Crestland Cooperative, Lenox (NH3) - Executive Summary

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Crestland Cooperative Company 
Risk Management Plan - Executive Summary 
1.  Crestland Cooperative Company (CCC) accidental release prevention policy involves, but is not limited to technologies, procedures, and management practices. All applicable procedures of the ANSI  K-61.1 - 1989 "Safe Requirements for the Storage and Handling of Anhydrous Ammonia", as adopted by the Iowa Department of Agriculture and Land Stewardship (IDALS), are adhered to. The CCC emergency response policy involves the preparation of response plans which are tailored to each facility and to the emergency response services available in the community, and is in compliance with the EPA Emergency Response Program requirements. 
2.  The CCC facility at Lenox is in the business of selling anhydrous ammonia to farm customers as a form of nitrogen fertilizer. The facility has one anhydrous ammonia storage tank(s) with the maximum capacity of 127,000 lbs. of anhydrous ammonia. The location includes anhydrous ammonia 
storage tanks, nurse tank filling risers, electrical panels, lighting, and anhydrous ammonia safety equipment. The facility is manned year round during normal business hours. 
3.  The off-site consequence analysis includes two anhydrous ammonia release scenarios, identified as "worse case release" and "alternative scenario". The first scenario is defined by EPA, which states that "the owner or operator shall assume that the maximum quantity in the largest vessel is released as a gas over 10 minutes due to an unspecified failure. The alternative scenario is defined as more likely to occur than the worst-case release scenario. 
The worst-case release scenario at Lenox involves a failure on the largest anhydrous ammonia storage tank with the capacity of 127,500 lbs. of anhydrous ammonia. The off-site consequence analysis for this scenario was performed by using pre-defined EPA guidelines in RMP-Comp version 1.04 software. 
EPA mandated meteorological conditions were determined by using  
RMP-Comp version 1.04 for both the worst-case release scenario and the alternative release scenario.  
When atmospheric dispersion modeling for the worst-case release scenario was performed using RMP-Comp assumptions, a distance to toxic endpoint of 2.0 miles. An estimate of residential population potentially affected of 1,350 was obtained by using1990 population census figures. 
The alternative scenario involves a one inch diameter puncture which releases 10 percent of the total volumn of the storage tank in ten minutes. 
When atmospheric dispersion modeling for alternative scenario releases was performed using RMP-Comp assumptions, a distance to toxic endpoint of 0.4 miles. An estimate of residential population potentially affected of 1,350 was obtained by using 1990 census figures. 
4. CCC's accidental release prevention plan is based on the following key elements: 
7 Annual training of all personnel required to handle ammonia and what to do in an emergency 
7 Facilities constructe 
d & maintained according to ANSI  K 61.1 - 1989 standards adopted by IDALS in Iowa 
7 Use of usual anhydrous ammonia safety equipment 
7 Use of effective operating procedures according to Agricom's anhydrous ammonia safety procedures handbook and  training videos 
7 Annual inspections by IDALS of storage tanks, piping for leaks, nurse tanks, applicators, transfer risers, riser hoses, safety equipment, pressure relief valve records, etc. 
The CCC Safety Director will inspect this facility twice per year and in conjunction with Insurance Company experts or Regulatory Authorities. 
5.  No accidental releases of anhydrous ammonia have occurred at this facility in the past five years. 
6.  This facility has an emergency response program, which has been coordinated with the Lenox Vol. Fire Department, which is a member of Taylor County LEPC (Local Emergency Planning Committee) in Iowa. This program includes response decision tree and a notification plan. Emergency operations and respo 
nse procedures are reviewed annually, with a site visit of the facility by the Fire Department. 
7.  Changes to improve safety at this facility are completed as required by rule change and/or methods to increase safety and/or efficiency of operations.
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