Battle Creek Farmers Cooperative - Osmond, NE - Executive Summary

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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  
68.10 because: 
      It stores anhydrous ammonia in excess of the threshold quantity 
      A release from this facility could impact an offsite public  
receptor (residence) 
      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  
20, 1999. 
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  
            hazards review 
            standard operating procedures 
            training program 
            maintenance program 
            compliance audits 
            incident investigation      
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.
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