(41) The McGregor Company Adams Retail - Executive Summary
ACCIDENTAL RELEASE PREVENTION PROGRAM |
The McGregor Company
Adams Retail Facility
1. Facility Accidental Release Policy
The owners, management, and employees of The McGregor Company along with the crew of the Adams facility located at Highway 11 Adams, Oregon 97810 are committed to the prevention of any accidental release of anhydrous ammonia or aqua ammonia. If an accidental release should occur, the McGregor Company and the Adams retail facility are prepared to work with the local fire department, or any other authorities to mitigate any release and minimize the impact of the release to people and the environment.
NOTE: See planned changes to improve safety.
2. Facility Information
o The primary activity at the facility is the storage, and handling of anhydrous and aqua, ammonia.
o Anhydrous ammonia and aqua ammonia are received, stored, and distributed as agricultural grade fertilizer to local farmers.
o Anhydrous ammonia is received by t
ruck and stored in one above ground tank(s) .The maximum amount of anhydrous ammonia handled is 80,000 lbs.
oAqua ammonia is received by truck and stored in one above ground tank(s) at the site. The maximum amount of aqua ammonia handled is 151,600 lbs.
3. The Worst-Case Release Scenario and Alternative Release Scenario
a. Anhydrous Ammonia Worst-Case and Alternative Release Scenarios
The worst-case release scenario involves the failure of the largest storage tank when filled to 85% capacity as limited by regulations. The scenario at this facility would release 80,000 pounds of anhydrous ammonia. The distance to the endpoint (the point of dispersion to 200ppm) is 0.94. This figure comes from TFI's DEGADIS model.
The alternative release scenario, is based on the most likely potential incident that might occur at this facility. We used the scenario that a 2" transfer hose would break and release 11,908 pounds of anhydrous ammonia for two minutes. The distance to the endpoint
(point of dispersion to 200 ppm) is 0.56 miles. This figure come from TFI's DEGADIS model.
b. Aqua Ammonia Worst-Case and Alternative Release Scenarios
The worst case scenario involves the failure of the aqua storage tank when filled to the largest inventory level on any given day. Total release of aqua ammonia from this tank would be 151,600 pounds of 20% aqua ammonia in solution. The total amount of this release would be contained within the secondary containment. The secondary containment regulations require that the containment contain at least 125% of the volume of the largest storage tank. This is per Washington State Department of Agriculture WAC 16-201-025. The distance to the endpoint (point of dispersion to 200 ppm) is 0.10 miles. This figure comes from EPA's RMP Comp.
The alternative release scenario is based on the most likely potential incident that might occur at this facility. We use the scenario that a 2" transfer hose would break and release 3,820 pounds of 20
% aqua ammonia solution in five minutes. The concrete loading pad on which the delivery truck was being loaded would contain all of the released aqua ammonia. This is a release from a break in a transfer hose. The distance to the endpoint (point of dispersion to 200 PPM) is 0.10 miles. This figure comes from EPA's RMP Comp.
4. Accidental Release Prevention Program
Anhydrous Ammonia and Aqua Ammonia: The Facility has implemented the provisions of the "Safety Requirements for Storage and Handling of Anhydrous Ammonia, ANSI K 61.1,
"Published by the American National Standards Institute, Inc, the standards of the U.S. Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia." And TFI's "Guidelines for Safe Storage and Handling of Ammonia"
5. Five-year Accident History
a. There have been no accidental releases or near misses of anhydrous ammonia, aqua ammonia, in the past five years that:
o Have caused any deaths, injuri
es, or significant property damage at the facility; nor
o Have resulted in off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
6. The Emergency Action Policy
The facility's emergency action policy was written in accordance with the following
o OSHA 29 CFR 1910.38;
o OSHA 29 CFR 1910.120;
7. Planned Changes to Improve Safety and Facility Accidental Release Policy.
The McGregor Company and its 33 retail fertilizer facilities located in Washington, Idaho and Oregon have an outstanding record on safety and environmental issues. We have an excellent safety and maintenance program and have won several regional, State and national environmental respect awards. Safety and environmental improvements are an ongoing process for the McGregor Company and all of its retail fertilizer facilities.
As a result of the RMP program the McGregor Company will be developing new plans and policies to protect the people who work at
our facilities, our neighbors and the environment. At this time The McGregor Company would ask for an exemption on filing an Emergency Response Plan. We ask that the McGregor Company be exempt until Dec. 31 1999. We apply for this exemption because of information received from EPA 10th District 112 r coordinator. During this time we will develop a complete written Emergency Response plan for all of The McGregor Company retail fertilizer facilities. The written plan would be complete by Sept. 1 1999. Next we will present the plan to all of the employees at our retail facilities. Awareness and training would start right away. Training would be scheduled around fall fertilizer season. All training to be completed by Dec. 31, 1999, As soon as possible or by the end of Jan. 2000 we will submit an updated RMP.