Kova Fertilizer - Cortland - Executive Summary

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Kova Fertilizer, Inc. @ Cortland 
3323 East SR. 258 
Seymour, IN  47274 
For Further Information Contact:       Roger DuMond,  Corporate Compliance Manager 
re:  Risk Management Plan for Anhydrous Ammonia- 
1.  The Facility Policy 
         The owners, management, and employees of Kova Fertilizer @ Cortland are committed to the prevention of accidental releases of anhydrous ammonia.  If an accidental release should occur, the facility is prepared to work with the local fire department, Emergency Management Agency, LEPC, or other authorities to mitigate any release and minimize the impact of the release to people and the environment. 
2.  Facility Information 
         -The primary activity at the facility is the storage and blending of fertilizers for sale to area farmers. 
         - Anhydrous ammonia is received, stored, and distributed to area farmers as a vital crop 
            production nutrient (nitrogen). 
         -The maximum amount stored at this facility 
would be 132,600 pounds (25,500 gallons) in our 18,000  
           gallon and 12,000 gallons storage tanks.  Product is routinely loaded into 1000 gallon mobile tanks for pick-up by and  
           sale to area farmers. 
3.  The Worst Case Release Scenario and the Alternative Release Scenario 
     a. The worst case scenario for this facility would be the release of the total contents of the largest   
         tank (18000 gallons) storage tank as a gas over a 10 minute time span.  The maximum quantity  
         released would be 80,000 pounds, which represents the volume of the largest storage tank at 85  
         percent capacity as limited by design standards, industry recommendations, and company policy.   
        The distance to endpoint (point of dispersion to 200 ppm) has been calculated for this rural  
         community as 1.89 miles. 
     b. The alternative release scenario is based on the five-year accident history and/or "most likely to  
          happen" release  
information.  For this facility, we have made our calculation based on hose rupture  
          during load-out thru a 1inch fill line and a simultaneous emergency excess flow valve fails  to close  
          during rapid flow rate changes associated with the hose rupture.  The distance to endpoint (point of  
          dispersion to 200 ppm) is .22 miles (1160 ft.).  Since this filling process is always supervised by an  
          employee, we calculate maximum time of escape to be two (2) minutes before a secondary shut-off  
          measure can be initiated. 
4.  The Accidental Release Prevention Program. 
          This facility has instituted the provisions of "Safety Requirements for the Storage and Handling of  
          Anhydrous Ammonia, K-61.1", published by The American National Standards Institute, Inc., and the  
          standards of the U.S. Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111,  
          "Storage and Handling of Anhydrous Ammoni 
5.  The Five-Year Accident History 
         There have been no accidental releases of anhydrous ammonia from this facility in the past five  
         years that: 
          - have caused any deaths, injuries, or significant property damage at the facility; nor 
          - to our knowledge, have resulted in offsite deaths, injuries, evacuations, sheltering in place,  
            property damage, or environmental damage. 
6.  The Emergency Response Program. 
       -The facility has: 
         a.   A written emergency action plan in accordance with OSHA Standard 29 CFR 1910.38 and             
               Secondary Containment Regulations for the State of Indiana; 
         b.  Provided state and local authorities the emergency planning and community right-to-know  
               information as required under SARA Title III (EPCRA) 
         c.  A written emergency response program, in accordance with OSHA standard, 29 CFR 1910.120,  
              including pre-emergency  
planning and employee training. 
7.  Planned Changes to Improve Safety 
          Safe operations of our facility is an on-going process and is constantly reviewed as new  
    knowledge is generated and additional regulations impact our industry.  Periodic evaluations are  
    performed to assess the maintenance of safe conditions.  There are no additional specific anhydrous  
    ammonia safety recommendations for implementation at this site at this time.
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