Terra International, Inc. (Mark Center, OH) - Executive Summary
Terra International, Inc. - Mark Center, OH |
Certification Statement for the Risk Management Plan, Program 2, Anhydrous Ammonia
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.
____________________________ Mike Cook
Signature Print Name
Executive Summary - Anhydrous Ammonia
Accidental Release Prevention and Emergency Response Policies:
This facility complies with the 1989 ANSI K 61.1 "Safety Requirements for the Storage and Handling of Anhydrous Ammonia". 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 Environmental, Health,
and Safety (EHS) group to maintain 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 anhydrous 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 month
ly safety meetings, conduct employee training, and act as the location's contact with the corporate EHS group. The site safety coordinator acts as the location's emergency contact.
Description of our Facility and the Regulated Substances Handled:
This facility is a wholesale farm supply distribution center. We store and distribute a wide variety of pesticides and fertilizers including anhydrous ammonia. Anhydrous ammonia is received by truck and rail, is handled and stored on-site, and is a substance regulated by the EPA requiring us to comply with the Risk Management Program. We sell anhydrous ammonia to grower customers in 1,000 gallon nurse tanks. The customer applies the ammonia into the soil as a source of nitrogen fertilizer for growing agricultural crops.
This facility maintains approximately 36 / 1,000-gallon nurse tanks for customer delivery. Our combined storage capacity in nurse tanks is 170,000 pounds. Anhydrous ammonia is stored in 2 stationary storage tanks [1 @ 30
,000 gallons; 1 @ 12,000 gallons] on site. The maximum storage capacity of the stationary storage tanks is 196,000 pounds of anhydrous ammonia. In addition, anhydrous ammonia may be stored temporarily in up to 2 rail cars. The maximum quantity of anhydrous ammonia that may be stored in rail cars is 320,000 pounds. Therefore, the total facility anhydrous ammonia storage capacity is 686,000 pounds. The largest single storage vessel at our facility contains 160,000 pounds.
Worst Case Scenario:
Our worst case scenario is the loss of the total contents of the 80 ton rail car, when filled to the greatest amount allowed (85% of capacity), released as a gas over 10 minutes, resulting in total vaporization. The maximum quantity released would be 160,000 pounds. According to DEGADIS modeling, this release (distance from point of dispersion to 200 ppm) would have off-site impact. It should be noted that Terra has never had a release of an entire stationary anhydrous ammonia storage tank f
rom any distribution facility.
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 purpose of this plan is a 2-minute release from a stationary storage tank representing a valve and hose failure requiring a manual shut down. The total amount of anhydrous ammonia released in this scenario would be 27,000 pounds. This release scenario (distance from point of dispersion to 200 ppm) would have off-site impact. It should be noted Terra has not had a release of this type from any distribution facility.
General Accidental Release Prevention Program and Chemical-Specific Prevention Steps:
The anhydrous ammonia system is designed, installed, and maintained in accordance with ASTM standards and ASME codes. This facility complies with the ANSI K 61.1 standards (1989), OSHA (29 CFR 1910.111), EPA's Accidental Release Prevention Rule, and all applicable federal, sta
te, and local codes and regulations.
Our ammonia system is protected from major releases by internal excess flow valves, check valves, relief valves, manual shutoffs, and emergency shutoff valves. The load-out risers used for the purpose of filling the nurse tanks are protected by excess flow valves and fill line breakaways to immediately stop the flow of ammonia if a line or a hose fails. All main storage tank valves and riser valves are locked when not in use.
Our ammonia system is inspected on a regular basis with maintenance and preventive maintenance scheduled and documented. Liquid and vapor valves, hoses, excess flow valves, gauges, and relief valves are replaced when necessary and according to the guidelines in the ANSI standards.
Training is provided to all employees at least annually, whenever there is a change in the process, or whenever competency with the regulations is questioned. The training consists of classroom lecture, current videos, testing and certification, an
d on the job training.
Five-year Accident History:
There have been no accidents involving anhydrous 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 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 ammonia release. This complies with the requirement for our facility to be included in the community emergency response plan prepared under 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 provisions for public notification, 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 safe ammonia transfer and handling procedures. We will also provide regular inspection and maintenance on all of the ammonia equipment.