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Tanner Industries, Inc.

Parent Companies:
Tanner Industries, Inc.
EPA Facility ID:
100000048995
Other ID:
Facility DUNS:
0
Parent Company DUNS:
39026802

Location:

Address:
15257 Highway 1064
Natalbany, LA 70451
County:
TANGIPAHOA
Lat / Long:
30.547, -90.474 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Tanner Industries, Inc.
Phone:
(215) 322-1238
Address:
735 Davisville Road
Third Floor
Southampton, PA 18966
Foreign Address:

Person responsible for RMP implementation:

Name:
David B. Binder
Title:
Dir. Quality and Regulatory Affairs
Email:

Emergency contact:

Name:
David B. Binder
Title:
Dir. Quality & Regulatory Affairs
Phone:
(215) 322-1238
24-hour phone:
(800) 643-6226
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(215) 322-1238
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Tangipahoa Parish LEPC
Full-Time Equivalent Employees:
1
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 21, 2012
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

NH3 Distribution
RMP ID:
1000052205
CBI claimed:
No
Program Level:
3
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
1,152,250
No
Public OCA Chemical
0
No
Aqua Blending
RMP ID:
1000052206
CBI claimed:
No
Program Level:
3
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (conc 20% or greater)
7664-41-7
869,815
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 6, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000042350

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 NH3 Distribution)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
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 NH3 Distribution)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Wind speed (meters per sec):
1.80
Stability class:
B
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Excess flow valve
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers
Public OCA Chemical (in Aqua Blending)
CBI claimed:
No
Percent weight:
29.0
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Wind speed (meters per sec):
1.40
Stability class:
B
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

Sept. 18, 2009 at 16:30
ID:
1000033745
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Duration:
1 minutes
Chemicals involved:
  • Ammonia (conc 20% or greater)
Release events:
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
None
Temperature:
78.00 ℉
Atmospheric stability:
Precipitation present:
Yes
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
21
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised operating procedures
  • Revised emergency response plan

7. Prevention: Program level 3

NH3 Distribution, Other Chemical and Allied Products Merchant Wholesalers (42469)
Prevention Program ID:
1000044111
Safety Review Date
Jan. 20, 2014, since latest RMP submission
PHA Update Date
Dec. 16, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Alarms
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Increased Inventory
  • Process Detection
  • Perimeter Monitoring
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 1, 2013, since latest RMP submission
Training Review Date
April 1, 2010, since latest RMP submission
Maintenance Review Date
March 22, 2013, since latest RMP submission
Maintenance Inspection Date
May 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 3, 2014
Management of Change Review Date
April 24, 2009
Pre-startup Review Date
Oct. 9, 2012
Compliance Audit Date
June 15, 2011
Compliance Audit Change Completion Date
June 15, 2014
Incident Investigation Date
Jan. 31, 2013
Incident Invest. Change Completion Date
Feb. 20, 2013
Participation Plan Review Date
May 15, 1999
Hot Work Review Date
May 15, 1999
Contractor Safety Review Date
July 15, 2010, since latest RMP submission
Contractor Safety Eval. Date
Jan. 14, 2014, since latest RMP submission
Aqua Blending, Other Chemical and Allied Products Merchant Wholesalers (42469)
Prevention Program ID:
1000044112
Safety Review Date
Jan. 20, 2014, since latest RMP submission
PHA Update Date
Nov. 19, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Increased Inventory
  • Process Detection
  • Perimeter Monitoring
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 14, 2014, since latest RMP submission
Training Review Date
April 1, 2010, since latest RMP submission
Maintenance Review Date
March 22, 2013, since latest RMP submission
Maintenance Inspection Date
May 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 18, 2013
Management of Change Review Date
April 24, 2009
Pre-startup Review Date
Dec. 12, 2013
Compliance Audit Date
June 15, 2011
Compliance Audit Change Completion Date
June 15, 2014
Incident Investigation Date
Feb. 24, 2014
Incident Invest. Change Completion Date
Feb. 24, 2014
Participation Plan Review Date
May 15, 1999
Hot Work Review Date
May 15, 1999
Contractor Safety Review Date
July 15, 2010, since latest RMP submission
Contractor Safety Eval. Date
Jan. 14, 2014, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
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:
Oct. 31, 2013
Local Response Agency:
Local Response Agency Phone:
(504) 748-9602
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Executive Summary

Risk Management Plan:



Toxic Material: Ammonia



Facility:

Tanner Industries, Inc.

