Crop Fertility Specialists - North Plant - Executive Summary

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Kova Ag Products, Inc. 
dba. Crop Fertility Specialists (North Plant) 
5622 W. 660 N. 
Winamac, In   46996 
 
For Further Information Contact:       Roger DuMond,  consultant to KAP ( Compliance Manager) 
                                                         1330 N. Anderson St. 
 
re:  Risk Management Plan for Anhydrous Ammonia- 
 
EXECUTIVE SUMMARY 
 
1.  The Facility Policy 
 
         The owners, management, and employees of Kova Ag Products @ Milford 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 are 
a farmers as a vital crop 
            production nutrient (nitrogen). 
         -The maximum amount stored at this facility would be 80,000 pounds (15,300 gallons) in our 18,000  
           gallon storage tank.  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 the 
         18,000 gallon storage tank as a gas over a 10 minute time span.  The maximum quantity released  
         would be 80,000 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 community  
         as 1.6 miles using the average of rural and agricultural from modeling da 
ta 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 1 inch 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 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". 
 
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 plan 
ning and community right-to-know  
               information 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.
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