Battle Creek Farmers Cooperative - Osmond, NE - Executive Summary
The United States Environmental Protection Agency (USEPA) developed the |
Risk Management Program (RMP) rule (40 CFR 68) to assist facilities in
preventing accidental releases of highly toxic or flammable chemicals.
The RMP established three levels of requirements for the program.
Programs 1 and 2 are for facilities that pose less risk to the
environment and therefore have reduced compliance requirements.
Program 1 is designed for "no impact" facilities and has the fewest
requirements, while Program 3 is the most stringent of the three
The program level for each facility is determined by:
Use of regulated substances in threshold quantity
Impact of an off-site public receptor (e.g., residence, school,
North American Industrial Classification System (NAICS) code
Five-year accident history
OHSA PSM (29 CFR 1910.119) applicability.
This facility is regulated under Program 2 requirements under 40 CFR
It stores anhydrous ammonia in excess of the threshold quantity
A release from this facility could impact an offsite public
It does not operate under a NAICS code specified in the rule
It is not subject to OSHA PSM (this is a retail facility).
40 CFR Part 68 Subpart G applies to an owner or operator of a
stationary source that has more than a threshold quantity of a regulated substance
in a process, as determined under 40 CFR 68.115 Battle Creek Farmers
Cooperative - Osmond, NE stores more than the threshold quantity of
anhydrous ammonia (10,000 pounds) for commercial sale.
Therefore, Battle Creek Farmers Cooperative - Osmond, NE is required to
submit a Risk Management Plan (RMP) as defined in 40 CFR 68.150 by June
The Battle Creek Co-op is committed to operating in a safe and
compliant manner. Employees involved in operating the ammonia storage
facility are thoroughly trained to identify and
the hazards posed by this the transfer process. Process
safety and emergency response materials are kept on site and
periodically reviewed. Information includes information pertaining to
the hazards of ammonia, process technology, process
equipment, and emergency response procedures.
The stationary source is the Battle Creek Farmers Cooperative - Osmond,
NE anhydrous ammonia storage facility. The largest ammonia
process group (e.g., largest storage tank or group of interconnected
tanks) is a railcar that has a storage capacity of 33,400 water gallons
(156,000 pounds) parked at a rail siding at the facility.
The railcars are used when an outside contractor converts anhydrous ammonia
(using a T-reactor) and other items into 10-34-00 fertilizer at this facility.
This process is in operation about 12 days per year.
The total ammonia stationary storage capacityconcists of:
up to three railcars with 33,400 water gallons of storrage
(468,000 for three railcars) for tempora
ry storage capacity
30,000 water gallons and an 18,000 water gallon storage tanks
or 224,000 pounds of permanent storage capacity
The facility also stores numerous smaller transportable tanks (nurse tanks)
that are actually used in the fertilizer application process.
The facility is required to complete one worst-case release scenario
per hazardous substance handled [68.165(a)(2)] to determine program
applicability. Battle Creek Co-op has chosen to use the DEGADIS+
release model to determine offsite impacts.
For this facility, a worst-case release would occur in the event that
the largest ammonia and propane storage tanks would rupture and the
entire contents would be released to the atmosphere in 10 minutes. The
worst-case scenario requires a ground-level release height (0 feet).
Ammonia release rate for use of DEGADIS+ is presented below:
Sample Ammonia Endpoint Calculation
Given: Storage Tank Capacity is 33,400 water gallons
ANSI K61.1 fillin
g density = 56 % (of water wt.)
Release Rate = Tank Capacity / 10 minutes
=(33,400 gal * 8.345 lb/gal water)*(0.56) / 10 min
= (278,000 lb)*(0.56) / 10 min
= 156,000 (rounded) / 10 min
= 15,600 lb/min
Results of Worst-Case Ammonia Release Scenario
Input of the preceding data into the DEGADIS+ release model, the
results indicate a worst-case impact of 2.22 (rounded) miles for the
facility. The worst-case model output summary is included at the end
of this section. The rule defines the toxic endpoint of anhydrous
ammonia to be 0.14 mg/L.
The residential population within a 2.22 mile radius of the facility is
800 (rounded) based on the 1990 US Census data.
The facility is required to complete one alternate release scenario per
regulated chemical per 40 CFR Part 68.165(a)(2). The alternative
release scenario considered is in accordance with the guidelines
provided in 40 CFR 68.22 and 68.28.
The alternative scenarios ch
osen for this facility involves a release
because of a sudden split in the hose during transfer at the largest
permanent storage tank. While this
scenario is still unlikely because the transfer hoses used have
multiple layers of rubber and a layer of braided stainless steel wire
underneath the outer sheath (to prevent abrasions, cuts, and splits) it
is more likely than the worst-case as required by 40 CFR 68.28(b)(i).
This scenario is also the
most likely to occur, since overfilling is prevented by a return vapor
line to the tank truck making the delivery. The transfer hose rupture
area is assumed at 0.5 square inches. Because personnel are always
present at the facility during transfer, Battle Creek Co-op personnel
will respond within 10 minutes. Release rate was calculated using the
OCAG tank release equation (Section 8.1.1).
Results of Ammonia Alternative Release Scenario
There are 2 people located within 0.23 miles from the facility. Thus,
this alternative re
lease scenario satisfies the conditions of '68.28.
Results of Propane Alternative Release Scenario
Input of the preceding data into the RMP Comp program, the results
indicate an alternate case impact of 0.05 miles for the facility. The
residential population within this radius is 0
The facility maintains written process safety information to enable
employees involved in handling ammonia to identify and
understand the hazards posed by this process. Written information
includes physical properties of ammonia, health risks
associated with ammonia exposure, and material safety data
sheets. In addition, the facility has conducted and/or implemented the
standard operating procedures
The Battle Creek Farmers Cooperative - Osmond, NE anhydrous ammonia
facility in Osmond has had no
recordable accidents within the
past five years.
Recommendations for safety improvements were identified in the hazard
review which was completed June 14, 1999. Recommendations were
identified for two categories: Standard Operating Procedures, and
Training. Safety improvements will be investigated concerning their
impacts on other systems and/or procedures prior to implementation.
Additional recommendations may be made upon review of any accidents
and/or when the hazard review is updated every five years.