Holland Company, Inc. - Executive Summary |
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1.1 Executive Summary 40 CFR '68.155 1.1.1 Accidental Release Prevention and Emergency Response Policies 40 CFR 68.155(a) Holland Company Inc.'s (Holland Company) accidental release prevention and emergency response policies have been developed to comply with the provisions of 40 CFR Part 68, as promulgated by the U.S. Environmental Protection Agency (EPA). Pursuant to that regulation, every owner or operator of a stationary source that has more than a threshold quantity of an identified regulated substance in a process must develop a Risk Management Program. The regulation sets forth three levels of compliance, designated as Programs. Program levels are determined by the facilities five year accidental release history, the distance to a toxic or flammable under a worst case release assesment, the process' NAICS code and whether the process is subject to OSHA's process safety management standard. Holland Company uses anhydrous ammonia as a part of its alum manufa cturing process. At any one time there may be 45,100 pounds of anhydrous ammonia onsite. This amount exceeds the established threshold quantity for anhydrous ammonia (10,000 lbs.) and subjects Holland Company to the regulation. Alum manufacturing has an NAICS code of 325188 - Other Inorganic Chemical Manufacturing. Holland Company falls within Program 3 requirements because the distance to a toxic endpoint for a worst-case release assessment is less than the distance to any public receptor as defined by 40 CFR 68.3. 1.1.2 The Stationary Source and Regulated Substances Handled 40 CFR ' 68.155(b) Holland Company is a manufacturer of ammonium alum, an inorganic chemical compound. Holland Company's manufacturing process utilizes a stationary 10,000 gallon tank containing anhydrous ammonia. Anhydrous ammonia is a regulated substance and storage of this quantity qualifies Holland Company as a stationary source. 1.1.3 Offsite Consequences Analyses 40 CFR 68.1 55(c) Holland Company's offsite consequences analyses includes consideration of two release scenarios, identified as the worst-case release and the alternative release. The worst-case release is defined by EPA as "the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint." Pursuant to EPA's guidelines, Holland Company has assumed this worst-case to be the total release of the maximum quantity of anhydrous ammonia stored at the facility. The alternative release scenario is defined as one that is "more likely to occur that the worst-case release scenario" and "will reach an endpoint offsite, unless no such scenario exists." Based on a process hazard analysis, Holland COmpany has selected a pipine failure as an alternative release scenario. 1.1.4 Holland Company's Accidental Release Prevention Program 40 CFR ' 68.155(d) Holland Company's accidental release prevention program i s based on several key elements: Training of operators and supervisors Preventive maintenance Use of equipment designed for anhydrous ammonia handling Use of accurate and effective operating procedures written with participation of operators Performance of a hazard review of equipment and procedures Implementation of an auditing and investigation program 1.1.5 Holland Company's Five Year Accident History 40 CFR ' 68.155(e) In the previous five years, Holland Company has had no accidental releases involving anhydrous ammonia. 1.1.6 Holland Company's Emergency Response Program 40 CFR ' 68.155(f) The EPA has interpreted the term response, as used on Subpart E of 40 CFR to exclude "response to incidental releases of hazardous substances where the substances can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance per sonnel." Actions such as "end[ing] a small leak (e.g. shutting a valve) or clean[ing] a spill that does not pose an immediate safety or health hazard" are considered incidental responses that would not require development of an emergency response program. In recognition of the danger that a release of anhydrous ammonia would pose to its employees, it has been the continuing policy of Holland Company to respond only to incidental releases. In the event of a major release, Holland Company will immediately contact local emergency response personnel. The emergency response personnel will have complete authority and control over response actions. This policy exempts Holland Company from the development of an emergency response program. Holland Company has notified the Adams Fire Department of the presence of anhydrous ammonia at its facility and has coordinated response to a major release with the Adams Fire Department. 1.1.7 Planned Changes to Improve Safety 40 CFR 65.155 (g) A Process Hazard Team was convened to review Holland Company's equipment and operating procedures. The members of the team includes a General Manager, Engineer, and Shift Supervisor from Holland Company, as well as an Environmental Regulatory Specialist from Berkshire Environmental Consultants, Inc. The team made several recommendations regarding safety. Holland Company is in the process of reviewing these recommendations and taking actions to improve safety. |