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                                                        Risk Management Plan 
                                                          Executive Summary 
                                            W. B. Johnston Grain Co., Billings Location 
Certification for the Risk Management Plan Program 2, Anhydrous Ammonia: 
    To the best of the undersigneds knowledge, the following information submitted is true, accurate, 
    and complete:        
    ________________________________              _Pat Oller_____________________ 
    Signature                                                                Printed Name 
   _Manager___Site Safety Coordinator __               _4/25/99______________________ 
    Title                                                                         Date 
A risk management plan has been implemented at Johnston Grain Companys Billings facility to provide a contingency plan in the event of an accidental release of anhydrous ammonia.  This plan has be 
en developed to prevent accidental release through responsible handling and proper storage of the product.  Johnstons will also ensure that employees receive the necessary training and that proper safety equipment is provided.  Johnstons will also make sure that the surrounding community is aware of our preparedness in the event of an accident. 
Johnstons Billings facility is a full service, country elevator, which sells feed, seed, fertilizer, as well as agriculture 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 fertilizer only.  Our facility has two storage tanks [1 @ 12,000 gal. & 1 @ 30,000 gal.] that have 42,000 gal. capacity and are filled to only 85%, this equals 196,000 pounds of ammonia.  We also have twenty-five 1,000 gallon nurse tanks and eighteen 1,400 gallon nurse tanks also filled to a maximum of 85% full at our l 
ocation.  The combined capacity of all tanks at this location is 92,200.0 gallons, or 430,300  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 locations contact with the corporate office.  The site safety coordinator acts as the locations emergency contact. 
As required by EPA guidelines, the following worst-case release and alternative release scenarios have been devised. 
Worst Case Scenario: 
Our worst case scenario is the loss of the total contents of the 30,000 gallon storage tank, when filled to greatest amount allowed (85% of capacity). released as a gas over 10 minutes, resulting in total vaporization.  The maximum quantity released would be 140,000 pounds.  According to DEGADIS modeling, this release (distance from point of dispersion to 20 
0 PPM) would have off-site impacts, and would travel 1.2 miles.  It should be noted that Johnstons  has never had a release of an entire stationary anhydrous ammonia storage tank from any of its facilities. 
Alternative Release Scenario: 
The most common 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 Johnstons has not had a release of this type from any facility in the past. 
General Accidental Release Prevention Program and Chemical-Specific Prevention Steps: 
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), EPAs Accidental Release P 
revention 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 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 at least annually, whenever there is changed 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. 
e Year Accident History: 
There have been no accidents involving anhydrous ammonia that caused deaths, injuries, property or environmental damage, including evacuations on or off site. 
Emergency Response Program: 
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 the 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 at our 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 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 include provi 
sions for public notification, initial medical care, evacuations, and LEPC coordination. 
Planned Changes to Improve Safety: 
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 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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