Clinton Landmark, Wilmington - Executive Summary

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RISK MANAGEMENT PLAN 
EXECUTIVE SUMMARY 
 
For further information contact:  Steve Haines, General Manager (937-382-1633). 
 
1. The Facility Policy 
 
The owners, management, and employees of Clinton Landmark are committed to the prevention of any accidental release of Anhydrous Ammonia.  If an accidental release should occur, the facility is prepared to work with the various fire departments, or other authorities, to mitigate any release and minimize the impact of the release to people and the environment. 
 
2. Facility Information 
 
The primary activity at the facility is the storage and blending of fertilizers for sale to farmers. 
 
Anhydrous ammonia is received, stored, and distributed for direct application as fertilizer for crop production nutrients. 
 
The maximum quantity stored would be 196,274 pounds in our three storage tanks, the largest of which is 18,000 gallons.  The maximum quantity handled would be the unloading of a rail tank car holding 160,000 pounds. 
 
3. The Worst-Case Releas 
e Scenario And The Alternative Release Scenario 
 
The worst-case release scenario would be the release of the total contents of a rail car released as a gas over 10 minutes.  The maximum quantity released would be 160,000 pounds which represents the volume of the largest storage tank at 56 percent capacity by weight as limited by design standards.  The distance to the endpoint (point of dispersion to 200 ppm) is 1.2 miles. 
 
The alternative release scenario, based on the most likely potential incident (no accidents occurred in the previous five-year accident history), is a release from or a break in a transfer hose.  The distance to the endpoint (point of dispersion to 200 ppm) is 0.31 miles. 
 
4. The Accidental Release Prevention Program 
 
The facility has implemented the provisions of "Safety Requirements for the Storage and Handling of Anhydrous Ammonia, K-61.1", published by The American National Standards Institute, Inc., and the standards of the U.S. Occupational Safety and Health Ad 
ministration (OSHA), 29 CFR 1910.111, "Storage And Handling Of Anhydrous Ammonia".  The facility has also complied with the "Regulations For Storing And Handling Fertilizer Anhydrous Ammonia" as regulated by the Ohio Department of Agriculture. 
 
5. The Five-Year Accident History 
 
There have been no accidental releases of anhydrous ammonia in the past five years that: 
- have caused any deaths, 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. 
 
6. The Emergency Response Program 
 
The facility has: 
- a written emergency action plan, in accordance with OSHA standard, 29 CFR 1910.38; 
- provided state and local authorities the emergency planning and community right-to-know information as required under SARA Title III (EPCRA). 
- a written emergency response program, in accordance with OSHA standard, 29 CFR 1910.120, including pre-emergency planni 
ng and employee training. 
 
7. Planned Changes To Improve Safety 
 
Safety improvement is an on-going process at the facility.  Periodic evaluations are performed to assess the maintenance of safe conditions.  There are no additional specific anhydrous ammonia safety recommendations for implementation at this time.
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