Logansport Wholesale Terminal - Executive Summary |
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The Andersons Logansport RMP Executive Summary Source and Product Description The Andersons Logansport Wholesale Fertilizer is engaged in the handling, storage, shipping and receiving of bulk agricultural fertilizers (liquid and granular). This facility has been operated by The Andersons, Inc. since the end of 1989. Key personnel at the Logansport facility are Rod Erny, facility manager and Tim Strasser, production supervisor. The facility occupies approximately 16 acres and is situated just east of Hwy. 35 at 2345 S. County Rd. 400 East in Washington Township, Cass County, Indiana. There are a few residences to the north, across the street, and a couple neighbors to the east. Kent Feeds is located adjacent to the facility on the west side. The Logansport facility uses aqua ammonia as a raw material for producing various types of liquid agricultural fertilizers. Aqua ammonia is a solution containing anhydrous ammonia and water. One 18,000 gallon tank is used for bulk storage of the liquid material. Aqua ammonia is not a poison, but it is an inhalation / respiratory hazard. Ammonia is a toxic material but it has no cumulative toxic effects on the human body. However, it is acutely corrosive when it comes in contact with mucous membranes, in particular. Aqua ammonia is a non-flammable liquid. Summary of Major Hazards The principal causes of ammonia emergencies are leaking pipes. Transfers from the bulk storage tank to the fertilizer mixing system occur inside fixed steel pipes and are automated from the control room. No hoses are utilized in the operation. A complete failure or burst tank is highly unlikely. The storage tank was built under strict guidelines established in the ASME pressure vessel code. The storage tank is located inside a secondary containment dike. Most major welding and structural work done on the tank or appendages is performed by certified welders. Consequences of Failure to Control the Hazards The worst case scenario for t his facility was created using EPA's RMP Comp software. A complete release of the tank contents (133,200 pounds -- creating a liquid spill with ammonia vapors) in a 10 minute period, using worst case atmospheric conditions, results in a distance to endpoint of .70 miles. The estimated exposed population is 80 people. This distance would not effect any schools or government offices. No hospitals, prisons or sensitive environmental receptors would be affected. There are passive mitigation systems available for this type of scenario. It is our belief that the risk of a complete release of the tank contents is very small. The tank is located inside a secondary containment dike in a protected location, and transfer appendages are protected by concrete barriers. A more probable release situation is expressed by the alternative release scenario. We believe that a more likely release could occur from a leaking pipe. We estimate that the maximum amount of aqua ammonia that could escape to the atmosphere is 13,320 pounds. A release of this nature would likely last for about ten minutes. Utilizing an average wind speed of 3.0 m/sec and atmospheric stability class D, the resulting distance to endpoint (for vapors only) would be 0.30 miles. In this more realistic scenario, the only potential exposed receptors would be the few residences to the east and north sides of the facility. Active and passive mitigation systems were included in the alternative case scenario. They are listed in the next section. Explanation of How Hazard Releases are Prevented. Passive mitigation refers to equipment, devices, or technologies that function without human, mechanical or other energy input. Passive mitigation systems in place at the Logansport facility are: 7 Secondary containment dikes that meet or exceed regulatory standards. Active mitigation refers to equipment, devices or technologies that require human, mechanical or other energy input to function. Active mitigation systems in place at the Logansport facility are: 7 Liquid valves on the tank which require manual effort to open or close. 7 Spill control kits are located at the facility and include sorbent material, shovels, PPE and disposal containers. 7 Operator and truck drivers supervise all transfers to and from the bulk storage tank Prevention Program Preventive maintenance is an integral piece of this facility's hazard management program. All hoses, tanks, valves and storage units are inspected at least monthly, and usually daily during the production season. A good PM program is our strongest defense against a release of anhydrous ammonia. Records of major maintenance tasks performed on the tank or appendages are on file. See "Steps Taken to Address Hazards" for more information on prevention measures and identification. Management System (see "Steps Taken to Address Hazards") Equipment maintenance All equipment maintenance is formally documented. See the "Prevention Program" section for further explanation. Training All employees receive annual training on anhydrous ammonia, emergency action plan and spill procedures, and hazard communication. Documentation and attendance rosters are on file at the facility. Contractors All contractors receive a "contractor safety review" prior to performing work at the facility. During this review, they are informed of any potential hazards at the facility, emergency procedures, site-specific safety rules and the ability to request an MSDS for any product at any time. Steps Taken to Address Hazards The Andersons Logansport Wholesale Fertilizer facility has many systems in place for hazard assessment and mitigation. The Safety Department performs annual hazard management audits at the facility. The audits include a physical walk through of the entire facility and a review of all EPA, OSHA and DOT paperwork and training documentation. Action items are noted and recommendations are made. The audits consist of five major topical areas: Safety & Health, Environmental, Fire Protection & Security, Administrative and Housekeeping & Storage. Issues are documented in a report and sent to the facility manager and upper management. Updates on action item status must be made within 30 days and 6 months of receiving the report. Formal investigations are performed for all environmental or safety incidents. Documentation is kept on file at the facility and the corporate Safety Department. Monthly Safety meetings allow employees to discuss any concerns they may have with the operation of the facility. Issues are documented and assigned to employees for follow-up. Records of all meetings are kept at the facility. Response Action in the Event of a Release In the event of a leaking pipe or defective valve, employees are instructed to shut down the transfer process and, if possible, approach the shutoff valve from upwind and attempt to turn it off. For an uncontainable release, employees will immediately cal l the police and fire department or other first responders, as appropriate. All employees, customers and contractors are to be evacuated to an upwind location. Once the response team has arrived, we will work in concert with them to close the valves between the tank and the leak. In the meantime, a steady spray of water will deluge the any resulting ammonia gases and knock it to the ground, while chemically binding any free ammonia. The employees are instructed to make emergency phone calls in this order: the facility Manager, 911, the corporate Safety Department emergency phone number, the Indiana Emergency Response hotline and the Indiana Department of Environmental Management emergency phone number. All applicable contact names and numbers are found in the facility spill and emergency response plan. Communication procedures with responders The local fire department has been invited to tour the Logansport facility in the past, and will continue to be invited on an annual basi s. Facility management, employees and fire department personnel have jointly discussed the location of the anhydrous ammonia and response procedures on a regular basis. They need know the location of all emergency shutoff valves and on-site response equipment. We believe that a strong relationship with first responders is our best defense. The LEPC and state regulatory agencies receive a copy of our hazardous materials storage information, every February, in accordance with our community right to know obligations. A copy of the Logansport Emergency Action Plan is on file with the LEPC and the local fire departments. |