Cottage Grove Cooperative - Dane Agronomy - Executive Summary |
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Risk Management Plan Executive Summary Clean Air Act Amendment, Section 112r Cottage Grove Cooperative - Dane Agronomy ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The owners, management and employees of Cottage Grove Cooperative - Dane Agronomy are committed to the prevention of any accidental release of anhydrous ammonia. Cottage Grove Cooperative - Dane Agronomy' policy is to adhere to all applicable Federal and State rules and regulations in order to: 1. Prevent unnecessary human exposure, 2. Reduce the threat to employees health, and 3. To reduce the threat to nearby members of the community. Safety depends upon the manner in which an accidental release is handled, combined with the safety devices inherent in the design of the operation, the safe handling procedures used and the training of personnel. Cottage Grove Cooperative - Dane Agronomy complies with the provision of "Safety Requirements for Storage and Handling of Anhydrous Ammonia, K-61-1", published b y 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 Ammonia". Cottage Grove Cooperative - Dane Agronomy's emergency response plan includes procedures for notification of the local fire authority, the LEPC and any potentially affected neighbors. STATIONARY SOURCES AND REGULATED SUBSTANCES Anhydrous Ammonia This facility is a wholesale farm supply distribution center as such we store and distribute a wide variety of pesticides and fertilizers including Anhydrous Ammonia. Anhydrous Ammonia is received by truck, is handled and stored on-site and is a regulated substance by the EPA requiring us to comply with the Risk Management Program. We sell anhydrous ammonia to grower customers in either 1,000 gallon or 1,500 gallon nurse tanks. The customer applies the ammonia into the soil as a source of nitrogen fertilizer for growing agricultural crops. This f acility maintains approximately 34 - 1,000-gallon nurse tanks for customer delivery. Our combined storage capacity in nurse tanks is 158,780 pounds. Anhydrous ammonia is stored in 2- 12,000 gallon stationary storage tanks on site. 112,000 pounds of anhydrous ammonia is the maximum storage capacity of stationary storage tanks. Therefore, the total facility anhydrous ammonia storage capacity for our facility is 270,780 pounds. RELEASE SCENARIOS Anhydrous Ammonia Worst Case Scenario Our worst case scenario is the loss of the total contents of the 12,000 gallon storage tank, when filled to the greatest amount allowed (85% of capacity), released as a gas over 10 minutes, resulting total vaporization. The maximum quantity released would be 56,000 pounds. According to DEGADIS modeling, this release (distance to point of dispersion to 200 PPM) would have off site impact. Alternate Release Scenario The most common alternative release scenario(s) from our facility would not reach an e nd-point off-site. The alternative release scenario modeled for the purposes of this plan is a 2-minute release from a railcar tank representing a valve and hose failure requiring a manual shut down. The total amount of anhydrous ammonia released in this scenario would be 27,000 pounds. This release scenario (distance to point of dispersion to 200 PPM) would have off site impact GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PREVENTION STEPS This distribution facility complies with EPA's Accidental Release Rule and with all applicable state codes and regulations. The anhydrous ammonia facility has implemented the provision of "Safety Requirements for Storage and Handling of Anhydrous Ammonia, K-61.1", published by The American National Standards Institute, Inc., and the standards of the U.S. Occupation Safety and Health Administration (OSHA), 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia". FIVE-YEAR ACCIDENT HISTORY There have been no accidental releas es of anhydrous ammonia in the past 5 years that have caused any death, injuries, or significant property damage at the facility; nor to our knowledge, have resulted in off site deaths, injuries, evacuation, sheltering in place, property damage or environmental damage. EMERGENCY RESPONSE PROGRAM This facility emergency response program is written in accordance with OSHA standard 29 CFR 1910.38. Cottage Grove Cooperative - Dane Agronomy has discussed this program with the LEPC and local fire department. A representative of the local fire department has inspected the site. 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 safety recommendations for implementation. |