United Cooperatives Inc - Executive Summary
Executive Summary |
The owner, management, and employees operating each of our facilities at United Cooperatives Incorporated are committed to the prevention of any accidental release of hazardous chemicals transported or stored at our locations. In the event that an accidental release should occur, we are prepared to work with our Local Fire Department, Emergency Response Personnel, and other appropriate authorities deemed applicable depending on the specific incident, to best mitigate any release and to minimize the impact of the release to people and the environment.
The primary activity of our company is NAICS code 42291 "Farm Supplies Wholesalers", whereas we are engaged in providing "agricultural inputs" that include the receiving, storage, and reloading of Anhydrous Ammonia for delivery to farmers in our area. This product is subject to the EPA Risk Management Program and is the subject of this plan. Only the facilities used for this pro
duct will be included in this report.
Anhydrous Ammonia is received, stored, and distributed for direct applications to farm fields during the early spring and late fall months. During the balance of the year, inventories will be storage only, with little, if any product transfer taking place. The maximum quantity stored in pressurized permanent storage vessels at the location described is 187,000 lbs. The maximum on site vessel size is 18,000 gallons, storing 84,000 lbs. The maximum quantity handled at a given time would be the off loading of a semi-trailer vehicle tank holding 40,000 to 42,000 lbs.
This portion of the facility is operated on an "as needed" basis with staff present only during the receiving and reloading of product for delivery. However there are four full-time employees at this facility. Our facilities have adequate lighting, and are inspected at various times day or night during use, and through out the "off season" when not in use.
Worst-Case Release Scena
The worst-case scenario would be release of the total contents of our largest Anhydrous Ammonia tank, release as a gas liquified by pressure over 10 minutes. The maximum quantity release would be 84,000 lbs., based on 85% tank capacity as limited by design standards. The distance to the endpoint (point of dispersion to 200 ppm) is 3.3 miles based on EPA's RMP Comp guidance program. Residential population within this area is approximately 4800 based on most recent census data.
Alternate Release Scenario
As we have not had an actual release of Anhydrous Ammonia during the last 5-years at the site, we believe the most likely release would be caused by a break in a transfer hose. Transfer hoses are protected by manual, self closing excess flow, and "pull away" valves. Our alternative release scenario is based on the loss of contents from the largest hose used (off loading transportation equipment). The distance to the endpoint (point of dispersion to 200 ppm) is 0.1 miles (528
feet) based on EPA's RMP Comp guidance program.
Accidental Release Program
For Anhydrous Ammonia, our accidental release program is based on guidelines found in the American National Standards Institute, Inc. (ANSI) standard K-61.1 "Safety Requirements for the Storage and Handling of Anhydrous Ammonia; and the U.S. Occupational Safety and Health Administration (OSHA) standard 29CFR1910.111 "Storage and Handling of Anhydrous Ammonia". Additionally, we conduct annual employee training on the safe handling, transportation and distribution of Anhydrous Ammonia, and have installed safety equipment including, but not limited to: Excess flow valves, break-away couplers at risers, emergency shut-off valves, barriers to avoid damage by trucks or other vehicles, and lock-outs to prevent tampering when site is unattended. Finally, we maintain routine contact with our local fire department and emergency response personnel; and have provided and/or participated in safety training exercises o
n Anhydrous Ammonia.
Five-Year Accident History
We have not had a release of Anhydrous Ammonia within the past five years that has caused any deaths, injuries, or significant property damage at this facility; nor to our knowledge have resulted in offsite deaths, injuries, evacuation, sheltering in place, property damage, or environmental damage.
Emergency Response Program
This facility is included in the written Community Emergency Response Plan by the Local Emergency Planning Committee (LEPC) and the State Department of Emergency Management. We also include these materials in our own Emergency Action Plan in accordance with OSHA standard 29CFR1910.38. We have provided State and Local authorities all Community Right-to-Know information requested as well as that required under SARA Title III (EPCRA). Our written employee safety programs include pre-emergency planning and employee training in accordance with OSHA standards, and are offered for review at any time by our Local Emer
gency Planning Committee (LEPC) to ensure that they conform to the community plan(s). We actively encourage participation in our Anhydrous Ammonia program by the local fire department, local emergency response team, community planners, etc., that may be expected to respond to an incident at our site.
Planned Changes to Improve Safety
Safety improvement is an on-going process at all of our facilities. Periodic evaluations are performed to assess the maintenance of safe conditions. There are no additional specific recommendations for implementation at this time.