Ruth Anhydrous Ammonia Site - Executive Summary

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Executive Summary for Cooperative Elevator Companys :  Ruth, Michigan,  Anhydrous Ammonia Facility 
 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Cooperative Elevator Co. are strongly committed to employee, public and environmental safety.  This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the process at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances.  Unforeseeably, if such a release does occur, our  trained personnel are at hand to control and mitigate the effects of the release.  We also coordinate with the Sherman Twp. Fire Dept.,  which provides additional emergency response expertise. 
 
 
2.    The Stationary Source and the Regulated Substances Handled 
Our facilitys primary activities encompass Storage and transfer of agricul 
tural anhydrous ammonia..  We have only that one regulated substance present at our facility. The ammonia at our facility is simply stored for delivery and use as an agricultural fertilizer. 
 
The maximum inventory of Ammonia at our facility is 80,000.00 lb., which is on hand when the storage tank is 85% filled. For safety purposes, the tank is never filled beyond 85%. 
 
 
3.    The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. 
Methodology given in the RMP Offsite Consequence Analysis Guidance by the EPA using the Look-up Table approach and equations has been employed by our facility to perform worst and alternative case release scenarios. The tables used for our scenarios were developed by The Fertilizer Institute, a trade organization serving our industry. TFI used Degadis for modeling the releases. The following paragraphs provide details of the chosen sce 
narios. 
 
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release of ammonia from the storage tank.  The scenario involves the release of 80,000 lb. of Ammonia in a gaseous form over 10 minutes.  Under worst case weather conditions, namely Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 2.13 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. It would be extremely unlikely that this would ever happen, as the tank would literally have to burst open for this to occur. 
 
An alternative release scenario is also provided for the anhydrous ammonia. This scenario represents a  more likely incident. 
 
The alternative release scenario for Ammonia involves a release of ammonia due to a ruptured transfer hose.  The scenario involves the release of 11,908.00 lb. of Ammonia in a gaseous form over 2 minutes.  It is believed that the release could be stopped within two minutes by our employees.  
Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L is 0.56 miles. 
 
 
4.    The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility complies with the requirements of several regulations, including requirements set out under 40 CFR part 68 of the EPA. Is also complies with other Federal, and State regulations. 
Additionally, our facility is inspected regularly by government agencies. Any recommendations made are promptly followed. 
 
5.    Five-year Accident History 
There have been no accidental releases in the past five years. 
 
 
6.    Emergency Response Plan 
Cooperative Elevator Co. carries a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes various aspects of emergency response including: adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of aff 
ected areas. 
 
Huron County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. The plan is reviewed at least annually, and promptly updated when necessary. 
 
7.    Planned Changes to Improve Safety 
More frequent self inspections are planned to identify and correct problems more promptly
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