Northeast Coop - Wakefield Branch - Executive Summary

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NORTHEAST COOP - WAKEFIELD BRANCH  EXECUTIVE SUMMARY 
 
1.  The accidental release prevention and emergency response policies at your facility. 
 
NORTHEAST COOP  complies with ANSI K-61-1 requirements for anhydrous ammonia storage and it is our policy to adhere to all applicable federal, state, and local laws.  We are committed to the prevention of any accidental release of anhydrous ammonia.  If an emergency were to occur, it is our policy to notify the THE DIXON COUNTY SHERIFF IN COORDINATION WITH THE WAKEFIELD VOLUNTEER FIRE DEPT and request that they respond to the emergency. 
 
2.  A description of your facility and the regulated substance handled.   
 
The primary purpose of this facility is storage of fertilizers for sale to the agricultural sector.  Anhydrous Ammonia is received, stored and distributed  for sale to farmers.  Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors. 
The maximum intended inventory of o 
ur anhydrous ammonia storage tank is _92700_____ pounds. (Optional) 
 
3.  The Worst-case release scenario. 
 
We used RMP Comp to determine the worst case scenario release at our facility.  Failure of my largest storage tank when filled to the greatest amount would have off site consequences. 
 
The alternative release scenario is based on the most likely incident to occur which is a break in a transfer hose.   
 
4.  The general accidental release prevention program and the specific prevention steps. 
 
The facility complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. The facility has implemented 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.  Five-year accident history. 
 
We nev 
er had an accident involving anhydrous ammonia  that caused death, injuries, property or environmental damage, evacuations or shelterings in place. 
 
6.  The emergency response program.  
 
a)In the event of an emergency involving our anhydrous ammonia system, it is our policy to notify the DIXON COUNTY SHERIFF who will notify the Fire Dept and request that they respond to the emergency.  We have discussed this policy with  the fire department:  members of the fire department have inspected our system. 
b) The facility has a written emergency action plan, in accordance with OSHA standard, 29 CFR 1910.38. 
c) The facility has provided state and local authorities the emergency planning and community right-to-know information as required under SARA Title III (EPCRA). 
d) The facility has 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.   Safety improvement is a 
n on-going process at the facility.  Periodic evaluations are performed to assess the maintenance of safe conditions.  There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. 
 
Risk Management Program 
Management of the Program 
(a)  NORTHEAST COOP will develop a management system to oversee the implementation of the risk management program elements. 
(b)  NORTHEAST COOP shall assign a qualified person that has the overall responsibility for the development, implementation, and integration of the risk management program elements. 
 
management has assigned this qualified person, JIM MEIER, the responsibility for the development, implementation, and integration of the risk management program elements. 
(c)  When responsibility for implementing individual requirements of this part is assigned to persons other than the person identified under paragraph (b) of this section, the names or positions of these people shall be documented. 
Any person  
indicated below must report to the person or persons that have overall authority for the risk management program. 
 
Risk Management Program 
Element    Person or Position Assigned Responsibility 
for NH3 Operations in WAKEFIELD, NE 
Safety Information:    EDNA WAGNER 
Hazard Review:    EDNA WAGNER 
Operating Procedures:    ROBERT PULS 
Training:    EDNA WAGNER 
Maintenance:    BOB PULS 
Compliance Audits:    JIM MEIER 
Accident Investigation:    ROBERT PULS, EDNA WAGNER 
 
PREVENTION PROGRAM 
SAFETY INFORMATION 
(a)  NORTHEAST COOP shall compile and maintain up-to-date safety information related to the regulated substances, processes, and equipment. 
 
7 Material Safety Data Sheets (MSDS's) that meet the requirements of 29 CFR 1910.1200(g). 
The MSDS's for Anhydrous Ammonia will be located at the fertilizer office for reference.   
7 Maximum intended inventory of equipment in which the regulated substances are stored or processed. 
This is the total amount of anhydrous ammonia which can be safely stored in our storage tanks. 
T 
he maximum intended inventory of our anhydrous ammonia storage tanks is _92700_____ pounds. 
 
NOTE:  Maximum intended inventory is calculated by adding up total tank capacity converted to pounds of all tanks at this particular facility location. 
 
