Anitox Corp. Buford Plant - Executive Summary

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Executive Summary for Anitox Corp 
 
Environmental Protection Agency 
Risk Management Program 
 
 
Anitox Corporation has spent over 20 years developing agricultural chemical products to control microbiological contamination of animal feed and feed ingredients.  Through an extensive Research and Development Center, Anitox is able to develop new products and services to assist the animal feed industry in providing safe, clean feed.  Anitox is committed to do all that is reasonable to protect our employees, our customers, and the public from results of chemical releases or fire.   
 
A primary goal for Anitox is to eliminate, or control, both known and potential safety and health hazards that exist in the work place.  Anitox goes to great lengths to accomplish this goal including the use of proper equipment, materials, manufacturing procedures, and trained employees.  The safety program for Anitox has received two awards for outstanding contributions of workplace safety and health.  Anitox was a 
warded the Lois Nelson Memorial Award by Georgia Technical University.  In addition, the Safe Plant Award was received from the American Feed Industry Association.  Anitox insures that all public service agencies responsible for emergency response are kept informed and updated on the Anitox emergency response plan.  These agencies include, but are not limited to, the Gwinnett County Fire Department and the County Hazardous Material Team.  Anitox has conducted facility tours and issued copies of the emergency response plan with these agencies. 
 
Anhydrous Ammonia is used in the manufacturing process at Anitox.  The Environmental Protection Agency and the Occupational Safety and Health Administration have determined anhydrous ammonia to be a hazardous material.  Both governmental agencies have issued regulatory requirements addressing the storage and use of this product.  Anitox has incorporated into its safety program the regulatory requirements of both Process Safety Management and Risk 
Management programs.  The National Response Center and the State of Georgia Emergency Response Commission are notified immediately in the event of a chemical release.  
 
The Risk Management Program requires an accidental chemical release analysis be conducted when a hazardous material is used within a manufacturing process.  This analysis is an attempt to calculate what, if any, offsite impact could occur in the event of an accidental chemical release.  Anitox used the RMP*Comp modeling software program developed by the Cameo team and provided by EPA, for this offsite analysis.  There are two analysis required by the Risk Management Program.  The first analysis is conducted assuming a worst case scenario; the second analysis is conducted assuming an alternative scenario.  
 
The worst case chemical release scenario involved modeling the rupture of the storage tank for anhydrous ammonia.  This type of failure would allow the total volume of anhydrous ammonia to be released to the enviro 
nment.  There are several steps taken by Anitox to mitigate the release in this type of tank failure.  Monthly tank inspections are conducted to insure that the structural integrity of the tank remains intact.  Secondary containment has been constructed surrounding the anhydrous ammonia tank to restrict the flow of liquid to a confined area in the event of a tank failure.  Anitox also has emergency response equipment, material, and trained personnel on site for immediate response to a release.  The offsite impact of this type of release would be influenced by circumstances such as wind direction, temperature, and rate of release.  Anhydrous ammonia vapors are lighter than air and can be expected to dissipate readily to the upper atmosphere.   
 
The alternative release scenario involved the rupture of a pipe containing anhydrous ammonia within the manufacturing process.  This alternative was chosen based on the limited number of areas within our process where a release could occur.  Anit 
ox takes similar steps to mitigate this type of release.  These steps include monthly process equipment inspections, secondary containment, and emergency response equipment, material, and trained personnel on site for immediate response.  Offsite impact would not occur based on the volume of product released in this scenario. 
 
Anitox has had one accidental release of anhydrous ammonia in the past five years.  A release of 2,392 pounds occurred on August 19, 1994.  A large percentage of this release was mitigated from reaching the environment.  The secondary containment surrounding the anhydrous ammonia tank, along with the on-site emergency response equipment helped contain the ammonia vapors during the release.  No one onsite or offsite was injured, but the potential for evacuation was directed to neighbors in close proximity as a precautionary measure during this release. 
 
Anitox continually strives to stay informed of new technology in the areas of safety and manufacturing processe 
s.  Continuous training of onsite personnel involving emergency response agencies enables Anitox to respond quickly and effectively to emergencies should they occur.  Anitox is currently researching the feasibility of an alarm system that can detect an ammonia release if it occurs.  We are also pursuing additional emergency response equipment that will improve our ability to mitigate the amount of ammonia reaching the environment during a release.  We are committed to uphold our reputation as environmental stewards within the community. We view ourselves as a business partner who, in conjunction with other businesses and the general public, can preserve and protect the environment in which we all live. 
 
Respectfully, 
 
 
 
Marsha Clark 
President
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