HiLine Cooperative, Inc. Sutherland - Executive Summary
Company Name Plant Location |
HiLine Cooperative, Inc. 1 M East HWY #30, Varner Siding Sutherland, Nebraska 69165
HiLine Coopeative, Inc., P.O. Box 96, Elsie, Nebraska 69134-0096
Risk Management Plan - EXECUTIVE SUMMARY
The management and employees operating each of our facilities are committed to the prevention of any accidental release of hazardous material transported or stored on our locations. In the event an accidental release should occur, we are prepared to work with our Local Fire Company(s), Emergency Response Personnel, and other appropriate authorities deemed applicable depending on the specific incident, to best mitigate any release and to minimize the impact of the release to people and the environment.
The primary activity of our company is NAICS code 422910, however we are also engaged in providing "agricultural inputs" that include the receiving, storage, and reloading of Anhydrous Ammonia for delivery to farmers in our area. The NAICS code we feel most applicable for receiving, storing, and reloading is # 493130 "farm product warehousing and storage". Although Anhydrous Ammonia is the only product subject to the EPA Risk Management Plan at this time, it should be noted that we also handle Propane for both agricultural uses and home heating, which is under consideration as a listed substance. We include Propane (as well as all crop protectents and petroleum products) in our planning, training, and maintenance programs, however only the Anhydrous Ammonia facilities will be included in this report.
Anhydrous Ammonia is received, stored, and distributed for direct application to farm fields during the early spring and fall months. During the balance of th
e year little if any product transfer occurs . The maximum quantity stored in pressurized permanent storage vessels at the location described is 255,000 Lbs. The maximum on site vessel size is 26,000 Gallons, storing 110,000 Lbs. During portions of the spring as many as 5 railroad cars may be on the siding with each car holding approximately 75 tons of anhydrous ammonia. It should be noted however, that at any given time only one railcar or one semi-trailer containing approximately 40-42,000 lbs. will be connected to the off-loading system.
The facility is operated on an "as needed" basis with staff present only during the receiving and reloading of product for delivery. Total annual hours for these needs do not meet the 2,080 hour requirement to qualify as a "full time employee" on site, therefore item number 1.11 is Zero. Our facilities have adequate lighting, and are inspected at various times of day and night throughout the year. Time expended for these inspections is
not included in our staffing calculation.
Worst-case release scenario:
The "worst-case release scenario" is considered to be the release of the total contents of our largest Anhydrous Ammonia tank. The maximum quantity released is based on 85 % tank capacity as limited by design standards. The distance to the endpoint (point of dispersion to 200 ppm) is based on EPA's RMP -Comp Program (Version 1.06). Possible public and environmental receptors within the area has been provided to the County LEPC (Local Emergency Planning Committee) for their consideration.
Alternative release scenario:
There has not been an actual release of Anhydrous Ammonia during the last 5-years at the site. We believe the most likely release would be caused by a break in a transfer hose. Transfer hoses are protected by manual, self closing excess flow , and "pull away" valves so our alternative release scenario is based on the loss of contents from the largest hose used (off loading transportation
equipment). The distance to the endpoint (point of dispersion to 200 ppm) is (Rural) 0.3 miles (1584 feet) per instructions by EPA guidance.
Item number 3.5 addressing quantity released shows a total quantity released of 79 pounds however due to the pressure in the line, the release rate is 200 pounds per minute which, given the release duration of 10 minutes would indicate a release of 2000 pounds. When the pressure of anhydrous ammonia is reduced quickly, the material rapidly self-refrigerates to -28:F. Once the liquid reaches this temperature the vaporization is quite slow, from where we estimate a 10 minute release duration. Additionally, the excess flow valve which will stop the flow from the tank when flow rates exceed the rating, has an orifice which will allow 0.05 pounds per minute of ammonia to escape at 100 psi.
Accidental Release Program:
Our Anhydrous Ammonia accidental release program is based on guidelines found in the American National Standards Institute, Inc.
(ANSI) standard K-61.1 "Safety Requirements for the Storage and Handling of Anhydrous Ammonia; and the U.S. Occupational Safety and Health Administration (OSHA) standard 29CFR 1910.111 "Storage and Handling of Anhydrous Ammonia". We conduct annual employee training on the safe handling, transportation and distribution of Anhydrous Ammonia, and have installed safety equipment including, but not limited to: Excess flow valves, Breakaway couplers at risers, Emergency shut-off valves, Barriers to avoid damage by trucks or other vehicles, and Lock outs to prevent tampering when the site is unattended. We also maintain routine contact with our local fire department and emergency response personnel; and have provided and/or participated in safety training exercises on Anhydrous Ammonia. We have developed an Emergency Action Plan for employees, customers, and visitor protection in event of fire, explosion, tornado, and other acts of god that initiates evacuation, emergency medical care
, contacts for assistance, etc. for all areas of our company including the Anhydrous Ammonia facility included in this plan. The primary emergency coordinator is listed in the Registration Section of this document. The primary emergency coordinator is listed in the Registration Section of this document. Additionally, we subscribe to the ChemTrec service (phone 800-424-9300) to provide emergency response information when needed. ChemTrec, through Farmland Industries, also includes a system to notify any of several listed local employees in the event of a release. Any of the following individuals may be contacted in the event the primary emergency coordinator cannot be reached:
NAME WORK PHONE 24-HR PHONE
Dick Lutz, Jr. 308-386-4519 308-386-2526
Shane Smith 308-386-4519 308386-2123
Five - Y
ear Accident History:
There has not been a release of Anhydrous Ammonia within the past five years that has caused any death, injuries, or significant property damage at the facility; nor to our knowledge have resulted in offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
Emergency Response Program:
This facility is included in the written Community Emergency Response Plan as prepared by the Local Emergency Planning Committee (LEPC), and the Nebraska Emergency Management Agency (NEMA) (former Nebraska State Civil Defense Agency). We also include these materials in our own Emergency Action Plan in accordance with OSHA Standard 29CFR 1910.38. We have provided State and Local authorities all Community Right-to-Know information requested as well as that required under SARA Title III (EPCRA). Our written employee safety programs include pre-emergency planning and employee training in accordance with OSHA standards, and are offered
for review at any time by our Local Emergency Planning Committee (LEPC) to ensure they conform to the community plan(s). We actively encourage participation in our Anhydrous Ammonia and Propane training programs by the local fire department(s), local emergency response team, community planners, etc. that may be expected to respond to an incident at our site.
Planned changes to improve safety:
Safety improvement is an on-going process at all of our facilities. Periodic evaluations are performed to assess the maintenance of safe conditions. There are no additional specific recommendations for implementation at this time.
For additional information, response to questions, or comments, please contact:
Roy Evans at 308-228-2291 .