Conklin Company Inc - Executive Summary |
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FACILITY DETAIL AND REGULATED SUBSTANCE HANDLED: Conklin Company is a small chemical manufacturer located in an industrial area in Shakopee. The regulated substance, aqua ammonia (ammonium hydroxide), a 28-30% solution of ammonia and water, is stored on site for use in the production of fertilizer. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: This facility complies with Minnesota Pollution Control Agency and Minnesota Department of Agriculture regulations for the storage and handling of ammonium hydroxide. It is our policy to adhere to all applicable federal, state, and local laws and regulations, and to take additional steps necessary to prevent releases from occurring. Should an accidental release occur, it is our policy to contact the Minnesota Duty Officer to report the incident and request any needed assistance, and to notify the National Response Center in the event of a release of a CERCLA RQ material. Conklin intends to employ the services of a private spill contractor, should a major spill occur that is beyond the capabilities of Conklin's Emergency Response Team to safely handle. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM: The Prevention Program has several components. It includes information on the regulated chemical, process technology, and the equipment involved. A process hazard analysis was used to identify hazards. Operating procedures describe the steps necessary for safely handling ammonium hydroxide from it's being received to its use in production. Operator training and contractor requirements help to ensure the safe handling of ammonium hydroxide and process equipment. Written procedures, equipment inspection and testing, quality assurance, and the training of maintenance personnel are completed to ensure the mechanical integrity of the system. A policy is in place to manage changes to the system to ensure they are reviewed for safety before implementation. Compliance audits ensure all policies are being complied with. WO RST-CASE AND ALTERNATIVE RELEASE SCENARIOS: EPA's RMP Comp software was used for worst-case and alternative release modeling. The minimum toxic endpoint distance provided by this software for any size release is "less than 0.1 mile" (<528 feet). Our worst-case release scenario is a liquid spill and vaporization resulting from the failure of our bulk storage tank, releasing up to 22,500 gallons of aqua ammonia. Administrative controls in the form of written operating procedures limit the maximum aqua ammonia in the 25,000-gallon storage tank to a maximum of 22,500 gallons. Mitigating factors include an epoxy coated solid concrete dike and the fact that the tank and dike are located entirely inside a closed building. The dike serves to limit the exposed surface area of a spill and the building also serves to limit the release rate to outside air, thus reducing the release rate to outside air to 3.52 pounds per minute. This dike and building were constructed in 1998 according to Minnesot a Pollution Control Agency regulations and stringent Minnesota Department of Agriculture regulations. Since the aqua ammonia storage tank was brand new in 1998, a failure of that tank is considered unlikely. The resulting distance to the toxic endpoint extends less than 528 feet (<0.1 mile) from the storage tank; this distance extends off-site and public receptors are located within this distance. Our alternative-release scenario is a liquid spill and vaporization resulting from a transfer hose release, releasing up to 20 gallons of aqua ammonia. Mitigating factors include an emergency shut-off valve located on the bulk tanker truck; the delivery truck operator, by written procedure and standard practice, stands with one hand on this control while unloading. Another mitigating factor is a containment pad to minimize the surface area of a spill, thereby reducing the vaporization rate to 4.22 pounds per minute. The resulting distance to the toxic endpoint extends less than 528 feet (<0. 1 mile) from the receiving area; this distance extends off-site and public receptors are located within this distance. FIVE-YEAR ACCIDENT HISTORY: We have never had an accident involving aqua ammonia that caused deaths, injuries, property or environmental damage, evacuations, or sheltering in place. EMERGENCY RESPONSE PROGRAM: Conklin Company has a written Emergency Response Plan that describes how emergency situations are to be handled. Conklin's employee Emergency Response Team (ERT) is trained to respond to emergency situations including chemical spills. A team member is assigned to notify and communicate with outside agencies in the event of an emergency release. ERT training consists of hands-on spill response, release-reporting requirements, air sampling equipment, personal protective equipment, emergency response procedures, first aid and CPR, and more. PLANNED CHANGES TO IMPROVE SAFETY: The aqua ammonia storage tank, containment dike, and storage building were all newly cons tructed and installed in 1998 in compliance with Minnesota Pollution Control Agency and Minnesota Department of Agriculture rules and regulations. Planned enhancements to improve safety include the installation of a monitor for ammonia vapors. |