Du-al Gas - Executive Summary |
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Risk Management Plan Du-al Gas, Inc. - Friesland, WI Prepared for: Ms. Orval Bronkhorst Du-al Gas, Inc. 109 Richland Street Friesland, WI 54703 Prepared by: Liesch Environmental Services, Inc. 6000 Gisholt Drive, Suite 203 Madison, WI 53713 (608) 223-1532 JN: 71052.00 July 8, 1999 James J. Fleischmann David Macdonald Project Manager/Air Services Principal EXECUTIVE SUMMARY Accidental Release Prevention Policies Du-al Gas, Inc. will work to prevent accidental releases of toxic or flammable substances that could result in a safety hazard to the public or to the workers at the. Facility. Du-al Gas will work with OSHA, U.S. EPA, and the Local Emergency Planning Committee (LEPC) contacts, including both fire department HAZMAT and the Columbia County Emergency Management office, to minimize the potential for any accidental release and to help assure that the facility is prepared to respond in the event of an accidental release. The emphasis of this Risk Manag ement Plan is on anhydrous ammonia, the currently regulated substance identified within the federal regulations. However, Du-al Gas, Inc. has procedures in place to help minimize the chance of accidents related to other potentially hazardous substances stored or handled on site. If an accidental release were to occur, it is the policy of Du-al Gas, Inc. to notify the appropriate emergency contacts. The City of Friesland contracts with a private company that has a HAZMAT response unit that acts as a primary responder in the event of a release of ammonia. Du-al Gas, Inc. would use their emergency response plan as a guide to direct the company's response. The facility maintains a response plan to cover potential releases of ammonia as required by the RMP rules. Description of Facility and Regulated Substance(s) Du-al Gas, Inc. operates a facility that markets both anhydrous ammonia and propane. Anhydrous ammonia is used as a nitrogen source by farmers in the region to promote crop growth. Du-al Gas stores a maximum of 52,740 pounds (10,200 gallons) of ammonia considering administrative limits at 85% of the physical storage vessel capacity to maintain a safe vapor space above the liquid surface. Anhydrous ammonia is stored on-site in excess of the threshold value of 10,000 lbs., identified under the Risk Management Plan (RMP) listing rule, and the substance is therefore included in this Risk Management Plan. The Court of Appeals for the District of Columbia has acted with a "stay of action" regarding propane storage RMP filings, thus the RMP at this time addresses only the ammonia storage. The Off-site Consequence Analysis provided an estimated distance to the listed 0.14 mg/l endpoint of concern identified by U.S. EPA. Worst-Case Release Scenario Description The worst-case release scenario modeling included the following: Substance Scenario Treatment Ammonia Release to concrete berm Winds at 1.5 m/s, nighttime F stability class The worst-case scena rios modeled meet the specifications described in the October 1996 Off-site Consequence Analysis Guidance and 40 CFR Part 68 (the RMP rules). Worst-case scenario modeling uses highest air temperatures and associated stored ammonia temperature, coupled with conservative nighttime wind speed and stability class assumptions. Alternative Release Scenario Description The Alternative Release Scenario was selected by evaluating several more typical events and considering the resulting impact with more typical release rates and atmospheric conditions. The Alternative Release Scenario was identified using the more conservative of the evaluated scenarios. The Alternative scenarios included the following: Substance Scenario Treatment Ammonia Release at actual modeled rate Winds at 4.56 m/s, D stability class The alternative case uses typical circumstances using a highest monthly temperature based on a review of the 50-year average conditions for July (the warmest month) from Ma disons's Truax field National Weather Service reporting station. Results of Off-site Consequence Analysis The Off-site Consequence Analysis resulted in the following predicted distances to the endpoints and population potentially affected: Distance to Endpoint (mi.) Residential Population Worst-case Scenario Ammonia 2.8 1,105 Alternative Scenario Ammonia 0.5 22 The estimated residential population potentially affected is derived using procedures described in EPA's Off-site Consequence Analysis Guidance. These procedures conservatively include the entire area inside of a circle described using the storage vessel at the center and the distance to the endpoint as the radius. Since typical events affect only a relatively narrow sector of this circle, and only a portion of the population would be present at the time, this estimate clearly represents an upper bound for the potentially impacted residential population. General Accidental Releas e Program and Prevention Steps Du-al Gas, Inc. complies with EPA's Accident Prevention Provisions set forth in 40 CFR Part 68 and applicable state and local codes and regulations. The also meets the EPCRA planning requirements for ammonia storage. Related discussion on the prevention initiatives is provided with the data elements in Section 8 of this plan. Five-Year Accident History No reportable incidents related to ammonia storage have occurred. Emergency Response Program In the event of an emergency involving propane or ammonia storage vessels, Du-al Gas, Inc. will notify the Friesland Fire Department HAZMAT team. The emergency response plan (prepared for propane releases under 40 CFR Part 68) will be used for response activity guidance by Du-al Gas, Inc. Because Du-al Gas, Inc. is not a primary responder to any ammonia release, no formal classroom training for response plans (HAZWOPER, 40-hr, etc.) is required. However the facility does train individuals on proper opera ting and maintenance procedures for propane and ammonia storage, with periodic coursework and annual in-house training. Planned Changes to Improve Safety The RMP includes changes, developed in recent years, which have already been implemented to improve safety at the facility. This includes the use of break-away equipment for the transfer hoses to prevent releases in the event of a "pull-away" by transporters of ammonia. In addition, the facility already uses hoses that are constructed to constrict and prevent releases of ammonia in the event the transfer hose encounters a sudden pressure drop if the hose is severed. The facility has been regularly sending individuals to formal courses on operational procedures and maintenance activities offered by nationally accepted firms, and has provided annual safety information at the beginning of the season. The new employees receive on-the-job training from senior personnel regarding equipment safety measures before operating the equip ment. No new changes to the safety plans are anticipated. |