HARLESS OIL COMPANY - Executive Summary |
|
FACILITY POLICY: The owner, mangement, and employees operating our facility are committed to the prevention of any accidental release of hazardous chemicals transported or stored on our location. In the event that an accidental release should occur, we are prepared to work with our Local Fire Company(s) Emergency Response Personnel, and other appropriate authorites deemed applicable depending on the specific incident, to best mitigate any; release and to minimize the impact of the release to people and to environment. FACILITY INFORMATION: The primary activity of our company is NAICS code 493l3, "Farm product storage and warehousing facility", however, we are also engaged in providing "agricultural inputs" that include the receiving, storage, and reloading of Anhydrous Amonia for delivery to farmers in our area. This product is subject to the EPA Risk Management Program and is the subject of this plan. Only the facility used for this product will be included in this report. Anhydr ous Amonia is received, stored and distributed for direct application to farm fields during the early spring and late fall months. During the balance of the year, inventories will be stored only with little if any product transfers taking place. The maximum quantity stored had been listed earlier in the RMP and will not be disclosed in this summary. Maximum quantity handled at a given time will be the unloading of a semi-trailer tank. The facility is operated on an "as need" basis with staff present during the receiving and loading of product for delivery. Annual hours for these do not meet the 2080 hour requirement to qualify as a "full time employee" on site; therefore, item number 1.11 is zero. Our facility has adequate lighting, and is inspected day and night during use, and through out the "off season". WORST-CASE RELEASE SCENARIO: The worst-case release scenario would be the release of the total contents of our largest Anhydrous Ammonia tank released as a gas over 10 minutes. The maximum quantity released has been indentified earlier in this program and would effect some residential population. ALTERNATIVE RELEASE SCENARIO: We have not had an actual release of anhydrous amonia during the last 5 years at this site so believe the most likely release would be caused by a break in a transfer hose. Transfer hoses are protected by manual, self-closing excess flow, and "pull away" valves. Our alternative release scenario is based on the loss of contents from the largest hose used for unloading the transportation tanks. ACCIDENTAL RELEASE PROGRAM; Our accidental release program for anhydrous ammonia is based on guidelines found in the American National Sandard Institute (ANSI) "Safety Requirements for the Storage and Handling of Anhydrous Ammonia," and the Occupational Safey and Health Administration (OSHA) standard 29CFR l910.111 "Storage and Handling of Anhydrous Ammonia." Additionally, we conduct annual employee training on the safe handling, transportation, and distribution of Anhydrous Ammonia, and have installed safety equipment including but not limited to: Excess flow valves, Breakaway couplers at risers, Emergency shut-off valves, and Lock outs to prevent tampering when the site is unattended. We maintain routine contact with our local fire department and emergency response personnel, and have provided and/or participate in safety training exercises on Anydrous Ammonia. FIVE YEAR ACCIDENT HISTORY: We have not had a release of anhydrous ammonia within the past five years that has caused death, injury, or significant property damage at the facility. To our knowledge, we have not caused any offsite death, injury, evacuation, sheltering in place, property damage, or environmental damage. EMERGENCY RESPONSE PROGRAM: This facility is included in the written Community Emergency Response Plan as prepared by the Local Emergency Planning Committee (LEPC) and the Nebraska Emergency Management Agency (NEMA). We also in clude these materials in our own Emergency Action Plan in accordance with OSHA 29 CFR 1910.38. We have provided State and Local authorities all Community Right-to-Know information requested as well as that required under SARA Title III (EPRA). Our written employee safety programs include pre-emergency planning and employee training in accordance with OSHA standards, and are offered for review at any time by our Local Emergency Planning Committee to ensure that they conform to the community plan. We actively encourage participation in our Anhydrous Ammonia training program by the local fire department(s), local emergency response team, hazardous materials responders, community planners, etc. that may be expected to respond to an incident at our site. PLANNED CHANGES TO IMPROVE SAFETY: Safety improvement is an on-going process at our facility. Periodic evaluvations are performed to assess the maintenance of safe conditions. There are no additional specific recommendations for imp lementation at this time. ADDITIONAL INFORMATION: For additional information, response to questions, facility tours, or comments, please contact Randy at HARLESS OIL COMPANY, telephone 1-402-765-257l. |