Hwy. 1064 & Railroad Crossing

Natalbany, LA 70451



Corporate Headquarters:

Tanner Industries, Inc.

735 Davisville Road

Third Floor

Southampton, PA. 18966



Corporate contact for further information:

David B. Binder

Telephone: 215-322-1238

Fax: 215-322-7791

Internet Site: www.tannerind.com

E-Mail: dbinder@tannerind.com



Company and Facility History:



Tanner Industries, Inc. is a third generation family owned and operated distributor of anhydrous and aqua ammonia, headquartered in Southampton, PA. The Tanner family started out in the ammonia business in 1954 with the purchase of National Ammonia Company in Philadelphia, PA. The company has grown to its current through the acquisition of three other ammonia companies, Bower Ammonia and Chemical Co. in 1971, Northeastern Ammonia Co. in 1985, and Hamler Industries in 1991. This particular facility was established in 1996.



The mission of Tanner Industries, Inc. is to constantly improve our products and services to meet or exceed our customer's needs, to distribute our products in a safe, efficient and environmentally responsible manner, and to generate a reasonable return in order to provide continuity for the business and employment for our employees.



Tanner Industries, Inc. is firmly committed to a fully effective implementation of the Risk Management Plan (RMP) as it applies to the safe distribution of ammonia. Our commitment to Responsible Distribution (RD) provides our company with an integrated environmental, health, safety, security, and product stewardship program that is supported by our strong corporate capabilities. Our dedication to the proper distribution and stewardship of ammonia includes involvement in emergency response training for first responders and other industry personnel to enhance the protection of our employees and community neighbors.

Tanner Ind
ustries, Inc. is a distributor of anhydrous ammonia. We are not a manufacturer. The material is transported to our facility by rail car or tank truck and then transferred from this equipment to either our on-site storage vessels or transport cargo tanks. From the storage vessels the material can be repackaged for bulk or non-bulk distribution to end-users.



At this facility, blending of a product we call "aqua ammonia" is also performed. This material, ammonium hydroxide, is a solution of ammonia and water. In order to avoid minor releases of anhydrous ammonia vapor, our handling processes institute closed loop systems that capture the ammonia gas in water. This solution is transferred into a process vessel where the volume is increased and the ammonia concentration standardized for distribution into the commercial market. This product, even at low concentrations, is still a hazardous material due to the ammonia that vaporizes off of it.



Benefits and Uses of Ammonia:

Ammonia is a basic chemical that has many common manufacturing and practical uses. The largest users of ammonia are agricultural industries. Ammonia itself is applied directly by farmers as a fertilizer. Some agricultural businesses combine ammonia and other chemicals and nutrients to form more complex fertilizers. Other common products that are made with ammonia include textiles, pharmaceuticals, cleaning solutions, dyes, inks and food packaging products. Ammonia is also used by some companies in various processes. Ammonia is recognized as an "ozone safe" refrigerant. This means that, unlike other refrigerants, any ammonia releases into the atmosphere will not harm the earth's ozone layer. Besides refrigeration, Ammonia is used in some common processes like drinking water purification, air and water pollution control, waste treatment, reprographics, and the heat treating or hardening of metal parts.



Potential Health Effects of Ammonia:

Even in small concentrations, ammonia is irritating to th
e eyes, throat and breathing passages. Accompanied with a very pungent odor, ammonia can be said to be "auto-repulsive". These characteristics provide us with an early warning of the material's presence and force us to retreat from ammonia contaminated atmospheres. High concentrations could have more serious health effects. These could include convulsive coughing, difficult and painful breathing, eye damage and in extreme cases, death. Liquid ammonia or ammonia solution contact of the eyes or skin can produce serious chemical burns requiring prompt medical attention.

Employees and contractors who work around ammonia should take the extra precautions of reviewing Material Safety Data Sheets/ Safety Data Sheets, wearing appropriate safety equipment and participating in special training programs as prescribed by the US Occupational Safety and Health Administration.



Safety Improvement Process:

Safety improvement is a corporate wide philosophy. Tanner Industries, Inc. continuously searches for ways to improve safety performance. Each facility has an individual, or individuals, that have been designated as the site safety representative(s). Each site representative(s) meets on a periodic basis with management to review safety concerns at our sites as well as at our customer facilities. The management representatives of the each site report directly to the corporate safety committee. The corporate safety committee is comprised of upper management, compliance personnel, headquarters employees, and field personnel that are familiar with plant processes. This committee meets on a regular basis to review accident and injury investigations, evaluate site specific issues, and provide recommendations and implementation guidance. Also, qualified personnel periodically inspect and evaluate each facility to assess safety and maintenance conditions. The results of these facility inspections are reported directly to upper management and the operations department. As a whole,
these systems provide Tanner Industries, Inc. with a continuous process for the identification of safety improvement opportunities thus reducing any risk to our society associated with a release of this important chemical.





