Crop Fertility Specialists @ Kewanna - Executive Summary |
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Kova Ag Products, Inc. dba. Crop Fertility Specialists @ Kewanna 10708 W. SR 14 Kewanna, IN 46939-8755 For Further Information Contact: Roger DuMond, consultant to KAP ( Compliance Manager) re: Risk Management Plan for Anhydrous Ammonia- EXECUTIVE SUMMARY 1. The Facility Policy The owners, management, and employees of Kova Ag Products @ Kewanna 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 106,600 pounds (20,400 gallons) in our two 12,000 gallon 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 one of the 12,000 gallon storage tank as a gas over a 10 minute time span. The maximum quantity released would be 53,000 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 1.25 miles using the average of rural and agricultural from modeling data charts. 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 .4 miles (2112 ft.) based on average of rural and agricultural topography from the DEGADIS modeling charts. 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 S tandards Institute, Inc., and the standards of the U.S. Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia". 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 info rmation 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. |