(3)  Safe upper and lower temperatures, pressures, flows, and compositions. 
These ranges define the safe conditions under which we operate our storage facility.  Excursions beyond these ranges represent abnormal conditions or upset conditions.  We must first recognize what is considered normal operations, to be able to recognize and react to abnormal situations. 
Anhydrous Ammonia (NH3)  is a chemical compound containing the elements nitrogen and hydrogen.  The formula is NH3 indicating that each volume of nitrogen is combined with 3 volumes of hydrogen.  Since the atomic weights of these elements differ, the weight ratio is 82.5% nitrogen to 17.5% hydrogen. 
At atmospheric temperature and pressure, ammonia is a colorless gas with a very sharp, c 
haracteristic odor.  This gas can be liquefied by cooling or by applying pressure.  In appearance, liquid anhydrous ammonia resembles water.  The boiling point at atmospheric pressure is -28 degrees F.  Above 900 degrees F, ammonia begins to decompose, reverting to hydrogen and nitrogen.  At -107.9 degrees F., anhydrous ammonia freezes to form white crystals. 
Anhydrous Ammonia is a relatively stable compound and is extremely hard to ignite.  Ammonia gas is flammable in air in the range of 16%-25% by volume with an ignition temperature of 1562 degrees F.  Conditions favorable for ignition are seldom encountered during normal operations due to the high lower limit, narrow range, and the high ignition temperature required.  However, the release of ammonia gas into a tightly enclosed or inadequately ventilated space may result in the accumulation of a flammable mixture that can cause a combustion explosion if a high temperature ignition source is present. 
(4)  Equipment Specifications 
 
NOR 
THEAST COOP will strive to keep on record all equipment specifications for bulk storage tanks, piping, pressure relief valves, temperature, pressure, and level gauges, valves, pumps, compressors, and hoses. 
(5)  Codes and Standards used to design, build, and operate our facilities. 
PROCESS SAFETY INFORMATION 
Process Safety Information for Anhydrous Ammonia Storage     
MSDS for Anhydrous Ammonia    Dated: 
Maximum Intended Inventory    22100 
Nominal Water Capacity of Largest Tank    26000 
Temperature    Upper:  ambient max. 110 F 
Lower:  ambient min. -15 F 
Pressure    Upper:  240 PSI @ 110 F 
Lower:  35 PSI @ -15 F 
Flow Rate    Loading:  120 G.P.M. 
Unloading:  41 G.P.M. 
Vapor Piping    250 PSIG?   OK 
Liquid Piping and Compressor Discharge    350 PSIG?  OK 
Safety Relief Valves 
 
 
RV1 
RV2 
RV3 
RV4    Each valve relieves    SCFM/air, three are required at all times, a fourth is provided to allow maintenance 
Replaced:  WILL ALL BE REPLACED  
Replaced:  LATER THIS YEAR 1999 
Replaced: 
Replaced: 
Internal Valve     
Excess Flow Valv 
e 
EFV1 
EFV2 
EFV3 
EFV4     
ALL OKAY 
Emergency Shutoff Valve 
ESV1 
ESV2     
ALL OKAY 
Hydrostatic Relief Valve 
HSV1 
HSV2 
HSV3 
    
 
ALL OKAY 
Pump 1    OK 
Pump 2    N/A 
Compressor 1    N/A 
Compressor 2    N/A 
Strainer    N/A 
Check Valves    OK 
Sightflow Indicator    N/A 
Tank Level Indicator    OK 
Tank Temperature Indicator    N/A 
Tank Pressure Indicators    OK 
Other Temperature Indicators    N/A 
Other Pressure Indicators    OK 
Design Codes     
State or Local Codes    ANSI K-61-1 1989 Edition with all Amendments 
Piping Design    OK 
Tank Design    OK 
Vaporizer Design    OK 
Date of Most Recent Revision1989    Revised By:SUGGESTED BY FIRE MARSHALL 
    
 
(b)  NORTHEAST COOP  will strive to ensure that our facilities are designed and are kept in compliance with recognized and generally accepted good engineering practices.  NORTHEAST COOP will make every attempt to keep our facility up-to-date with the ANSI code K-61.1with all amendments. 
 
