High Plains Co-op - Executive Summary |
|
Risk Management Plan (RMP) - Ammonia Executive Summary High Plains Co-op Sterling, Colorado 1. Accidental Release Prevention and Emergency Response Policies We at High Plains Co-op in Sterling are strongly committed to employee, public, and environmental safety. This commitment is an inherent part of our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release. We also coordinate our response efforts with the Sterling Fire Department, which provides addit ional emergency response expertise. 2. Stationary Source and Regulated Substances Handled Our facility's primary activities include support services for crop production. We have anhydrous ammonia stored in a temporary, 78-ton rail car and 25,000- and 30,000-gallon interconnected tanks at our facility in Sterling (Figure 1). The maximum amount stored is 105.5 tons (396,575.5 pounds) at the maximum fill capacity of 85%. 3. Worst Case Release and Alternative Release Scenarios We utilized RMP PRO for the worst case and alternate case scenarios of the required offsite consequence analysis for our facility. The following details these scenarios. The worst case release scenario involves a catastrophic release of the entire contents of the two interconnected anhydrous ammonia storage tanks (240,576 pounds) in gaseous form over a 10- minute period. At Class F atmospheric stability, 1.5 m/s wind speed, and urban topography, the maximum distance to a toxic endpoint of 0.14 mg/L is 6.8 miles (Figure 2). The estimated population within a 6.8-mile radius of this facility is 15,000. The alternative release scenario involves a release from an anhydrous ammonia product line. The scenario involves the release of 9,139.71 pounds of ammonia in a gaseous form over a period of 30 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of ammonia is 0.31 mile (Figure 3). The estimated population within a 0.31-mile radius of the facility is 100. 4. General Accidental Release Prevention Program Our facility has taken all the necessary steps to comply with the EPA's accidental release prevention requirements as set forth in 40 CFR part 68. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information High Plains Co-op maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equip ment designs associated with all processes (Appendix D). Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled effectively. Any findings from the hazard analysis are addressed in a timely manner. Operating Procedures High Plains Co-op maintains written operating procedures to ensure that activities within our covered processes are conducted safely. These procedures address various modes of operation; the information is regularly reviewed and is readily accessible to operators involved in the processes (Appendix B). Training High Plains Co-op has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Mechanical Integrity High Plains Co-op conducts documented maintenance checks on process equipment to ensure proper operation. Maintenance checks are conducted by qualified p ersonnel with previous training in maintenance practices. Examples of process equipment that would receive maintenance checks include: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner (Appendix C). Management of Change Written procedures are in place at High Plains Co-op to manage changes in process chemicals, technology, equipment, and procedures. Process operators, maintenance personnel or other employees whose job tasks are affected by a modification in process conditions are promptly notified of the modification and offered training to deal with it. Pre-startup Reviews High Plains Co-op routinely conducts pre-startup safety reviews related to new processes and modifications in established processes. These reviews are conducted to confirm that construction, equipment, and operating and maintenance p rocedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits High Plains Co-op conducts compliance audits on a regular basis to determine whether the plan's provisions, set out under the 40 CFR part 68, are being implemented. Any non-compliance issue discovered during the audit is promptly corrected. Employee Participation High Plains Co-op truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP, particularly information resulting from process hazard analyses. 5. Five-year Accident History High Plains Co-op has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, no accidental relea se has occurred during this period. 6. Emergency Response Plan High Plains Co-op maintains a written emergency response plan to deal with accidental releases of hazardous materials. The plan addresses all aspects of emergency response including first aid and medical treatment, evacuations, and notification of local emergency response agencies and the public (Appendix A). |