Brems - Executive Summary |
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EXECUTIVE SUMMARY Brems 1. Accidental release prevention and emergency response policies: In this distribution facility, initially constructed in 1978, we handle anhydrous ammonia which is considered hazardous by EPA. We are committed to the prevention of accidental releases of this product at our facilities. It is necessary to observe certain safety precautions in handling anhydrous ammonia to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle anhydrous ammonia, combined with the safety devices inherent in the design of this facility combined with the safe handling procedures that we use and the training of our personnel. Our emergency response program for anhydrous ammonia is based on the ANSI K-61.1 standard, "Safety Requir ements for the Storage and Handling of Anhydrous Ammonia", and the OSHA standard 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia". The facility has a written emergency action plan, in accordance with OSHA Standard 29 CFR 1910.38; has provided state and local authorities the emergency planning and right-to-know information as required under SARA Title III (EPCRA); has coordinated response actions with the Knox Fire department, including pre-emergency planning and emergency training, and has verified that the County Emergency Plan includes the facility in the event of a release of regulated substances; and, has instructed employees on procedures for notification of the local fire authority (Knox Fire Department ) and notification of any potentially affected neighbors. 2. The stationary source and regulated substances handled. anhydrous ammonia This facility receives, stores, and distributes anhydrous ammonia and other agronomic products for retail use by customers for crop production Anhydrous ammonia is received by truck transports and rail and stored in 1 tank. The regulated substance handled at this distribution facility is anhydrous ammonia. The maximum amount of anhydrous ammonia that can be stored at this plant is 131,325 pounds; the maximum amount handled would be 291,325 pounds (including the rail car coupled to the 30,000 gallon ammonia tank). 3. The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. Product: anhydrous ammonia Worst case Scenario: Release of the total contents of the 30,000 gallon ammonia tank filled to 85% capacity coupled to a 100 ton capacity rail car filled to 80% would be released as a gas over 10 minutes. The maximum quantity released would be 291,325 pounds. The distance to the endpoint (point of dispersion to 200 ppm) is 3.5 miles. Alternative Rel ease Scenario: Based on a potential incident of an overfill of the largest storage tank. The distance to the endpoint (point of 200 ppm dispersion) is 1.18 miles. The amount of anhydrous ammonia released would be 11908 pounds. 4. The general accidental release prevention program and the specific prevention steps. This distribution facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. The facility's anhydrous ammonia plant has implemented the ANSI K-61.1 standard, "Safety Requirements for the Storage and Handling of Anhydrous Ammonia", and the OSHA standard 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia"; periodic inspections by the Indiana State Chemists Office are also conducted. The major hazards identified with anhydrous ammonia include toxic release, stress corrosion, overfilling, equipment failure, earthquake, and tornado. Process controls, such as relief valves, check valves, manual shutoffs, al arms and procedures, and excess flow devices are utilized to minimize the potential for release. Mitigation systems available include a deluge or water curtain provided by the responding fire department in the event of a release which would "knock down" the vapor cloud and neutralize the ammonia. Employees are trained on an initial and ongoing basis. Employee Training is provided as well as periodic refresher training available from our Safety Coordinator, industry seminars, and vendor programs. Competency is measured through written and oral testing, demonstration (hands-on), and observation. Maintenance programs are in place. Items are replaced if they fail, present a risk to the user, are required by law or standard, are out-of-date, or if a system or process is changed or upgraded. OSHA 1910.111 standards are used to identify those needs. The Indiana State Chemist also makes periodic unannounced visits to our facility to inspect equipment, tanks, and safety training (they do not always leave documentation). In addition, employees utilizing the equipment on a nearly daily basis informally inspect the equipment for leaks, cracks, soundness, etc. 5. Five-year accident history. We have had no accidental releases of propane or anhydrous ammonia from this facility in the last 5 years. 6. The emergency response program. This facility has an emergency action plan, in accordance with OSHA standard 1910.38. We have coordinated response actions with the Knox Fire Department, including pre-emergency planning and emergency training. We have discussed this program with the Starke County Local Emergency Planning Committee, and our facility is included in the county emergency plan. In the event of a release of regulated substances, our employees have been instructed on the procedures for notification of the local fire authority (Knox Fire Department), emergency personnel, and notification of any potentially affected neighbors. 7. Planned changes to improv e safety. This facility was constructed in 1978. Safety improvement is an ongoing process at our facility. Periodic evaluations are performed to assess the maintenance of safe conditions. This facility is in compliance with the OSHA 29 CFR 1910.111 standard and the ANSI K61.1 standard. The Indiana State Chemist also is in the process of reviewing and updating their requirements for bulk anhydrous ammonia storage facilities. Any updates or improvements required by this change will be implemented as soon as possible.. |