(c)   NORTHEAST COOP shall update the safety information if a major change occurs that makes the information inaccurate. 
Des 
cription of Major Change    Year Installed    Appropriate Design Code 
        
        
        
Reviewed By:        Date: 
 
HAZARD REVIEW 
(a)  NORTHEAST COOP  shall conduct a review of the hazards associated with the regulated substances, processes, and procedures.  The hazard review will help us determine whether we are meeting applicable codes and standards, identify and evaluate the types of potential failures, and focus our emergency response planning efforts. 
 
The review shall identify the following: 
(1)  The hazards associated with the process and regulated substances; 
(2)  Opportunities for equipment malfunctions or human errors that could cause an accidental release; 
(3)  The safeguards used or needed to control the hazards or prevent equipment malfunction or human error; and  
(4)  Any steps used or needed to detect or monitor releases. 
 
ANHYDROUS AMMONIA STORAGE FACILITY 
HAZARD REVIEW CHECKLIST 
 
Answer the questions below by indicating "yes", "no", or "N/A" (for not applicable).  "No" responses require fur 
ther comment and a projected completion date for correcting the deficiency. 
Siting    Yes/No/NA    Comments-Correction Date 
1.  Does the arrangement of the fixed storage tanks conform with the minimum distances allowed in Table 3 of ANSI K-6l.1, l989 Edition?    Y     
2.  Are the fixed storage tanks located 50 feet from a dug well or other sources of potable water as outlined in ANSI K-6l.1, l989 Edition?    Y     
Piping, Equipment, & Container Appurtenances    Yes/No/NA    Comments-Correction Date 
1.  Is your storage facility designed according to ASME code for pressure vessels? 
 
      Fixed Storage Tanks ASME? 
 
      Vaporizers ASME?    Y 
 
 
Y 
 
Y     
2.  Is the pressure rating of your storage tanks appropriate for the product in service? 
 
     Storage Tanks?          Y 
 
 
Y     
3.   Is the stored product properly identified?    Y     
4.  On installations with multiple tanks, are the elevations of the storage tanks arranged to prevent overfilling of the lowest container?    N/A     
5.  On installations with stairways or ladders, a 
re they well anchored, supported , and of slip proof construction?    Y     
6.  On installations with stairways or ladders, are railings provided and in good condition?    Y     
7.  On installations with stairways or ladders, are catwalks provided so personnel need not walk on any portion of the container?    Y     
Is the piping designed according to 5.6.1 to 6.10, ANSI code K-6l.1, l989 Edition? 
 
Are the pump and compressor discharge and liquid transfer lines suitable for a working pressure of 350 psi? 
 
Is the vapor piping suitable for a working pressure  
of 250 psi?    Y 
 
 
 
Y 
 
 
Y     
9.  Is the relief capacity of your pressure relief devices: 
 
For fixed storage tanks, designed according to Sections 5.8 and 6.3 ANSI code K-6l.1, l989 Edition?     
 
 
 
Y     
10.  Is the capacity of your pressure relief devices designed according to 5.8 and 6.3 of ANSI code K-6l.1, l989 Edition? 
 
Have your relief devices been tested or replaced every five years or within the manufacturer's replacement date according to section 5.8.15  
of ANSI code K-6l.1, l989 Edition?    Y 
 
 
 
 
 
Y     
11.  Do you have appropriate level gauges, temperature indicators, excess flow valves, and pressure gauges installed on your fixed ASME storage tanks as specified in 6.2 ANSI code K-6l.1, l989 Edition?    Y     
12.  Do you have the appropriate hydrostatic relief valves installed between every section of liquid piping which can be blocked by manual or automatic valves according to 5.8.11 ANSI code K-6l.1, l989 Edition?    Y     
13.  Do you have the appropriate corrosion protection required by  ANSI code K-6l.1, l989 Edition?     Y     
14.  On installations with pumps, are they installed according to 5.10.6 of ANSI code K-61.1, l989 Edition? 
   Y     
15.  On installations with compressors, are they installed according to 5.10.7 of ANSI code K-61.1, l989 Edition? 
 
