Morral Companies - Caledonia - Executive Summary |
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Morral Companies - Caledonia Facility Manager: John Boyd Sr. Facility Telephone: (740) 465-3251 Accidental Release Prevention and Emergency Response Protocols: The owners, management and employees of the Caledonia facility are committed to providing a safe workplace free of accidental releases of anhydrous ammonia. Health, safety and environmental compliance are a fundamental part of every employee's job. It is facility protocol to adhere to applicable Federal, State and local laws and to implement appropriate controls to prevent accidental releases of anhydrous ammonia. If an accidental release were to occur, the facility would respond in accordance with its Emergency Action Plan and is prepared to work with the local fire department, the Local Emergency Planning Committee and other authorities to control and mitigate the release and minimize the impact of the release to employees, the environment and the general public. Stationary Source and Regulated Substances Handled: The primary activity at this facility (the stationary source) is the storage and handling of fertilizers for direct retail sale to farmers. Anhydrous ammonia is received, stored and distributed for direct application as crop production nutrients. The maximum stored quantity of anhydrous ammonia at the facility is approximately 203,000 pounds stored in one (1) 18,000 gallon storage tank and two (2) 12,000 gallon storage tanks. The maximum fill level of each tank is 85% of the total tank capacity, which is controlled by a liquid level gauge. This facility is loaded by transport truck; therefore, the maximum quantity of anhydrous ammonia handled would occur when the on-site storage tanks are at the maximum fill level of 85%. Worst-Case Release Scenario and Alternative Release Scenario: The worst-case release scenario would be the release of the total contents of the 18,000 gallon storage tank. The maximum quantity of anhydrous ammonia released would be approximately 87,000 pounds released in a gaseous form over ten (10) minutes. The resulting distance to the toxic endpoint concentration extends offsite and public receptors are within the distance to the endpoint. The distance to the toxic endpoint concentration (0.14 mg/L) is 0.98 miles. There was one (1) administrative control considered in this scenario; which is, the storage tank is not filled more than 85% full. There were no passive mitigation measures considered in this scenario. The alternative release scenario involves a release of anhydrous ammonia from a break/rupture in a two (2) inch hose during transfer of ammonia from the storage tank to a nurse tank. The quantity of anhydrous ammonia released in a gaseous form would be approximately 12,000 pounds, which is based on a release rate of approximately 6,000 pounds per minute over a two (2) minute time period. The resulting distance to the toxic endpoint concentration extends offsite and public receptors are within the distance to the endpoint. The distance to the toxic endpoint concentration (0.14 mg/L) is 0.56 miles. There were no passive mitigation measures considered in this scenario. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps: This facility complies with EPA's accidental release prevention requirements and applicable State and local codes and regulations. The following sections briefly describe the elements of the facility's release prevention program. 1) Safety Information: The facility was designed and constructed in accordance with applicable Federal and State regulations. All plans and procedures maintained at the facility are periodically reviewed by facility management for safety updates and changes. Material Safety Data Sheets, equipment specifications and the codes and standards used to build and operate the anhydrous ammonia equipment are maintained at the facility. 2) Hazard Review: Facility management conducts reviews of the hazards associated with the hand ling and storage of anhydrous ammonia. The reviews identify the opportunity for equipment malfunctions or human errors that could cause an accidental release, the safeguards used to control hazards and prevent releases, and the steps used to detect or monitor releases. The results of the reviews are documented and problems identified are addressed in a timely manner. 3) Operating Procedures: The facility maintains written operating procedures for the handling and storage of anhydrous ammonia. The procedures generally follow the provisions of the Occupation Safety and Health Administration (OSHA) standard, 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia" and the American National Standards Institute (ANSI) standard, "Safety Requirements for the Storage and Handling of Anhydrous Ammonia, K-61.1". The written procedures are reviewed by facility management on a regular basis and revised as necessary. 4) Training: All employees at the facility that handle anhydrous am monia participate in a training program. Initial training for new employees consists of classroom type instruction (e.g., reading safety information, operating procedures and response measures followed by a written test) and on-the-job supervision. Refresher training for all employees is conducted at least once every three (3) years. The training program is reviewed by facility management on a regular basis and revised as necessary. 5) Maintenance: The facility maintains written equipment inspection and maintenance procedures. Storage and transfer/process equipment inspections are performed by qualified personnel on an approximate annual basis and are documented. Equipment maintenance procedures follow either instructions furnished by the equipment vendors, Federal or State regulations (i.e., the provisions of the OSHA standard, 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia") or industry codes (i.e., the provisions of the ANSI standard, "Safety Requirements for th e Storage and Handling of Anhydrous Ammonia, K-61.1"). The written procedures are reviewed by facility management on a regular basis and revised as necessary. 6) Compliance Audits: As required by the RMP rule, compliance audits will be performed at least once every three (3) years. The audit will be documented and conducted by a person knowledgeable in the safe handling and storage of anhydrous ammonia. Corrective actions required as a result of each compliance audit will be performed promptly and documented. 7) Incident Investigation: Facility management will investigate each incident that results in, or could have reasonably resulted in a catastrophic release of anhydrous ammonia. The investigation will be performed to identify the situation leading to the incident as well as corrective actions to prevent the release from reoccurring. Investigation reports will be retained for five years. Five-Year Accident History: There have been no accidental releases of anhydrous a mmonia in the past five (5) years that caused deaths, injuries, or significant property damage at the facility; nor, to our knowledge, resulted in offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. Emergency Response Program: In the event of an emergency, it is facility protocol to notify the local fire department and other emergency responders and request that they respond to the emergency. Facility employees will not respond to accidental releases of anhydrous ammonia except for those that are small or incidental, can be controlled at the time of the release by employees in the immediate release area (e.g., shutting a valve) and do not appear to pose an immediate safety or health hazard. This protocol has been discussed with the local fire department and the other emergency responders and the facility has appropriate mechanisms in place to notify the emergency responders when there is a need for a response. The facility is also i ncluded in the written community emergency response plan developed under the Emergency Planning and Community Right-to-Know Act (EPCRA). Planned Changes to Improve Safety: There are no specific anhydrous ammonia safety changes planned at this time. However, safety improvement is an on-going process at this facility. Periodic evaluations are performed to assess the safety of equipment and procedures. |