Burr Oak Branch - Executive Summary
Executive Summary |
(a) Who - Winneshiek Cooperative Association (WCA) is an organization owned by crop growers and livestock producers in NE Iowa and SE Minnesota. The member-owners of WCA benefit from having strategically located fertilizer, feed and grain facilities in Winneshiek and Howard (Iowa) counties.
Being owned by farmers, WCA does everything it can to protect and preserve the environment. The members, management and employees of WCA are committed tot he prevention of any accidental releases of anhydrous ammonia (NH3) or any other hazardous material. In the event an accidental release occurs, the Burr Oak facility is well prepared to work with the local fire department, or other authorities, to mitigate any releases and minimize the impact of the release to people and the environment.
All applicable procedures of the U.S. Environmental Protection Agency prevention programs are strictly adhered to. The WCA Emergency Response Policy involves the preparation of response pla
ns which are tailored to each facility and to the emergency response capabilities of the community they're located in.
(b) What and Where - The Burr Oak branch of WCA handles Anhydrous Ammonia (NH3) as one of the most economical sources of nitrogen fertilizer for corn. The Burr Oak location serves corn growers from SE Minnesota as well as NE Iowa. The Burr Oak branch includes the NH3 plant, a dry fertilizer plant, liquid fertilizer tanks, a bagged feed, seed and crop protection product warehouse and a small country gas station with a short line of groceries and beverages for sale. The NH3 is stored in a 30,000 gallon bulk tank, located at the farthest point away from the public to the rear of our Burr Oak location. The tank, with a maximum capacity of 131,500 pounds of NH3, is mounted on two cement pillars. The entire NH3 handling process includes the latest safety products, with many of the safe-guards duplicated to assure extra protection. The NH3 facility is inspected on a daily ba
sis during the spring planting and fall harvest seasons. All of the NH3 equipment is inspected annually by State officials. Much of the non-durable equipment (including hoses, safety valves) are replaced on a regular basis most of the time long before being required to be replace by other state and federal standards. The Burr Oak branch is manned, with staff on site seven days a week.
(c) Worst-case and alternate accidental release scenarios - The offsite consequence analysis includes two accidental release theories, found as "worst case release" and "alternative release scenario."
The worst case scenario is defined by EPA, which states that "the owner or operator shall assume that the ... maximum quantity in the largest vessel . . . is released as a gas over 10 minutes" due to an unspecified failure. This accidental release is very unlikely to occur. However, should it occur, 131,500 pounds of NH3 would be released, with a toxic end point (0.14 mg/L) reached at 6.9 miles down wi
nd from the facility.
The alternative release scenario is defined as "more likely to occur" than the worst-case scenario. With no accident history experience to base on, it is WCA's presumption the most likely to occur would be the rupture of a transfer hose or pipe, tied with the failure of the involved excess-flow valve. The toxic end point (0.14 mg/L) would reach 2.2 miles down wind from the facility.
WCA used RMP-Comp to calculate the "toxic endpoint" selected by the EPA of .14 mg/L. The public population within the "toxic endpoint distance" of the Burr Oak facility is defined as the "population potentially affected" by a worst-case toxic release.
Because NH3 is not stored within a building, no passive mitigation measures can be credited to slow or reduce any release.
(d)How to prevent accidental releases - WCA's accidental release prevention program is based upon provisions within "Safety Requirements for the Storage and Handling of Anhydrous Ammonia, K-61.1," published by
the American National Standards Institute, Inc. and OSHA 29CFR 1910.111, "Storage and Handling of Anhydrous Ammonia." In addition to these requirements, WCA has also included the following elements:
(1)Strictly limiting the number of staff who are allowed to handle NH3
(2)Annual, thorough, strict safety and handling training of all people involved NH3.
(3)All valve handles, controls and electrical switches are secured and/or locked to prevent unauthorized releases and/or the overfilling of the main bulk tank.
(4)All pipelines have redundant as well as triple redundant valves and locking for security and safety.
(5)Strict enforcement of all parts replacement policies mandated by state and federal officials.
(6)Rigorous inspection of each portable NH3 tank during loading.
(7)Thorough inspections of all NH3 application equipment before spring application season, after fall application season and before being transported between farmers.
(e)No accidental releases of anhydrous ammonia ha
ve occurred at this facility in the past five years
(f)Emergency Response Program - Safety improvements at WCA are an on-going process. WCA has an extensive emergency response program which it coordinates with the Winneshiek County Local Emergency Planning Committee and the local fire departments. This program includes an emergency response decision chart, emergency phone number list, notification plans, maps and diagrams.