On installations with compressors, is there either an integral means of preventing liquid from entering the compressor or a liquid suction protection trap according to 5.10.7 of ANSI code K-61.1, l989 Editi 
on?    N/A 
 
 
 
 
 
 
N/A     
16.  Do your compressor and pump motors conform with 5.10.6 and  5.10.7 of ANSI code K-61.1, l989 Edition?    Y     
17.  On installations with liquid strainers, are they installed on the suction of your pump or meter according to 5.10.7.5 of ANSI code K-61.1, l989 Edition and capable of being cleaned?    N/A     
18.  On installations with flexible connections on pumps, compressors or loading and unloading bulkheads, are they installed as specified by 5.6.5 of ANSI code K-61.1, l989 Edition?    Y     
19.  Do you have either excess flow valves, back-flow check valves or internal valves as specified by 5.5-5.5.12 of ANSI code K-61.1, l989 Edition?    Y     
20.  Do you have container appurtenance protection as specified in 5.5.1-5.5.2 of ANSI code K-61.1, l989 Edition?    Y     
21.  Do you have manual valves and emergency shutoff valves a required by 5.10.8.1 Amendment to ANSI code K-61.1, l989 Edition?    Y     
22.  Do you have a breakaway stanchion as required by 5.10.8-1 of ANSI code K-61.1, l989 Editio 
n?    Y     
23.  Are all above ground lines securely fastened to structural members of adequate strength and supported at proper intervals?    Y     
24.  Are pressure gauges located so that they will not be exposed to physical damage?    Y     
25.  Are there sufficient lines for all purposes, without improper dual use or make-shift connections being used for some operations?    Y     
26.  Are hoses the correct type for each use?    Y     
27.  Are hose couplings of the correct type and properly attached (fully seated on the hose)?    Y     
28.  Is adequate transfer hose storage provided?    Y     
29.  Are the written transfer, loading & unloading instructions available?    Y     
Human Factors    Yes/No/NA    Comments 
1.  Have your operators been trained on the written operating instructions for this anhydrous ammonia facility?    Y     
2.  For operators on the job on or before June 21, l999, do they have the required knowledge, skills, and ability to perform their duties safely?    Y 
 
 
Y     
3.  Are your operators whose job duties require the use of t 
he above listed equipment understand the operating limits of the system in regards to: 
 
Capacity? 
 
Pressure? 
 
Temperature? 
 
Adverse Weather or Natural Conditions? 
   Y 
 
 
 
 
Y 
 
Y 
 
Y 
 
Y     
4.  Have your operators been trained in the correct response to conditions which exceed the operating limits of the system?    Y     
5.  Have your operators been trained in their duties for emergency conditions? 
 
Fire? 
 
Anhydrous Ammonia Gas Release? 
 
Severe Weather or Natural Conditions? 
   Y 
 
 
Y 
 
Y 
 
Y     
6.  Are the written operating instructions available to the operators?    Y 
    
7.  Do the written operating instructions reflect current operation of the facility?    Y     
8.  Have major modifications to your anhydrous ammonia facility taken place?    N    NOT AT PRESENT TIME 
9.  Are contractors used at the facility?    Y     
10.  Are safe work practices such as lock/out, tag/out, hot work, and line opening practices followed at the facility?    Y     
11.  Is there a written emergency response plan? 
 
Is it current? 
 
Have your operators been  
trained? 
 
Do you provide emergency response equipment? 
 
Has it been checked?    Y 
 
 
Y 
 
Y 
 
Y 
 
Y     
General Hazards    Yes/No/NA    Comments 
1.  Does your anhydrous ammonia storage facility have protection against tampering as specified in 6.7.1 of ANSI code k-61.1, l989 Edition?    Y     
2.  Is the area around your containers and transfer piping free of all combustible material?    Y     
3.  Has your facility been required by your local fire authority to provide special protection? 
 
Fixed Water Sprays/Monitor Nozzles? 
 
Insulating Coatings? 
 
Mounding/Burial? 
 
Other Types?    N 
 
 
 
N 
 
N 
 
N 
 
N    NOT AS OF  THE PRESENT TIME 
4.  Has a federal, state, or local agency or fire authority required: 
 
Local Gas Detection Monitors? 
 
Perimeter Gas Monitors and Public Alarms?     
 
