Padonia Grain Farmers, Inc. - Executive Summary |
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For further information contact: Phil Hinton, General Manager 1. Facility policy The owners, management, and employees of Padonia Grain Farmers are committed to the prevention of any accidental releases of anhydrous ammonia. If an accidental release should occur, the facility is prepared to work with the local fire company, or other authorities, to mitigate any release and minimize the impact of the release to people and the environment. 2. Facility information The primary activities at this facility affected by the Risk Management Plan are the storage and retail sales of anhydrous ammonia to farmers. Anhydrous ammonia is received, stored, and distributed for direct application by farmers. The maximum quantity stored would be 180,000 lbs in our 12,000 gallon storage tank and all nurse tanks. 3. The worst-case release scenario and the alternative release scenario In each of the following scenarios I have opted to consider our location as urban for dispersio n modeling purposes. The reason for this is that all tanks sit near large buildings, tall trees, and the facility as a whole sits in a valley. All of these factors would help to limit the plume drift radius. The worst-case release scenario for anhydrous ammonia would be the release of the total contents of the storage tank and nurse tanks due to some catastrophic event like a derailed train striking and substantially damaging all anhydrous storage vessels causing a total release over 10 minutes. The maximum quantity released would be 180,000 lbs, representing the total volume of all tanks. The distance to the endpoint of the release is 6.1 miles. Padonia realizes that this is a larger release quantity than the RMP requires; however, we feel that this truly represents a worse-case scenario. The alternative release scenario for anhydrous ammonia is based on the most likely potential incident that would result in an offsite leak; an overfill on the storage tank that resulted in the failure of the pop-off valves. If we assume that possibly all of the tanks contents could leak out over a two-hour period, the quantity released would be 60,000 lbs. The distance to the endpoint of the release would be .28 mile. 4. The accidental release prevention program Padonia Grain Farmers, Inc. has implemented a safety compliance manual that details the proper operations of all of the facilities procedures, including anhydrous ammonia. This manual includes step by step procedures for day-to-day operations as well as periodic checks to ensure proper equipment use and maintenance. These procedures were developed and implemented with regulations set forth by OSHA and ANSII in mind. 5. The five year accident history There have been no accidental releases of anhydrous ammonia 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 faiclity has a written emergency action plan in accordance with OSHA standards 29 CFR 1910.38 and has provided state and local authorities the emergency planning and community Right-To-Know information as required under SARA Title III (EPCRA). 7. Planned changes to improve safety Safety improvement is an on-going process at the facility. Periodic evaluations are performed to assess the maintenance of safe conditions. There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. |