Battle Creek Farmers Cooperative - BC South - Executive Summary |
|
The United States Environmental Protection Agency (USEPA) developed the Risk Management Program (RMP) rule (40 CFR 68) to assist facilities in preventing accidental releases of highly toxic or flammable chemicals. The RMP established three levels of requirements for the program. Programs 1 and 2 are for facilities that pose less risk to the environment and therefore have reduced compliance requirements. Program 1 is designed for "no impact" facilities and has the fewest requirements, while Program 3 is the most stringent of the three levels. The program level for each facility is determined by: Use of regulated substances in threshold quantity Impact of an off-site public receptor (e.g., residence, school, park) North American Industrial Classification System (NAICS) code Five-year accident history OHSA PSM (29 CFR 1910.119) applicability. This facility is regulated under Program 2 requirements under 40 CFR 68.10 because: It stores anhydrous ammonia in excess of the threshold quantity A release from this facility could impact an offsite public Receptor (residence) It does not operate under a NAICS code specified in the rule It is not subject to OSHA PSM (this is a retail facility). 40 CFR Part 68 Subpart G applies to an owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process, as determined under 40 CFR 68.115 Battle Creek Farmers Cooperative - BC South stores more than the threshold quantity of anhydrous ammonia (10,000 pounds) for commercial sale. Therefore, Battle Creek Farmers Cooperative - BC South is required to submit a Risk Management Plan (RMP) as defined in 40 CFR 68.150 by June 20, 1999. The Battle Creek Co-op is committed to operating in a safe and compliant manner. Employees involved in operating the ammonia storage facility are thoroughly trained to identify and understan d the hazards posed by this the transfer process. Process safety and emergency response materials are kept on site and periodically reviewed. Information includes information pertaining to the hazards of ammonia, process technology, process equipment, and emergency response procedures. The stationary source is the Battle Creek Farmers Cooperative - BC South anhydrous ammonia storage facility. The largest ammonia process group (e.g., largest storage tank or group of interconnected tanks) has a storage capacity of 30,000 water gallons (140,000 pounds). The total ammonia stationary storage capacity is 86,000 water gallons or 402,000 pounds (consisting of two 30,000 water gallon tanks and a 26,000 water gallon tank). The facility also stores numerous smaller transportable tanks (nurse tanks) that are actually used in the fertilizer application process. The facility is required to complete one worst-case release scenario per hazardous substance handled [68.165(a)(2)] to determine program applicability. Battle Creek Co-op has chosen to use the DEGADIS+ release model to determine offsite impacts. For this facility, a worst-case release would occur in the event that the largest ammonia storage tanks would rupture and the entire contents would be released to the atmosphere in 10 minutes. The worst-case scenario requires a ground-level release height (0 feet). Ammonia release rate for use of DEGADIS+ is presented below: Sample Ammonia Endpoint Calculation Given: Storage Tank Capacity is 30,000 water gallons ANSI K61.1 filling density = 56 % (of water wt.) Release Rate = Tank Capacity / 10 minutes = (30,000 gal * 8.345 lb/gal water)*(0.56) / 10 min = (250,350 lb)*(0.56) / 10 min = 140,000 (rounded) / 10 min = 14,000 lb/min Results of Worst-Case Ammonia Release Scenario Input of the preceding data into the DEGADIS+ release model, the results indicate a worst-case impac t of 2.1 (rounded) miles for the facility. The worst-case model output summary is included at the end of this section. The rule defines the toxic endpoint of anhydrous ammonia to be 0.14 mg/L. The residential population within a 2.1 mile radius of the facility is 400 (rounded) based on the 1990 US Census data. The facility is required to complete one alternate release scenario per regulated chemical per 40 CFR Part 68.165(a)(2). The alternative release scenario considered is in accordance with the guidelines provided in 40 CFR 68.22 and 68.28. The alternative scenarios chosen for this facility involves a release because of a sudden split in the hose during transfer. While this scenario is still unlikely because the transfer hoses used have multiple layers of rubber and a layer of braided stainless steel wire underneath the outer sheath (to prevent abrasions, cuts, and splits) it is more likely than the worst-case as required by 40 CFR 68.28(b)(i). This scenario i s also the most likely to occur, since overfilling is prevented by a return vapor line to the tank truck making the delivery. The transfer hose rupture area is assumed at 0.5 square inches. Because personnel are always present at the facility during transfer, Battle Creek Co-op personnel will respond within 10 minutes. Release rate was calculated using the OCAG tank release equation (Section 8.1.1). Results of Ammonia Alternative Release Scenario There are 5 people located within 0.23 miles from the facility. Thus, this alternative release scenario satisfies the conditions of '68.28. The facility maintains written process safety information to enable employees involved in handling ammonia to identify and understand the hazards posed by this process. Written information includes physical properties of ammonia, health risks associated with ammonia exposure, and material safety data sheets. In addition, the facility has conducted and/or implemented the following: hazards review standard operating procedures training program maintenance program compliance audits incident investigation The Battle Creek Farmers Cooperative - BC South anhydrous ammonia facility in Battle Creek has had no recordable accidents within the past five years. Recommendations for safety improvements were identified in the hazard review which was completed June 14, 1999. Recommendations were identified for two categories: Standard Operating Procedures, and Training. Safety improvements will be investigated concerning their impacts on other systems and/or procedures prior to implementation. Additional recommendations may be made upon review of any accidents and/or when the hazard review is updated every five years. |