 
N 
 
N    NOT AS OF THE PRESEN TIME 
This Hazard Review was Completed by:        On (Date): 
ROBERT PULS        06-15/99 
 
The latest date by which all changes resulting from the process hazard review are expected to be completed is LATE 1999. 
OPERATING PROCEDURES 
(a)  NORTH 
EAST COOP shall prepare written operating procedures that provide clear instructions or steps for safely conducting activities associated with each covered process consistent with the safety information for that process.  Operating procedures or instructions provided by equipment manufacturers or developed by persons or organizations knowledgeable about the process and equipment may be used as a basis for our operating procedures. 
The maximum intended inventory of our anhydrous ammonia storage tanks is ___92700________ pounds at this facility location. 
AMMONIA OPERATING PROCEDURES - TRANSFER OF AMMONIA 
Ammonia is delivered to the facility by tanker truck.  During the entire transfer operation,  the truck driver will be present to monitor the transfer and to take corrective action if required to minimize releases.  Unauthorized personnel {i.e., customers/ visitors) will not be allowed in the immediate area during the transfer operation.  The pump and compressor methods are essentially-i 
dentical, except that the pump method pressure in the two tanks is equal throughout the process. 
Before attaching any hoses it is the responsibility of the truck driver to make sure all required safety equipment is available, easily accessible and in working order.  Goggles and gloves will be worn at all times during the transfer operation.  The following is the step-by-step procedures for tanker truck  delivery procedures: 
TANKER TRUCK NORMAL DELIVERY PROCEDURES 
1. Before beginning the transfer process, the truck driver checks the conditions of all required safety equipment.  All equipment must be in good conditions before proceeding.  Required personal protective equipment {PPE} will be worn throughout the procedure. 
2. The delivery tanker is position properly in relation to storage piping. 
3. Brakes are applied and wheels are choked and engine turned off. 
4. Storage tank contents are checked to assure sufficient capacity remains to hold the contents  
      of the delivery tank befo 
re connecting any hoses  
5. All delivery tank and storage piping system valves are confirmed closed. 
6. All hoses, hose connections, couplings and gaskets are inspected and cleaned.  Check for defects, cracks or excessive wear and replace all worn or missing gaskets. 
7. Inspect transport hoses and ensure that they are free of defects and do not have any kinks or short bends. 
8. Confirmed all bleeder valves are closed. 
9. Vapor and liquid hoses are connected, making certain that all connections are straight and tight. 
10. Pressure in both the delivery tanker and storage vessel are checked.  Pressure in both tanks should be approximately equal at this point.  Remember to open all valves slowly this will ensure that the excess flow valve does not closes 
11. Open the delivery tank vapor valve and check for leaks, then open the bulk vessel vapor valve between the truck and bulk tank and inspected for leaks. 
12. Open the delivery tank liquid valve first then the bulk tank liquid valves are s 
lowly opened and inspected for leaks. 
13. Before starting the pump, check the liquid in the bulk storage tank.  If the tank does not have at least several inches in it, very slowly open the liquid belly valve on the tank last, turning no more than two turns, until the liquid in the bulk tank is at least 5" or 6" deep.  This prevents possible damage to the bulk tank float on the sight gauge.  The PTO shaft should not be engaged until the valve is complete open. 
14. Once the transfer starts, it is against the law to leave the area. 
15. Fill the tank only 85% full,  Use the fixed liquid level gauge, which is also called the "85% bleeder." 
16. When the transport tank is empty, compressor stopped and all vapor and liquid valves are closed, it is important to open the bleeder valves on the transport vapor and liquid hoses to make sure all pressure is out of each hose. 
17. Pressure from the lines should be released through bleeder valves into a 30 gallon drum of water.After pressure is reliev 
ed, bleeder valves are left open and hoses disconnected.  Always point hoses away from you and others in the area because ammonia could be trapped in the hose.  Leave bleeder valves are opened until the hoses are disconnected then close them. 
18. After all hoses and adapters are stowed ensure all acme caps are replaced, locks replaced on bulk tank lines.  A final check is made to assure that all valves are closed and hoses disconnected before approval is given to remove chocks and move tanker truck. 
19. Finally, when it is safe, goggles and gloves are removed.  Personnel protective equipment is to be cleaned{as necessary}and only then properly stored. 
AMMONIA TRANSFER TO NURSE TANK 
The following is the typical step-by-step procedures for ammonia transfer. 
1. Before beginning the transfer, the coop employee checks the condition of all required safety equipment.  All equipment must be in good condition before proceeding.  Required personal protective equipment {PPE} is to be worn through 
out the procedure. 
2. The nurse tank is positioned properly in relation to the riser and wheels are choked. 
3. The nurse tank is checked to assure tank is empty. 
4. Inspect acme threats on nurse tank riser hose-end valves and replace gasket if damaged or worn. 
5. Connect the riser vapor hose to the nurse tank vapor valve.  Then connect the riser liquid hose to the nurse tank liquid fill valve. 
6. Slowly open the vapor valves starting at the nurse tank and proceeding along the line through the compressor (if used) to the bulk tank vapor valve, opening each valve as you come to it. 
7. Compare nurse tank pressure with bulk tank pressure.  They should now be equalized. 
8. Open liquid valves, starting at the bulk tank and proceed along the line through the pump (if used) to the tank liquid fill valve. 
9. Start pump/compressor (if used) and make sure the flow starts.  If the flow does not start, recheck all previous steps.. 
10. During transfer the law requires you to stay in attendance.  Use 
this time to check:  safety water on nurse tanks; cover on pressure relief valve; tires on nurse tank; safety chain, hitch pin and tongue and wheel bearings. 
11. When the nurse tank float gauge shows 75% full, open the 85% bleeder valve, making sure the opening faces away from you.  The valve should be releasing vapor at this point.  Watch for the change to a stream of liquid that indicates the nurse tank is at the 85% safe fill level. 
12. If using a compressor:  close the riser liquid valve, then the 85% bleeder and then stop compressor.  If using a liquid pump:  stop the pump, then close the riser liquid valve, and then close the 85% bleeder valve. 
13. Close the hose-end valve on the liquid line, to allow liquid to drain from the coupling. 
14. Close all liquid valves, then all vapor valves. 
15. Open hose-end of bleeder valves, to clear couplings, then disconnect and store hoses. 
16. Replace acme caps on nurse tank valves. 
17. Follow these general safety rules for making connections  
and opening and closing valves:  hand tight only; handle hose end carefully; never use hand wheel or valve levels as a handle; and never unload from multiple tanks at the same time if they have common lines. 
18. You are responsible for the safety of the nurse tanks and must agree to the following: 
7 hoses are to be secured to the parking plug; 
7 safety chain must be of proper strength and properly fastened; 
7 all decals and markings meet state and federal regulations; 
7 The maximum speed while pulling a nurse tank is 25 mph or less {liquid loads shift constantly}. 
 
