Nu-Gro Technologies - Executive Summary

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Executive Summary 
Nu-Gro Facility 
Nu-Gro Technologies is located in Glove Cities Industrial Park, City of Gloversville, Fulton County, NY.  This plant produces the nitrogen component of agricultural fertilizer by reacting urea with UFC-85, sulfuric acid, and sodium hydroxide.  The only regulated substance above the threshold limit at this facility is formaldehyde, which at a 30% concentration by weight in the UFC-85, could represent as much as 56,000 lbs.   The 17,000 gal. tank that holds the UFC-85 is protected by a dike and has it's own containment room separated by walls from the rest of the building.    
Overall Accidental Release Prevention and Emergency Response Policies 
Nu-Gro Technologies is firmly committed to maintaining a safe and healthful working environment for our employees and the public.  We fully intend to comply with all applicable governmental regulations.  To that end, Nu-Gro Technologies, Inc. will provide training, education, information, equipment and contr 
ols necessary to maintain a safe plant environment and a safe and appropriate response to any spills that may occur. 
Worst Case and Alternative Release Scenarios 
The worst case scenario was calculated using RMP*Comp.  Rupture and complete release of UFC-85 tank was considered.  Passive mitigation taken into consideration included diking and enclosed room containment.  Resulting effected radius from the liquid spill and vaporization of formaldehyde was .1 miles.  Actual radius was likely much less, but RMP*Comp defaults to .1 mile as a minimum.  There are about 25 mobile homes and one small business within the .1 mile radius from the storage tank.  Estimated public receptors are 75. 
The alternative release scenario considered is tank spillover from overfilling.  This scenario has occurred in the past.   Once again, the effected radius defaulted to the minimum value of .1 with the same public receptors. 
General Accidental Release Prevention Program 
The prevention program has been  
written to give employees the proper training and procedures to prevent or minimize the consequences of catastrophic releases of UFC-85.  It is based on Part 1910.119 of Title 29 of the Code of Federal Regulations.  All involved employees shall be informed of the potential hazards or upsets in the process where UFC-85 is stored or transferred that may result in releases of UFC-85.  
Five Year Accident History 
There were two reportable accidents in the five-year accident history.  A 9/12/98 event involved a spill of UFC-85 when disconnecting fill lines after transfer was complete.  This spill occurred outside the building.  The amount of formaldehyde released did not meet the 100 pound EPA threshold but exceeded the NYSDEC reportable quantity of 1 pound.  No onsite or offsite consequences were reported.  In January of 1998, an overfill occurred on the UFC-85 tank, resulting in the spill-over of roughly 2,000 gallons into the containment dike and inside of the containment building.  No 
onsite or offsite consequences were reported.  
Emergency Response Program 
There is an emergency response program in place that, in the event of a spill, outlines procedures to notify in-plant personnel, minimize and clean up the spill and to determine what authorities need to be notified and appropriate time frames.  Also addressed are health and safety issues such as first aid, medical procedures, personal protective equipment and training issues.  Coordinating efforts have been established with the local emergency planning committee and the local emergency response coordinator.  
Planned Changes to Improve Safety 
Changes and updates to the covered process scheduled for implementation in 1999 include: 
7 Updated labeling of tanks, valves, and ports; 
7 Implementation of annual inspection program; 
7 Implementation of 5 year inspection program 
7 Install high level alarms; 
7 Install level gauges; 
7 Install transfer station secondary containment; 
7 Seal and pump leak prevention progra 
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