Buffalo Coal Company - Executive Summary

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40 CFR 68 
1.0    40 CFR 68.155 - EXECUTIVE SUMMARY                     
1.1    Accidental Release Prevention and Emergency Response Policies at the Stationary Source                             
Buffalo Coal Company, Inc. has polices and procedures in place that have trained their employees in the safe handling and emergency responses necessary to prevent and/or mitigate the accidental release of anhydrous ammonia used at their facility. 
Equipment used in the transportation, storage and use of anhydrous ammonia conform to the appropriate federal and state regulations.  Equipment and maintenance records are kept on the site.                     
Buffalo Coal uses third party contractors to transport the anhydrous ammonia and consultants to provide additional training in safety and emergency procedures for their employees.                      
Buffalo Coal has coordinated its emergency procedures with the local LEPC and other industry in the area.                     
1.2    Station 
ary Source and Regulated Substances Handled         
There are two stationary sources and processes covered in this risk management plan.                     
Process 1 - 12,000 gallon capacity anhydrous ammonia AST     
Process 2 - 8,000 gallon capacity anhydrous ammonia AST                     
1.3    Worst Case and Alternative Scenarios Including Administrative Controls and Mitigation Measures to Limit Discharge Distances                 
Buffalo Coal has performed a hazard assessment of its operations and determined that the worst case scenario release of anhydrous ammonia would result from the catastrophic failure of a storage tank that was filled to 85% of capacity.                     
For the worst case scenario discharge no administrative controls or mitigation measures were used to limit the anticipated discharge distances to determine the toxic endpoint for the regulated material.                 
Buffalo Coal has performed a hazard assessment of its operations and determined that the alternative release scenario of anhydrous ammonia would m 
ost likely result from the failure of a transfer hose during the transfer of the material from a bulk tanker truck to a storage tank.         
For the alternative release scenario, Buffalo Coal's passive mitigation systems such as the mass flow valves within the tank and active mitigation measures initiated by employees monitoring the material transfer will limit the duration and amount of material released below the capacity of both the tanker truck and storage tank.  These actions will reduce the distance to the toxic endpoint for the alternative release scenario.                     
1.4    General Accidental Release Prevention Program and Chemical-Specific Prevention Steps                             
The storage tanks are equipped with passive mitigation devices.  Mass flow valves are designed to prevent the rapid loss of material through piping as the result of a sudden loss of pressure.  Transfer operations moving anhydrous ammonia from tanker trucks to storage tanks are monitored by trained personnel.                 
Employees have been trained as to the proper handling and hazards of anhydrous ammonia.  Containers are properly labeled and hazard warnings posted.  Personal protective equipment appropriate for working with anhydrous ammonia has been provided to the employees.                     
1.5    Five-Year Accident History                         
1.6    Emergency Response Program                                                         
In the event of a reportable release of anhydrous ammonia, Buffalo Coal employees have been trained to take immediate actions to mitigate the release, don personal protective equipment, evacuate to a designated area, communicate with other off-site personnel and contact local authorities through the LEPC.                     
1.7    Planned Changes to Improve Safety                             
Based on the most recent hazard evaluation performed at the facility in June 1999, Buffalo Coal will improve the labeling and protective barriers around each tank and purchase new respirators for employee use.
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