What Tanner Industries, Inc. Does to Keep Us Safe

Prevention Policy Statement:

The owners, management and employees of Tanner Industries, Inc. are committed to the prevention of accidental releases of ammonia. Our company has implemented the standards of the US Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia" as well as the published provisions of the American National Standards Institute's (ANSI), K61.1, "Safety Requirements for the Storage and Handling of Anhydrous Ammonia".



Tanner Industries, Inc. is a member of the National Association of Chemical Distributors (NACD) and committed to Responsible Distribution (RD). This process is an initiative of the NACD and its member companies designed to provide a system which promotes continuous improvement in the health, safety, security and environmental performance of all its members. It is designed to be sensitive and responsive to the public concerns about the chemical industry.



As a member of the NACD, Tanner Industries, Inc. is committed to the continuous improvement in the chemical distribution industry's responsible management of chemicals. We pledge to manage our business according to the Codes of Management Practice of the Responsible Distribution Process. These codes pertain to:



1) Risk Management.

2) Compliance Review and Training.

3) Carrier Selection.

4) Handling and Storage.

5) Job Procedures and Training.

6) Waste Management.

7) Emergency Response and Public Preparedness.

8) Community Outreach.

9) Product Stewardship.

10) Internal RD Audits.

11) RD Corrective and Preventive Action.

12) RD Document and Data Control.

13) Security



Tanner Industries, Inc.
is the recipient of the Chemical Education Foundation's 1996 Product Stewardship Award - Chemical Distributor Category, for exhibiting excellence in fostering chemical product stewardship. In 2001, Tanner Industries, Inc. was the recipient of the Facility Leadership Award presented by the Philadelphia Local Emergency Planning Committee (PLEPC) Tanner received the award for its Ammonia Safety & Emergency Response programs that it facilitates. In December 2002, David Binder, Director of Quality, Safety & Regulatory Affairs at Tanner was presented EPA Region III's Partnership Award in recognition of significant efforts towards emergency preparedness, prevention and response programs. In 2009, Tanner Industries, Inc. was presented with the Private Industry Award by the Philadelphia Fire Departments, Hazardous Materials Task Force. This was the first time such an award has been issued by the Hazmat Task Force. Tanner was nominated and received the award for its outstanding support, which has included training programs and training materials, in assisting with the development and excellence of the Hazmat unit. In 2010, David Binder was awarded the "Chairman's Award" by TRANSCAER®, Transportation Community Awareness and Emergency Response is a voluntary national outreach effort that focuses on assisting communities to prepare for and respond to a possible hazardous materials transportation incident. TRANSCAER members consist of volunteer representatives from the chemical manufacturing, transportation, distributor, and emergency response industries, as well as the government. Mr. Binder was honored for the active role he took to ensure the success of the "trailblazing" anhydrous ammonia training program carried out in cities and states across the nation. In 2011, 2012 and 2013 Mr. Binder also received the "Individual Achievement Award" presented by TRANSCAER, in honor of his contributions to hazardous materials transportation safety through participation in the
Transportation Community Awareness and Emergency Response Program. In 2012 and 2013, Tanner Industries, Inc., received the "National Achievement Award" for leadership, commitment, and dedication to the National TRAENSCAER initiative.

Tanner Industries, Inc. uses a variety of safety equipment and specialized procedures to prevent accidental releases of anhydrous ammonia. In support of our policy, following is a typical list of safety equipment and systems employed at this facility.



?Employees are provided with the necessary personal protective equipment to ensure protection from ammonia exposure during the performance of their work functions or emergency escape procedures.



?Pressure relief valves are employed on all storage, transfer and delivery equipment to handle unexpected increases in pressure. Per their operational design, these valves will reset after relieving only the excess pressure. Depending on their situational placement in the process, these valves may be designed to relieve pressures caused from either vapor or liquid.



?Excess flow shut off devices are incorporated throughout the process as prescribed by federal regulation. These valves are designed to stop the flow of liquid material any time their rated flow capacity is exceeded. These valves are designed to prevent the catastrophic release attributed to a storage tank line or valve break.