(b)  NORTHEAST COOP shall ensure that the operating procedures are updated, if necessary, whenever a major change occurs and prior to startup of the changed process. 
 
TRAINING 
(a)  NORTHEAST COOP  shall ensure that each employee presently operating a process, and each employee newly assigned to a covered process, have been trained or tested competent in the Operating Procedures provided in the last section that pertain to th 
eir duties.  For those employees already operating a process on June 21, l999 NORTHEAST COOP will certify in writing that the employee has the required knowledge, skills and abilities to safely carry out the duties and responsibilities as provided in the operating procedures. 
 
Training Programs provide immediate benefits because trained workers have fewer accidents, damage less equipment, and improve operational efficiency.  Training gives workers the information they need to understand how to operate safely and why safe operations are necessary.  A training program, including refresher training, is the key to ensuring that the rest of our prevention program is effective. 
 
The following employees were already operating this anhydrous ammonia storage facility on June 21, 1999.  These employees have the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures. 
 
EMPLOYEES WORKING PRIOR TO 6/21/99 
Employee Name    E 
mployee I.D. #  
ROBERT PULS     
CARL HINZ     
MARK SHOPKE     
CHRIS LANDER     
    
    
 
Certified by:________ROBERT PULS___________   ______06-15-99_______ 
       Manager signature            Date 
 
NORTHEAST COOP will train all new workers in the operating procedures we are using to comply with the Risk Management Program.  Any time the procedures are revised, everyone must be trained on the revised procedures.  At least once every three years, we will provide refresher training on the operating procedures even if they have not changed.  The training must cover all parts of the operating procedures, including information on the consequences of deviations and steps needed to address deviations or upset conditions. 
We are also required to ensure that each worker trained has understood the training and is competent to operate the process safely.  EDNA WAGNER, will determine what kinds of competency testing to use.  Observation of the employee may be appropriate in many cases.  We are required to report in the Risk Man 
agement Plan the type(s) of competency testing we use.  We will also keep an attendance log for any formal training or refresher training to ensure that everyone who needs to be trained is trained.  These logs will help in performing the compliance audits and demonstrate compliance with the rule. 
(b)  Refresher Training.  Refresher training shall be provided at least every three years, and more often if necessary, to each employee operating a process to ensure that the employee understands and adheres to the current operating procedures of the process.  EDNA WAGNER, shall determine the appropriate frequency of refresher training. 
 
