West Liberty NH3 Facility - Executive Summary

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1. Facility accidental release and emergency response policy. 
The management and employees of Rich-Law Service Company 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 department, or other authorities, to mitigate any release and minimize the impact of the release to people and the environment. 
2. The stationary source and the regulated substances handled. 
The primary activity at the facility is the storage and blending of fertilizers for sale to farmers.  Anhydrous ammonia is received, stored, and distributed for direct application as a crop production nutrient.  Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors. 
The maximum quantity of anhydrous ammonia that can be stored would be 112,000 pounds. 
3. The worst-case release scenario and the alternative release scen 
The worst-case release scenario would be the release of the total contents of a [storage tank or tank car] released as a gas over 10 minutes.  The maximum quantity released would be 56,000 pounds, which represents the volume of the [largest storage tank or tank car] as limited by design standards.  
The distance to the endpoint of .14 mg/L for the worst-case scenario is .74 miles. 
The alternative release scenario based on the most likely potential incident is a release from a break in a transfer hose. 
The distance to the endpoint of .14 mg/L for the alternative scenario is .19 miles.  This release has the possibility of extending beyond the facility boundary. 
4. The accidental release prevention program. 
This facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations.  This facility has implemented the provisions of "Safety Requirements for the Storage and Handling of Anhydrous Ammonia, K-61.1", published by The Ame 
rican National Standards Institute, Inc. as adopted by state regulation and the standards of the U.S. Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111, "Storage and Handling of Anhydrous Ammonia". 
5. Five year accident history.  
The following is a list of accidental releases in the past five years that have occurred at the facility: 
- On 5/15/97 an employee improperly handled a transfer hose and a small release  
NH3 occurred.  The amount of release was less than 10 pounds, but the employee did suffer NH3 burns to his leg and foot. 
6. The emergency response program. 
The facility has: 
- a written emergency action plan, in accordance with OSHA standard, 29 CFR 1910.38; 
- provided state and local authorities the emergency planning and community right-to-know information as required under SARA Title III (EPCRA); 
- a written emergency response plan, in accordance with OSHA standard, 29 CFR 1910.120, including pre-emergency planning and employee training. 
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 specific safety recommendations for implementation at this time.
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