Terra International, Inc. - Forest, IN - Executive Summary |
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Terra International, Inc. - Forest, In Certification Statement for the RMP Program 2, Aqua Ammonia (24% ammonia solution) To the best of the undersigned's knowledge, information and belief formed after reasonable evaluation and by actual knowledge of the facility and process, the information submitted is true, accurate and complete. Mark Schwarzkopf Signature Print Name RMP Coordinator 3/31/99 Title Date Executive Summary - Aqua Ammonia (24% ammonia solution) Accidental release prevention and emergency response policies. This facility complies with the Office of Indiana State Chemist - Indiana Commercial Fertilizer Law requirements and Terra policies for the storage of liquid fertilizer. In addition, it is our policy to adhere to all applicable federal, state and local laws. Terra's Corporate Mission states "To provide for the safety of our employees, our customers and the general public". In order to fulfill this mission, Terra provides a corporate EHS group to maintai n and administer comprehensive safety and environmental programs and procedures. EHS field safety services supervisors audit and monitor facility compliance with the safety standards of the company. All locations are required to conduct their own internal audit utilizing checklist survey forms that are reviewed regularly and updated as necessary to ensure all applicable federal state and local regulations are covered. The EHS group conducts comprehensive annual audits at every location to measure regulatory compliance including those governing the safe handling and storage of aqua ammonia. The field supervisors require a timely written response with the completion date of all recommendations resulting from the audits. Each location has a 'site safety coordinator' as an extension of the EHS group. These coordinators are given training to monitor the day to day safe work activities, maintain the required regulatory record keeping, conduct monthly safety meetings, conduct employee tra ining and act as the location's contact with the corporate EHS group. The site safety coordinators act as the location emergency contact. Description of our facility and the regulated substances handled. This facility stores liquid 24% Aqua Ammonia for use in manufacturing other liquid fertilizer solutions. Aqua Ammonia is received by truck, handled and stored on-site and is a regulated substance by the EPA requiring us to comply with the Risk Management Program. We mix aqua ammonia solution with other fertilizers to make various grades of liquid fertilizer and/or micro nutrients. The liquid fertilizer or micro nutrients are plant foods applied to the soil for growing agricultural crops. Aqua ammonia is stored on site in one 30,000 gallon stationary storage tank, within concrete secondary containment. This storage tank is our largest single storage vessel at our facility and it contains 228,000 pounds of 24% aqua ammonia, representing approximately 65,000 pounds of ammonia. Wor st case scenario Our worst case scenario is the loss of the total contents of the one 30,000 gallon storage tank to the secondary containment dike released as a liquid over 74.5 minutes with ammonia being released as a vapor. The maximum quantity released would be 65,000 pounds of ammonia. According to DEGADIS modeling, this release (distance to point of dispersion to 200 PPM) would have off site impact. Alternative Release Scenario The most common alternative release scenario from our facility would not reach an end-point off-site. The alternative release scenario modeled for the purposes of this plan is a pipe leak, from a stationary storage tank resulting in a 2,000 pound release of aqua ammonia over 43.2-minutes. The total amount of ammonia released in this scenario would be 500 pounds. This release scenario (distance to point of dispersion to 200 PPM) would have off site impact. General accidental release prevention program and chemical-specific prevention steps. The aqua ammo nia system is designed, installed and is maintained in accordance with ASTM standards and the ASME codes. This facility complies with the Office of Indiana State Chemist - Indiana Commercial fertilizer law, API 650 and API 653 tank design and inspection specifications, EPA's Accidental Release Prevention Rule as well as all applicable federal, state and local codes and regulations. Our aqua ammonia system is protected from major releases by relief valves, manual shutoffs and concrete secondary containment. All of the main storage tank valves are locked when not in use. Our aqua ammonia system is inspected on a regular basis with maintenance and preventive maintenance scheduled and documented. Valves, hoses, and relief valves are replaced when necessary and/or according to the guidelines in accordance with Terra policies and industry standards. Training is provided to all employees at least annually, whenever there is a change in the process or whenever competency with the regulation s is questioned. The training consists of classroom lecture, current videos, testing and certification and on the job training. Five-year accident history. There has been no accidents involving aqua ammonia that caused deaths, injuries, property or environmental damage including evacuations on or off-site. Emergency Response Program. In the event of an emergency involving our aqua ammonia system, it is our policy to notify the local community fire department and request that they respond to the emergency. In preparation for this, we have coordinated with all of the local response agencies by providing information and facility tours to ensure that they are familiar with and properly prepared for an incident at our facility. This will help to ensure that our community has the strategy for responding to and mitigating the threat posed by an aqua ammonia release. This complies with the requirement for our facility to be included in the community emergency response plan prepared u nder EPCRA and coordinated with our LEPC. In addition, Terra has an Emergency Response and Contingency Plan for each facility that complies with the requirements of OSHA (29 CFR 1910.38 and 1910.1200). The plan includes public notification, provisions for initial medical care, evacuations and LEPC coordination. Planned changes to improve safety. We do not plan to make any changes to the physical site. We will continue to provide our employees with ongoing annual training to ensure that they are current with all of the safe ammonia transfer and handling procedures, and provide regular inspection and maintenance on all of the aqua ammonia equipment. |