(c)  NORTHEAST COOP may use training conducted under Federal or state regulations or under industry-specific standards or codes or training conducted by equipment vendors to demonstrate compliance with this section of the Risk Management Program. 
DOT 49 CFR 172.704) (2) requires refresher training every three years.  The DOT training may be considered part of 
the training required to fulfill the refresher training requirement. 
(d)  NORTHEAST COOP shall ensure that operators are trained in any updated or new procedures prior to startup of a process after a major change. 
 
Most recent review of training program_EDNA WAGNER_________on__03-15-99_____ 
Name                Date 
MAINTENANCE 
(a)  NORTHEAST COOP shall prepare and implement procedures to maintain the on-going mechanical integrity of the anhydrous ammonia equipment.   
 
Preventive maintenance and inspection and testing of equipment are critical to safe operations.  Waiting for equipment to fail could also mean waiting for an accident that could harm people and the environment.  Further, a thorough maintenance program will save us money by cutting down-time caused by equipment failures. 
We will prepare and implement procedures for maintaining the mechanical integrity of our process equipment, and train our workers in the maintenance procedures.  We will develop a schedule for inspecting and testing  
of the equipment based on manufacturer's recommendations and past experience. 
(b)  NORTHEAST COOP shall train or cause to be trained each employee involved in maintaining the on-going mechanical integrity of the process.  To ensure that the employee can perform the tasks in a safe manner, each such employee shall be trained in the hazards of the process, in how to avoid or correct unsafe conditions, and in the procedures applicable to the employee's job tasks. 
(c)  Any maintenance contractor shall ensure that each contract maintenance employee is trained to perform the maintenance procedures developed under (a) of this section. 
 
(d)  NORTHEAST COOP shall perform or cause to be performed inspections and tests on process equipment.  Inspection and testing procedures shall follow recognized and generally accepted good engineering practices.  Our policy will be two-fold;  1-to check the system and facility while we are working around the plant on normal operations, employees will note any  
problem or potential maintenance which needs immediate attention and either fix it immediately or notify their appropriate supervisor; and 2-Once a year we will conduct a thorough inspection following the checklist below to identify and correct any problems or potential problems that may need to be addressed by the inspection. 
Maintenance Inspection Checklist and Tests for Anhydrous Ammonia Storage Facilities 
I.  Maintenance Checklist    Yes    No and Comment 
Check Manufacturer's data plate.  Is it securely attached and legible? 
For each storage tank?    Y     
Are above-ground containers properly painted?    Y     
Are containers free of corrosion damage, dents, gouges, or other damage?    Y     
Is piping free of rust, painted {vapor-yellow & liquid-orange} and labeled?    Y     
Is piping ASME schedule 80?    Y     
Is storage vessel(s) and piping adequately protected against vehicle traffic?    Y     
Is area clean, well-kept, and free of readily ignitable materials?                                                                
                  Y     
Are saddle pads in good condition?    Y     
Are storage tanks located with ample working space all around?    Y     
Are storage tanks properly labeled? 
7 "Caution - Ammonia" or "Anhydrous Ammonia" {minimum 6" on both sides and ends} 
7 Warning and First Aid Decal    Y     
Are storage tanks at least fifty feet from petroleum tanks?    Y     
Is the facility locked when unattended? 
7 Main valves locked? 
7 Hose end valves locked?    Y     
Are hoses marked for anhydrous ammonia use?    Y     
Are hoses within current service life?    Y     
Are all hoses free from cuts, soft spots or bulges, blistering, chinking or flattening, or indications that the hose may have been stretched or slippage at the coupling?    Y     
Are all hoses properly secured, protected, and in serviceable condition?    Y     
Are excess flow valves in place?    Y     
Does the storage tank(s) have an operational pressure indicating gauge graduated from 0-400 psig?    Y     
Are automatic back-check valves installed {i.e., transport liquid line}?    Y     
Are relief valves inst 
alled?    Y     
Are relief valves installed at correct height?    Y     
Are rain caps on relief valves in place?    Y     
Does the storage tank(s) have an operational percentage fill gauge?    Y     
Are only approved ammonia valves in place?    Y     
Is the facility free of leaks and in good condition?    Y     
Are bleeder valves suitable for venting ammonia from transfer hoses into water?    Y     
Is a safety water tank {labeled-"First Aid Water"} or safety shower available {tank must be large enough to totally immerse an employee}?    Y     
Are flexible fitting splash-proof goggles worn by employees handling ammonia?    Y     
Is a rubber  protective rain suit or slicker {pants & coat} available?    Y     
Are rubber protective boots available?    Y     
Are rubber protective gloves available?    Y     
Are protective guards in place and in good condition?    Y     
Are  all employees properly trained?    Y     
Are qualified personnel assigned to handle ammonia physically capable of wearing a respirator in a hazardous environment?    Y     
Are there two (2) full-face gas masks 
with current ammonia canisters available?    N    ONLY ONE 
Are extra canisters current?    Y     
Is a First Aid kit on site?    Y     
Is a fire extinguisher in the immediate area?    Y     
Has the fire extinguisher been checked monthly and initialed?    Y     
Are wheel chocks for nurse tanks and rail cars available?    Y     
Is the local fire department capable of responding to an anhydrous ammonia emergency? 
{What level?  Awareness Level / Operations Level / Technician Level / Specialist Level}    Y    AWARENESS LEVEL 
 
