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

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Certification for the Risk Management Plan Program 2, Anahydrous 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 Renfrow facility to provide a contingency plan in the event of an accidental release through responsible handling and proper storage of the product.  Johnston's will also ensure that employees rec 
ieve the necessary training and that proper safety equipment is provided.  Johnston's will also make sure that the surrounding sommunity is aware of our preparedness in the event of an accident. 
Johnston's Renfrow 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 in anhydrous ammonia.  Anhydrous ammonia is recieved, stored and distributed from our facility as a crop fertilizer 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 sixteen (16) 1,000 gallon Nurse tanks also filled to a maximum of 85% full at our location.  The combined capacity of all tanks at this location is 28,000 gallons or 131,000 pounds of anhydrous ammonia. 
This facility has a "site-safety coordinator", all Johnston coordinators are given training to monitor the d 
ay 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 emergency contact. 
As required by EPA guidelines, the following worst-case release and alternative release scenarios have been devised. 
Our worst 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 0.84 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 locations. 
most common alternative release scenario from our facility would be in the failure of a one-inch transfer hose of approximately 2901 pounds of anhydrous ammonia over a two-minute period.  Under the worst weather conditions the contents would travel 0.22 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, chack valves, relief valves, and manual shut-offs.  The load out risers used for the purpose 
of filling the nurse tanks are protected 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 in 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 al least annually, whenever there is change in the process, or whenever comptency with the regulations is questioned.  The training sonsists of classroom lecture, current vidoes, testing and certification, and on the job training. 
This facility had a reportable accident occuring on 07-17-1998.  The release began at 5:30 a.m. and lasted for one hour and 15 minutes.  This anhydrous ammonia release was the result of an unknown factor causing a valve to malfunction.   
This release resulted in $3600 in damages to off-site trees and landscaping. 
In the event of an emergency involving our ammonia 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 are are properly prepared for an incident at our facility.  This will ensure that the community has the strategy for responding to and mitigating the threat posed by an ammonia release.  This complies with 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 includes 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 oue employees with ongoing annual training to ensure that 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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