonia spills also undergo a phenomenon known as "auto-refrigeration". This is an effect that is demonst
rated by a decrease in the internal temperature of an ammonia pool due to vaporization. This characteristic essentially decreases the vaporization rate of an ammonia pool. Thus, the vapor cloud from a liquid release would diminish over time and the endpoint would be dynamic. An increased effect could be expected if the release were to occur within an area that limited the exposed surface of the pool. Neither the auto-refrigeration property of ammonia or any other mitigating factors were a consideration used in this scenario.
The off-site area impacted by the release could experience ammonia concentrations of 200 parts per million (ppm). Please refer Section 2, Worst Case Release Scenario of the Risk Management Plan for further information.
Alternate Case Release Scenario
Tanner Industries, Inc considered a conservative alternate case scenario. We selected a release amount of 150 pounds of anhydrous ammonia, which is 150% of the maximum amount released at any of our facilities based
on our five year accident history. We applied this conservative scenario to all of our facilities for the following reasons:
a) All of our facilities store and handle anhydrous ammonia.
b) All of our facilities use the same basic processes in their operation.
c) The potential for this amount to be released at any of our facilities does exist.
d) Some of our facilities do not have a history of accidental releases.
The scenario was performed considering the total 150 pounds of ammonia released as a gas. No mitigating factors were assumed for this scenario.
The off-site area impacted by the release could experience ammonia concentrations of 200 parts per million (ppm). Please refer Section 3, Alternative Case Release Scenario of the Risk Management Plan for further information.
Alternate Case Release Scenario for Ammonium Hydroxide (Aqua)
Tanner Industries, Inc considered a conservative alternate case scenario. We selected a release amount of 20,000 pounds (2675 gallons) o
f ammonium hydroxide solution at a 29.4% concentration of ammonia. This quantity is about 150% of the maximum amount released at any of our blending facilities based on our five year accident history. We applied this conservative scenario to all of our ammonium hydroxide blending facilities for the following reasons:
a) All of these facilities store and handle ammonium hydroxide at this maximum concentration.
b) All of these facilities use the same basic processes in their operation.
c) The potential for this amount to be released at any of these facilities does exist.
d) Some of our facilities do not have a history of accidental releases of this material.
The scenario was performed considering a total amount released as a liquid. No mitigating factors were assumed for this scenario.
The off-site area impacted by the release could experience ammonia concentrations of 200 parts per million (ppm). Please refer Section 3, Alternative Case Release Scenario of the Risk Managem
ent Plan for further information.
Five Year Accident History:
There have been no unintentional releases of either anhydrous ammonia, (listed on chart as anhydrous) or ammonium hydroxide, (listed on chart as aqua) at the Tanner Industries, Inc., Swansea, SC. facility in the past five years that meet the US EPA Risk Management Program (RMP) defined reporting requirements.
The following is a list of all unintentional ammonia releases at our facility that have been reported to federal, state and local authorities in the past five years under the requirements of US Environmental Protection Agency's Superfund Amendments and Reauthorization Act (SARA) Title III, Emergency Planning and Community Right to Know Act (EPCRA). None of these releases, to our knowledge, resulted in any adverse impacts to the community, the environment or our employees.
Quantity Released (Anhydrous) 1994 1995 1996 1997 1998 1999 (1st Qtr.)
Greater than 1,000 pounds N/
A N/A 0 0 0 0
100 to 1,000 pounds N/A N/A 0 0 0 0
10 to 100 pounds N/A N/A 0 0 0 0
Less than 10 pounds N/A N/A 0 0 0 0
Quantity Released (Aqua Ammonia) 1994 1995 1996 1997 1998 1999 (1st Qtr.)
Greater than 1,000 pounds N/A N/A 0 0 0 0
100 to 1,000 pounds N/A N/A 0 1 0 0
10 to 100 pounds N/A N/A 0 0 0 0
Less than 10 pounds N/A N/A 0 0 0 0
NOTE: No history exists prior to the esta
blishment of this facility in 1996.