?Breakaway valves are installed at the unloading platforms. These valves are designed to separate and stop the flow of liquid material, minimizing damage to piping and other equipment.



?Pneumatically actuated emergency shutoff valves (ESVs) are designed to stop the flow of anhydrous ammonia from all stationary storage vessels and rail cars. Several emergency shutoff switches have been placed in easily accessible remote locations throughout the facility. Operation of any one emergency shutoff switch shall activate the closure of all emergency shutoff valves simultaneously.



?Wet probe detectio
n device senses impending trailer overfill and sends a signal to the flow controller to turn off the loading pump. It is normally installed into the vapor return pipeline for an aqua trailer loading process.

?Fixed Ammonia detectors equipped with alarm system.



?Regular facility and equipment inspections ensure safe and proper operating conditions.



?On-going mechanical integrity program.



?Employees are trained in start-up, operation, shut-down and maintenance of all equipment. The facility has a copy of the written Standard Operating Procedures that are required to perform these tasks and employees are required to follow these procedures and encouraged to reference them as needed.



?Employees and contractors receive extensive health care and safety training pursuant to all applicable regulatory guidelines.



?Investigation of any accident, injury, or near miss with the development and implementation of corrective action plans in order to prevent re occurrences at any of our facilities.



?Routine audits and inspections are performed by both Tanner Industries, Inc. management and outside agencies to ensure safe and correct procedures are employed, and to identify areas where safety can be improved.



Off-Site Consequence Analysis:



Release scenarios were modeled using the "Aerial Locations of Hazardous Atmospheres (ALOHA)" software developed by the US Environmental Protection Agency. Off-site receptors have been identified using "LandView " software developed by the US Department of Commerce, Bureau of Census. The off-site area impacted by the release could experience ammonia concentrations of 200 parts per million (ppm). Please refer Section 2, Worst Case Release Scenario of the Risk Management Plan and Section 3, Alternative Case Release Scenario of the Risk Management Plan for further information.



Five Year Accident History:



There has been no unintentional release of either anhydrous ammonia, (listed on chart as anhydrous) or ammonium hy
droxide, (listed on chart as aqua) at this Tanner Industries, Inc. facility in the past five years that meet the US EPA Risk Management Program (RMP) defined reporting requirements.



The following is a list of all unintentional ammonia releases at our facility that have been reported to federal, state and local authorities in the past five years under the requirements of US Environmental Protection Agency's Superfund Amendments and Reauthorization Act (SARA) Title III, Emergency Planning and Community Right to Know Act (EPCRA). None of these releases, to our knowledge, resulted in any adverse impacts to the community, the environment or our employees.



Quantity Released (Anhydrous) 2009 2010 2011 2012 2013

Greater than 1,000 pounds 0 0 0 0 0

100 to 1,000 pounds 0 0 0 0 0

10 to 100 pounds 0 0 0 0 0

Less than 10 pounds 0 1 1 1 0



Quantity Released (Aqua Ammonia) 2009 2010 2011 2012 2013

Greater than 1,000 pounds 0 0 0 0 0

100 to 1,000 pounds 0 0 0 0 0

10 to 100 pounds 1 0 0 0 0

Less than 10 pounds 0 0 0 0 0









Emergency Response Procedures:



Emergency Response Policy Statement:

The owners, management and employees of Tanner Industries, Inc. are prepared to cooperate with local emergency responders and other authorities to mitigate any release and minimize the impact of any release to the community, the environment, and our employees. To be prepared for any potential chemical accidents, our company communicates regularly with the Local Emergency Planning Committee (LEPC) and local fire departments.



The facility has a written emergency action plan in accordance with US Occupational Health and Safety Administration (OSHA) standard 29 CFR 1910.38. We have provided state and local authorities the Emergency Planning and Community Right to Know (EPCRA) information as required by the US Environmental Protection Agency's SARA Tit
le III standard. Also, our company has an Emergency Response Plan/Program, in accordance with OSHA standard 29 CFR 1910.120 (q), including pre-emergency planning and employee, customer and, public emergency responder training programs that are specific to anhydrous and aqua ammonia.











Sheltering in place is considered to be a proven method for protecting people in the event of an accidental release. To shelter-In-Place do the following:



1) Move inside immediately (building or vehicle).

2) Close all windows and doors.

3) Turn off ventilation systems.

4) Go into and seal a room (use tape, towels etc. to seal doors and windows if possible).

5) Use radio, phone, etc. for communications