Morrow County Grain Growers, Inc., Ione - Executive Summary
Risk Management Plan (RMP) - Ammonia |
Morrow County Grain Growers, Inc.
1. Accidental Release Prevention and Emergency Response Policies
We at Morrow County Grain Growers, Inc. in Ione are strongly committed to employee, public, and
environmental safety. This commitment is an inherent part of our comprehensive accidental release
prevention program that covers areas such as design, installation, operating procedures, maintenance,
and employee training associated with the processes at our facility. It is our policy to implement
appropriate controls to prevent possible releases of regulated substances. If such a release does
occur, our trained emergency response personnel are at hand to control and mitigate the effects of
the release. We also coordinate our response efforts with the Ione Fire Department, which p
additional emergency response expertise.
2. Stationary Source and Regulated Substances Handled
Our facility's primary activities include support services for crop production. We have anhydrous
ammonia stored in an 18,000-gallon tank at our facility in Ione (Figure 1). The maximum amount
stored is 15,300 gallons (78,733.8 pounds) at the maximum fill capacity of 85%.
3. Worst Case Release and Alternative Release Scenarios
We utilized RMP PRO for the worst case and alternate case scenarios of the required offsite
consequence analysis for our facility. The following details these scenarios.
The worst case release scenario involves a catastrophic release of the entire contents of the
anhydrous ammonia storage tank (78,733.8 pounds) in gaseous form over a 10-minute period. At
Class F atmospheric stability, 1.5 m/s wind speed, and urban topography, the maximum distance to
a toxic endpoint of 0.14 mg/L is 4.2 miles (Figure 2). The estimated population within a 4.2-mile
ius of this facility is 400.
The alternative release scenario involves a release from an anhydrous ammonia product line. The
scenario involves the release of 7,616.42 pounds of ammonia in a gaseous form over a period of 30
minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14
mg/L of ammonia is 0.31 mile (Figure 3). The estimated population within a 0.31-mile radius of the
facility is 40.
4. General Accidental Release Prevention Program
Our facility has taken all the necessary steps to comply with the EPA's accidental release prevention
requirements as set forth in 40 CFR part 68. The following sections briefly describe the elements
of the release prevention program that is in place at our stationary source.
Process Safety Information
Morrow County Grain Growers, Inc. maintains a detailed record of safety information that describes
the chemical hazards, operating parameters, and equipment designs associated with all processes
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are
identified and controlled effectively. Any findings from the hazard analysis are addressed in a
Morrow County Grain Growers, Inc. maintains written operating procedures to ensure that activities
within our covered processes are conducted safely. These procedures address various modes of
operation; the information is regularly reviewed and is readily accessible to operators involved in
the processes (Appendix B).
Morrow County Grain Growers, Inc. has a comprehensive training program in place to ensure that
employees who are operating processes are competent in the operating procedures associated with
Morrow County Grain Growers, Inc. conducts documented maintenance checks on process
equipment to ensure proper operation. Maintenance checks are conducted by qualified person
with previous training in maintenance practices. Examples of process equipment that would receive
maintenance checks include: pressure vessels, storage tanks, piping systems, relief and vent systems,
emergency shutdown systems, controls, and pumps. Any equipment deficiencies identified by the
maintenance checks are corrected in a safe and timely manner (Appendix C).
Management of Change
Written procedures are in place at Morrow County Grain Growers, Inc. to manage changes in
process chemicals, technology, equipment, and procedures. Process operators, maintenance
personnel or other employees whose job tasks are affected by a modification in process conditions
are promptly notified of the modification and offered training to deal with it.
Morrow County Grain Growers, Inc. routinely conducts pre-startup safety reviews related to new
processes and modifications in established processes. These reviews are conducted to confirm that
construction, equipment, and
operating and maintenance procedures are suitable for safe startup prior
to placing equipment into operation.
Morrow County Grain Growers, Inc. conducts compliance audits on a regular basis to determine
whether the plan's provisions, set out under the 40 CFR part 68, are being implemented. Any non-
compliance issue discovered during the audit is promptly corrected.
Morrow County Grain Growers, Inc. truly believes that process safety management and accident
prevention is a team effort. Company employees are strongly encouraged to express their views
concerning accident prevention issues and to recommend improvements. In addition, our employees
have access to all information created as part of the facility's implementation of the RMP,
particularly information resulting from process hazard analyses.
5. Five-year Accident History
Morrow County Grain Growers, Inc. has had an excellent record of preventing accidental releases
over the last 5 y
ears. Due to our stringent release prevention policies, no accidental release has
occurred during this period.
6. Emergency Response Plan
Morrow County Grain Growers, Inc. maintains a written emergency response plan to deal with
accidental releases of hazardous materials. The plan addresses all aspects of emergency response
including first aid and medical treatment, evacuations, and notification of local emergency response
agencies and the public (Appendix A).