W. B. Johnston Grain Company Covington, Oklahoma - Executive Summary

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Risk Management Plan 
Executive Summary 
W.B. Johnston Grain Co.-Covington Location 
Certification for the risk Management Plan Program 2, Anhydrous Ammonia 
To the best of the undersigned's knowledge.  The following information submitted is true, accurate, and complete. 
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A risk management plan has been implemented at Johnston Grain Company's Covington facility to provide a contingency plan in the event of an accidental release of anhydrous ammonia.  This plan has been developed to prevent accidental release through responsible handling and proper storage of the product.  Johnston's will also ensure that employees receive the necessary trai 
ning and that proper safety equipment is provided.  Johnston's will also make sure that the surrounding community is aware of our preparedness in the event of an accident. 
Johnston's Covington facility is a full service, country elevator, which sells feed, seed, fertilizer, as well as agricultural chemicals.  The only substance subject to regulation under RMP and above the threshold quantities is anhydrous ammonia.  Anhydrous ammonia is received, stored, and distributed from our facility as a crop feritlizer only.  Our facility has one storage tank that has 12,000 gallons capacity and is filled to only 85%, this equals 56,000 pounds of ammonia.  We also have  fifteen (15) 1000 gallon Nurse tanks also filled to a maximum of 85% full at our location.  The combined capacity of all tanks at this location is 27,000 gallons or 126,050 pounds of anhydrous ammonia. 
This facility has a "site safety coordinator", all Johnston coordinators are given training to monitor the day to day safe work  
activities, maintain the required regulatory record keeping, conduct safety meetings, conduct employee training, and act as the location's contact with the corporate office.  The site safety coordinator acts as the location's emergency contact. 
As required by EPA guidelines the following worst-case release and alternative release scenarios have been devised. 
Our worse case scenario is the loss of the total contents of the 12,000 gallon storage tank, when filled to the greatest amount allowed (85% of capacity), released as a gas over 10 minutes, resulting in total vaporization.  The maximum quantity released would be 56,000 pounds.  According to DEGADIS modeling, this release(distance from point of dispersion to 200 PPM) would have off-site impacts, and would travel .84 miles.  It should be noted that Johnston's has never had a release of an entire stationary anhydrous ammonia storage tank from any of its facilities. 
The most commo 
n alternative release scenario from our facility would be in the failure of a 1-inch transfer hose and release of approximately 2901 pounds of anhydrous ammonia over a two-minute period.  Under the worst weather conditions the contents would travel .22 miles before dispersing enough to no longer pose a hazard to the public.  It should be noted that Johnston's has not had a release of this type from any facility in the past. 
The anhydrous ammonia system is designed, installed, and maintained in accordance with ASTM standards and ASME codes.  This facility complies with the ANSI K61.1 standards, OSHA(29 CFR 1910.111), EPA's Accidental Release Prevention Rule, and all applicable federal, state, and local codes and regulations. 
Our ammonia system is protected from major releases by internal excess flow valves, check valves, relief valves, and manual shutoffs.  The load-out risers used for the purpose o 
f filling the nurse tanks are portected by excess flow valves to stop the flow of ammonia if a line or hose fails.  All main storage tank valves are locked when not is use. 
Our ammonia facility is inspected on a regular basis with maintenance and preventative maintenance scheduled and documented.  Liquid and vapor valves, hoses, excess flow valves, gauges, and relief valves are replaced when necessary and according to the guidelines in the ANSI standards. 
Training is provided to all employees at least annually, whenever there is change in the process, or whenever competency with the regulations is questioned.  The training consists of classroom lecture, current videos, testing and certification, and on the job training. 
There have been no accidents involving anhydrous ammonia that caused deaths, injuries, property or environmental damage, including evacuations on or off site. 
In the event of an emergency involving our ammoni 
a system, it is our policy to notify the local community fire department and request that they respond to the emergency.  In preparation for this, we have coordinated with all of the local agencies by providing information and offering tours to ensure that they are familiar with and are properly prepared for an incident ar out facility.  This will help ensure that the community has the strategy for responding to and mitigating the threat posed by an ammonia release.  This complies wiht the requirement for our facility to be included in the community emergency response plan prepared under EPCRA and coordinated with our LEPC. 
Johnston Grain has an Emergency Response and Contingency Plan for our facilities that include provisions for public notification, initial medical care, evacuations, and LEPC coordination. 
We do not plan to make any changes to the physical site.  We will continue to provide our employees with ongoing annual training to ensure tha 
t they are current with safe ammonia transfer and handling procedures.  We will also provide regular inspection and maintenance on all of the ammonia equipment.
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