Inspected by:    Inspection Date: 
    
These procedures were last reviewed or inspected by:  ROBERT PULS, EDNA WAGNER    Date:06-15-99 
    
Piece of Equipment Inspected:    Most Recent Date: 
Nh3 storage tank    06-15-99 
 
 
 
 
COMPLIANCE AUDITS 
A compliance audit is a way for you to evaluate and measure the effectiveness of your risk management program.  An audit review should be conducted for each prevention program element to ensure that they are up-to-date and being implemented correctly.  This will help you identify problem ar 
eas and take corrective actions.   
 
At least every three(3) years, you must cerify that you have evaluated compliance with the prevention program requirements for each covered process.  At least one(1) person on your audit team must be knowledgeable about the covered process.  This person may function as a team by himself/herself.  You must develop a report of you findings, determine and document an appropriate response to each finding, and document that you have corrected any deficiency.  You may want to develop a checklist.  You should take steps to correct any deficiencies you find.  You may also choose to have the audit conducted by a qualified outside party.   
 
You must keep a written record of audit findings, your response to those findings, and documents showing that deficiencies have been corrected.  You must keep the two most recent audit reports, but you need not keep a report that is more that five years old.  You may also want to keep a record of  who conducted the audit, b 
ut you are not required to do this.  
 
INCIDENT INVESTIGATION 
NORTHEAST COOP will provide a summary of the accident, recommendations and actions.  NORTHEAST COOP will make any recommendations to prevent a recurrence of the incident.   
 
INCIDENT INVESTIGATION REPORT 
Date:    Substance:  Anhydrous Ammonia    Quantity Released: 
Duration:    Weather:     
Description:         
Findings    Recommendations    Actions 
        
        
        
The expected completion date of any changes recommended by the investigation 
____________________________. 
EMERGENCY RESPONSE PROGRAM 
 
7 Coordinate emergency response with your local fire department and any other local emergency planning and response agencies. 
 
7 Coordination with the fire department may consist of a discussion with them or a walk-through of your facility.  The purpose is simply to be sure that the fire department is aware of the hazards associated with propane at your facility and ready to respond if an accident occurs.  Also, contact your Local Emergency Planning Committee (LE 
PC). 
 
7 Document all coordination with the local fire company and any other organizations. 
 
7 The person assigned the responsibility for implementing the risk management program should complete the following certification: 
 
I EDNA WAGNER have coordinated emergency response for my facility with local emergency responders in the following ways: 
 
 
Method    Date 
 
Example:  PHONE CONVERSATION WITH LEPC REPRESENTATIVE AND PHONE CONVERSATION WITH DIXON COUNTY SHERIFF OFFICE    6-08-99 
    
    
    
    
    
    
    
    
    
    
    
   
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