DECATUR - Executive Summary

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Executive Summary 
Mark's Brothers Company, INC. 
A.    Introduction 
This faclity is a retail fertilizer and agri-chemical sales operation.  Bulk and packaged products are stored for eventual sale to the farmer.  This facility unloads anhydrous ammonia from semi tanker trailers or railcars for storage in pressure storage tanks.  The ammonia is then stored for eventual sale and use by our farmer customers. 
This facility has an excellent safety record with no deaths or serious injuries to plant personnel or contractors due to the RMP covered process.  There have been no accidents in the past five years. 
The facility's safety record is a direct result of the emphasis placed on plant safety by management and employees alike.  
B.    Accidental Release Prevention Policies and Program: 
This facility strives to meet or exceed compliance with state ammonia regulations.  The company's Environmental, Health & Safety staff furnishes technical assistance and performs safety and environme 
ntal audits and training on a regular basis. 
The ammonia tank and associated equipment is inspected annually following recommended industry and engineering frequencies.  Pressure tank and pressure lines are tested following pressure vessel testing standards.  
Safety meetings for all employees are held at least every month at this facility.  In addition to safety training classes, each employee has taken numerous computer based training courses. 
We believe safety and environmental stewardship must be second nature to all employees and contractor personnel. 
C.    Emergency Response Policies and Program: 
Each facility employee is trained to be familiar with the Emergency Response policies and procedures through safety reviews and other safety meetings.  The Emergency Response Plan is reviewed on an annual basis as part of employee refresher training.   Safety policies and procedures are also reviewed on an annual basis. 
The Emergency Response Plan is followed in the event of an emergen 
cy.  Included in this plan is the testing of the on-site emergency warning system. 
The Local Emergency Planning Committee and Fire Department personnel are furnished a copy of the Emergency Response Plan and invited to tour the facility on a regular basis. 
The facility Emergency Action Plan covers such things as accidental releases of plant chemicals, natural disasters and emergency response practices and procedures.  The plan is reviewed each year with all employees.  The company maintains seven Hazardous Materials Response Teams throughout the country, ready to respond to emergencies at the plant.  The response teams have undergone extensive training in Hazardous Material Response. 
D.    Worst Case Scenario: 
This facility has one anhydrous ammonia storage tank on-site. The tank is equipped with pressure safety relief valves and excess flow valves.  Based on the worse case scenario as defined by the EPA, there would be public receptors within this location's affected zone. 
The EPA r 
equires a very conservative worst case scenario to be a catastrophic rupture of the largest tank with a complete loss of product over 10 minutes.  
It should be noted that the EPA describes the worst-case scenario as: 
"Because the assumptions required for the worst-case analysis are very conservative, the results likely will be very conservative...These endpoints are concentrations below which it is believed nearly all individuals could be exposed for one half hour to one hour without any serious health effects.  In addition, the worst case analysis is carried out using very conservative assumptions about weather and release conditions.  The distance to the endpoint estimated under worst-case conditions should not be considered a zone in which the public would likely be in danger; instead, it is intended to provide an estimate of the maximum possible area that might be affected in the unlikely event of catastrophic conditions."  (EPA550-B-98-003, Section4.2) 
We believes the chances  
for a catastrophic rupture are extremely unlikely because of the routine testing, facility safety systems, daily inspections, and constant monitoring. 
E.    Alternative-case Scenario: 
The ammonia tank(s) are filled via trucks and/or railcars; then product is transferred to small nurse tanks.   The most likely release scenario would be a rupture of a hose connecting a nurse tank and ammonia transfer system.  The conditions picked for this scenario are those which would create a maximum amount of loss of anhydrous ammonia.  
F.    Five Year Accident History: 
This facility has an excellent safety record with no deaths or serious injuries to any of its personnel or contractors as a result of the RMP covered process. In addition, there have been no accidents resulting in releases of ammonia with off site consequences during the entire operations period. Extensive programs  
and procedures are in place to maintain that record. 
G.    Planned Changes to Improve Safety: 
This facility continuously lo 
ok for ways to enhance the safety of this location.  Monthly safety inspections are conducted which result in corrective actions; annual equipment inspections are conducted; and detailed audit of our ammonia system is conducted at least every three years. 
H.    Summary:   
We and our employees are extremely proud of our safety record and vast improvements made in both environmental stewardship and safety over the last several years.  We believe, with our programs and policies in place and with the continued efforts of our personnel, we will maintain our safety record and our safe plant environment for the public, our customers, and our employees for years to come.
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