Fuller Fertilizer, Inc. - Executive Summary |
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Accidental Release and Emergency Response Policies Fuller Fertilizer takes a proactive approach to chemical safety. This approach includes the following: Isolation - Our facility is located in a rural setting away from large urban centers and institutions. The nearest school is almost 10 miles and the nearest city of over 2000 in population is 13 miles. Prevention - Our anhydrous ammonia facility was only recently installed (1997). All welding and pipe fitting was done by an Illinois State certified installer. After installation the system was hydrotested to insure integrity of the tank and plumbing. History - Our Company has been handling anhydrous ammonia at this facility since 1968 without a significant release. Management has been passed on through the family and the current manager has over 20 years experience. Commitment - We are committed to continuing our excellent record through timely maintenance and regular operator training. Caution - We have an emergency managem ent plan and are in regular contact with local emergency responders. Regulated Substances Handled Our facility is a retail supplier of fertilizers, agricultural chemicals and seed. We do not manufacture products, only warehouse and deliver. The only product stored at our facility that is covered under RMP is anhydrous ammonia. We have the capacity to store a total of about 100 tons of anhydrous ammonia in three large storage tanks. The actual average quantity stored at any given time will probably be about 70 tons or less. We actively operate the anhydrous ammonia facility only about three months in the spring and two and one half months in the fall. During the off season months our inventory will average about 20 tons and no loading or unloading operations will be performed. Worst-case Release Scenario Our worst-case release scenario assumes a complete hose failure during a transfer operation. It is assumed that the tank is full, all automatic flow limiters fail and personn el are unable to stop the release resulting in a total loss of the product. We calculated the potential off-site movement using the DEGADIS model. Due to the presence of nearby trees and buildings we used the urban terrain model. Under this model off-site movement would be limited to 1.16 miles downwind. The worst-case scenario is unlikely since written procedures, employee training and equipment inspections would reduce the chances of a sudden hose failure or accidental drive-off. Even if a transfer hose failure occurs, excess flow limiters would immediately close to slow or eliminate the release. Alternative Release Scenario The alternative release scenario also assumes a complete hose failure during a transfer operation, however this time human intervention will stop the release after two minutes. Again all automatic flow limiters are assumed to fail. We calculated the potential off-site movement using the DEGADIS model and urban terrain. Under this scenario off-site movem ent would be only 0.78 miles. The alternative scenario is the more likely one since partial hose failures, while rare are possible, and employees in the area would be alerted by the sound and odor of the release and would quickly limit the quantity released. General Accidental Release Prevention Our accidental release prevention program includes the following: training, maintenance, inspection and documentation. Training All employees involved in the handling or transport of anhydrous ammonia are trained in the proper operation of the equipment including: normal operating procedures, normal shutdown, maintenance, inspection, emergency shutdown and repair procedures. This training includes Illinois Department of Agriculture training as well as our own hazardous materials training. Maintenance Maintenance and repairs are performed as needed when a problem is identified (leak, faulty valve, etc.) as well as at the startup of each season's use. Problems identified by quarterly inspe ctions are repaired as soon as possible and records of repairs are kept. Inspection All equipment pertaining to anhydrous ammonia is inspected quarterly using a checklist with the results of the inspection documented and follow-up done to be sure identified areas of concern are addressed. An inspector from the Illinois Department of Agriculture inspects the installation semi-annually and follows-up to ensure all repairs are completed. Documentation Forms are used and kept on file for hazard review, quarterly inspections, compliance audits, incident investigations and corrective actions. Employee participation in training programs is also documented. Written procedures have been produced concerning operating, inspecting, maintaining and shutting down of anhydrous ammonia handling equipment. Five Year Accident History No significant accidental releases of anhydrous ammonia have occurred within the last five years. Emergency Response Program The emergency response program for anh ydrous ammonia release is a part of our overall emergency response program. The local fire department has toured and inspected our facility within the last six months and has a copy of our emergency response plan. The plan includes a site map with utility disconnects and safety equipment marked, names and phone numbers of nearby residents and phone numbers for emergency contacts within our company. Also included in the plan are phone numbers for local medical responders and basic first aid measures in case emergency personnel are injured. Planned Changes Planned changes to our facility include improved lighting to make nighttime operations safer and improved security measures to prevent unauthorized tampering with equipment. Respectfully Submitted, Keith Fuller, Manager |