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Circle T Fertilizer & Seed Co., Inc. - Mt. Hermon

Parent Companies:
Circle T Fertilizer & Seed Company, Inc.
EPA Facility ID:
100000014156
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
Highway 450 North
Mt. Hermon, LA 70450
County:
WASHINGTON
Lat / Long:
30.988, -90.321 (Get map)
Method:
Interpolation - Map
Description:
Facility Centroid
Horizonal accuracy:
m
Horizontal reference datum:
Source map scale:

Owner/Operator:

Name:
Circle T Fertilizer & Seed Co. Inc.
Phone:
(504) 839-5449
Address:
1610 Washington
Franklinton, LA 70438
Foreign Address:

Person responsible for RMP implementation:

Name:
Dean Thomas
Title:
Vice-President
Email:

Emergency contact:

Name:
Elton Thomas
Title:
President
Phone:
(504) 839-5449
24-hour phone:
(800) 454-9300
Ext or PIN:
Email:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Full-Time Equivalent Employees:
1
Covered by OSHA PSM:
No
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 15, 1999
Inspecting Agency:
LP Gas Comission
Using Predictive Filing:
No

Processes:

Ammonia Storage
RMP ID:
1349
CBI claimed:
No
Program Level:
2
NAICS:
Farm Supplies Wholesalers (42291)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
56,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
May 27, 1999
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
1246

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ammonia Storage)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
DEGADIS+
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Ammonia Storage)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
DEGADIS+
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

No Prevention Program level 3

8. Prevention Program level 2

Ammonia Storage, Farm Supplies Wholesalers (42291)
Prevention Program ID:
1019
Safety Review Date
April 17, 1999, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • OSHA (Ammonia)
  • ASTM Standards
  • ANSI Standards
  • ASME Standards
Hazards Identified
  • Toxic Release
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Tornado
  • Hurricanes
Process Controls
  • Relief Valves
  • Manual Shutoffs
  • Grounding Equipment
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classroom
  • On the Job
Competency Testing
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 17, 1999, since latest RMP submission
Training Review Date
April 17, 1999, since latest RMP submission
Maintenance Review Date
April 17, 1999, since latest RMP submission
Maintenance Inspection Date
Dec. 15, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
April 17, 1999
Compliance Audit Change Completion Date
June 20, 1999
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

9. Emergency response

Facility In Community Plan:
No
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
May 17, 1999
Local Response Agency:
Local Response Agency Phone:
(504) 839-3515
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary


10124 LDEQ Facility ID Number

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. Circle T Fertilizer &
Seed Company, Inc. - Mt. Hermon Plant stores more than the threshold
quantity
of anhydrous ammonia (10,000 pounds) for commercial sale as fertilizer.
Therefore, Circle T Fertilizer & Seed Company, Inc. - Mt. Hermon Plant
is required to submit a Risk Management Plan (RMP) as defined in 40 CFR
68.150 by June 20, 1999.

Circle T Fertilizer is committed to operating in a safe and compliant
manner. Empl
oyees involved in operating the ammonia storage and
transfer 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 Circle T Fertilizer & Seed Company, Inc. -
Mt. Hermon Plant anhydrous ammonia storage and transfer facility. The
largest process group (e.g., storage tanks or group of interconnected
tanks) has a storage capacity of 12,000 water gallons (56,000 pounds).
The total stationary storage capacity is 56,000. 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 40 CFR 68.165(a)(2) to determine program applicability. Circle T
Fertilizer has chosen to use the DEGADIS+ to determine offsite impacts.

Worst-Case Scenario Parameters
1. Land Use - Rural
2. Release Qty - 56,000 lb
3. Release Rate - 5,600 lb/min
4. Release Duration - 10 min

For this facility, a worst-case release would occur in the event that a
primary ammonia tank 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). Release calculations
are
presented below:

Sample Endpoint Calculation

Given: The Storage Tank Capacity is 30,000 water gallons
ANSI K61.1 filling density = 56 % (of water wt.)

Release Rate = Tank Capacity / 10 minutes
= (12,000 gal * 8.345 lb/gal water)*(0.56) / 10 min
= (100,140 lb)*(0.56) / 10 min
= 56,000 (rounded) / 10 min
= 5,600 lb/min

Input of the preceding data into
DEGADIS+ model, the results indicate a
worst-case impact of 1.5 miles for the facility. The rule defines the
toxic endpoint of anhydrous ammonia to be 0.14 mg/L. The residential
population within a 1.5 mile radius of the facility is 300 (rounded)
based on the 1990 US Census data.

The facility is required to complete one alternate release scenario 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. Alternative release parameters are presented below:

Alternative Scenario Parameters

1. Land Use - Rural
2. Release Qty - 600 lb
3. Release Rate - 60 lb/min
4. Release Duration - 10 min

The alternative scenario 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 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, Circle T Fertilizer personnel
will respond within 10 minutes. Release rate was calculated using the
OCAG tank release equation (Section 8.1.1).

Input of the preceding data into DAGADIS+ revealed an alternative
release scenario impact of 0.23 miles for the facility. There is an
estimated impact on 5 people located within 0.23 miles from the
facility. The amount of ammonia that would have to be released to
reach this residence is as unlikely as the worst-case scenario. Thus,
this alternative release scenario satisfies the conditions o
f 68.28.
There is no population impact from the alternative release scenario.

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 Circle T Fertilizer & Seed Company, Inc. - Mt. Hermon Plant
anhydrous ammonia facility in Franklinton has had no recordable
accidents within the past five years.

Recommendations for safety improvements were identified in the hazard
review which was completed April 17, 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.