Battle Creek Farmers Cooperative - Osmond, NE - 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 - Osmond, NE stores more than the threshold quantity of anhydrous ammonia (10,000 pounds) for commercial sale. Therefore, Battle Creek Farmers Cooperative - Osmond, NE 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 understand 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 - Osmond, NE anhydrous ammonia storage facility. The largest ammonia process group (e.g., largest storage tank or group of interconnected tanks) is a railcar that has a storage capacity of 33,400 water gallons (156,000 pounds) parked at a rail siding at the facility. The railcars are used when an outside contractor converts anhydrous ammonia (using a T-reactor) and other items into 10-34-00 fertilizer at this facility. This process is in operation about 12 days per year. The total ammonia stationary storage capacityconcists of: up to three railcars with 33,400 water gallons of storrage (468,000 for three railcars) for tempora ry storage capacity 30,000 water gallons and an 18,000 water gallon storage tanks or 224,000 pounds of permanent storage capacity 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 and propane 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 33,400 water gallons ANSI K61.1 fillin g density = 56 % (of water wt.) Release Rate = Tank Capacity / 10 minutes =(33,400 gal * 8.345 lb/gal water)*(0.56) / 10 min = (278,000 lb)*(0.56) / 10 min = 156,000 (rounded) / 10 min = 15,600 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 impact of 2.22 (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 2.22 mile radius of the facility is 800 (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 ch osen for this facility involves a release because of a sudden split in the hose during transfer at the largest permanent storage tank. 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 is 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 2 people located within 0.23 miles from the facility. Thus, this alternative re lease scenario satisfies the conditions of '68.28. Results of Propane Alternative Release Scenario Input of the preceding data into the RMP Comp program, the results indicate an alternate case impact of 0.05 miles for the facility. The residential population within this radius is 0 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 - Osmond, NE anhydrous ammonia facility in Osmond 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. |