Valley Grain & Fertilizer Company - Executive Summary

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             Risk Management Plan (RMP) - Ammonia 
                      Executive Summary 
              Valley Grain & Fertilizer Company 
                       Highland, Kansas 
 
 
 1. Accidental Release Prevention and Emergency Response Policies 
We at Valley Grain & Fertilizer Company in Highland are strongly committed to employee, public, 
and environmental safety.  This commitment is an inherent part of our comprehensive accidental 
release prevention program that covers areas such as design, installation, operating procedures, 
maintenance, and employee training associated with the processes at our facility.  It is our policy to 
implement appropriate controls to prevent possible releases of regulated substances.  If such a release 
does occur, our trained emergency response personnel are at hand to control and mitigate the effects 
of the release.  We also coordinate our response efforts with the Doniphan County Fire De 
partment, 
which provides additional emergency response expertise. 
 
 2. Stationary Source and Regulated Substances Handled 
Our facility's primary activities include support services for crop production.  We have anhydrous 
ammonia stored in a 18,000-gallon tank at our facility in Highland (Figure 1).  The maximum 
amount stored is 15,300 gallons (78,733.8 pounds) at the maximum fill capacity of 85%. 
 
 3. Worst Case Release and Alternative Release Scenarios 
We utilized RMP PRO for the worst case and alternate case scenarios of the required offsite 
consequence analysis for our facility.  The following details these scenarios. 
 
The worst case release scenario involves a catastrophic release of the entire contents of the 
anhydrous ammonia storage tank (78,733.8 pounds) in gaseous form over a 10-minute period.  At 
Class F atmospheric stability, 1.5 m/s wind speed, and urban topography, the maximum distance to 
a toxic endpoint of 0.14 mg/L is 4.2 miles (Figure 2).  The estimated population wi 
thin a 4.2-mile 
radius of this facility is 1,500. 
 
The alternative release scenario involves a release from an anhydrous ammonia product line.  The 
scenario involves the release of 7,616.42 pounds of ammonia in a gaseous form over a period of 30 
minutes.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 
mg/L of ammonia is 0.31 mile (Figure 3).  The estimated population within a 0.31 -mile radius of 
the facility is 400. 
 
 4. General Accidental Release Prevention Program 
Our facility has taken all the necessary steps to comply with the EPA's accidental release prevention 
requirements as set forth in 40 CFR part 68.  The following sections briefly describe the elements 
of the release prevention program that is in place at our stationary source. 
 
 
Process Safety Information 
Valley Grain & Fertilizer Company maintains a detailed record of safety information that describes 
the chemical hazards, operating parameters, and equipment designs associated with a 
ll processes 
(Appendix D). 
 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are 
identified and controlled effectively.  Any findings from the hazard analysis are addressed in a 
timely manner. 
 
Operating Procedures 
Valley Grain & Fertilizer Company maintains written operating procedures to ensure that activities 
within our covered processes are conducted safely.  These procedures address various modes of 
operation; the information is regularly reviewed and is readily accessible to operators involved in 
the processes (Appendix B). 
 
Training 
Valley Grain & Fertilizer Company has a comprehensive training program in place to ensure that 
employees who are operating processes are competent in the operating procedures associated with 
these processes. 
 
Mechanical Integrity 
Valley Grain & Fertilizer Company conducts documented maintenance checks on process equipment 
to ensure proper operation.  Maintenance checks are conduc 
ted by qualified personnel with previous 
training in maintenance practices.  Examples of process equipment that would receive maintenance 
checks include:  pressure vessels, storage tanks, piping systems, relief and vent systems, emergency 
shutdown systems, controls, and pumps.  Any equipment deficiencies identified by the maintenance 
checks are corrected in a safe and timely manner (Appendix C). 
 
Management of Change 
Written procedures are in place at Valley Grain & Fertilizer Company to manage changes in process 
chemicals, technology, equipment, and procedures.  Process operators, maintenance personnel or 
other employees whose job tasks are affected by a modification in process conditions are promptly 
notified of the modification and offered training to deal with it. 
 
Pre-startup Reviews 
Valley Grain & Fertilizer Company routinely conducts pre-startup safety reviews related to new 
processes and modifications in established processes.  These reviews are conducted to confirm that 
constr 
uction, equipment, and operating and maintenance procedures are suitable for safe startup prior 
to placing equipment into operation. 
 
Compliance Audits 
Valley Grain & Fertilizer Company conducts compliance audits on a regular basis to determine 
whether the plan's provisions, set out under the 40 CFR part 68, are being implemented.  Any non- 
compliance issue discovered during the audit is promptly corrected. 
 
Employee Participation 
Valley Grain & Fertilizer Company truly believes that process safety management and accident 
prevention is a team effort.  Company employees are strongly encouraged to express their views 
concerning accident prevention issues and to recommend improvements.  In addition, our employees 
have access to all information created as part of the facility's implementation of the RMP, 
particularly information resulting from process hazard analyses. 
 
 5. Five-year Accident History 
Valley Grain & Fertilizer Company has had an excellent record of preventing accidental rel 
eases 
over the last 5 years.  Due to our stringent release prevention policies, no accidental release has 
occurred during this period. 
 
 6. Emergency Response Plan 
Valley Grain & Fertilizer Company maintains a written emergency response plan to deal with 
accidental releases of hazardous materials.  The plan addresses all aspects of emergency response 
including first aid and medical treatment, evacuations, and notification of local emergency response 
agencies and the public (Appendix A).
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