NORTHEAST COOPERATIVE - WISNER BRANCH - Executive Summary

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NORTHEAST COOP WISNER 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 DAVID KINDSCHUH CUMING COUNTY CIVIL DEFENSE IN COORDINATION WITH THE WISNER FIRE DEPARTMENT 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 o 
f our anhydrous ammonia storage tank is ________61800___ 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 never had an accident involving anhydrous ammonia  that caused death, injuries, property or environmental damage or evacuations. 
 
6.  The emergency response program.  
 
a)In the event of an emergency involving our anhydrous ammonia system, it is our policy to notify DAVID KINDSCHUH, CUMING COUNTY CIVIL DEFENSE DIRECTOR IN COORDINATION WITH THE WISNER FIRE DEPARTMENT and request that they respond to the emergency. 
b) The facility has a written emergency action plan in accordance with OSHA standard, 29 CFR 1910.38.61800 
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 an on-going process at the facility.  Periodic evaluations are performed to asse 
ss 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 authori 
ty for the risk management program. 
 
Risk Management Program 
Element    Person or Position Assigned Responsibility 
for NH3 Operations in WISNER, NE 
Safety Information:    EDNA WAGNER 
Hazard Review:    EDNA WAGNER 
Operating Procedures:    KENT MEYER 
Training:    EDNA WAGNER 
Maintenance:    KENT MEYER 
Compliance Audits:    JIM MEIER 
Accident Investigation:    KENT MEYER, 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. 
The maximum intended inventory of our anhydrous ammonia storage tanks is __61800__ 
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, characteristic 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 
 
NORTHEAST COOP will strive to keep on record all equipment specifications for bulk sto 
rage 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     
Maximum Intended Inventory    61800 
Nominal Water Capacity of Largest Tank    12000 GALLONS 
Temperature    Upper:  ambient max. 110 F         OK 
Lower:  ambient min. -15 F 
Pressure    Upper:  240 PSI @ 110 F             OK 
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: ORIGINAL 
Replaced: ORIGINAL 
Replaced: ORIGINAL 
Replaced: ORIGINAL 
Internal Valve    OK 
Excess Flow Valve 
EFV1 
EFV2 
EFV3 
EFV4     
OK 
Emergency Shutoff Valve 
ESV1 
ESV2     
OK 
 
Hydrostatic Relief Valve 
HSV1 
HSV2 
HSV3 
    
OK 
Pump 1    N/A 
Pump 2    N/A 
Compressor 1    OK 
Compressor 2    N/A 
Strainer    OK 
Check Valves    OK 
aSightflow Indictor    OK 
Tank Level Indicator    OK 
Tank Temperature Indicator    N/A 
Tank Pressure Indicators    OK 
Other Temperature Indicators    N/A 
Other Pressure Indicators    N/A 
Design Codes     
State or Local Codes    ANSI K-61-1 1989 Edition with all Amendments 
Piping Design     
Tank Design     
Vaporizer Design     
Date of Most Recent Revision    Revised By: CENTRAL WELDING  
    
 
(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. 
Description of Major Change    Year Installed    Appropriate Design Code 
        
        
        
Reviewed By:        Date: 
 
HAZARD RE 
VIEW 
(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 further comment and a projected completion date for correcting the deficiency. 
Siting    Yes/No/NA    Comments-C 
orrection 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, are they well anchored, supported , and of slip proof construction?    Y     
6.  On installations with stairw 
ays 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                                     
11.  Do you have appropriate l 
evel 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? 
   N/A     
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 Edition? 
    
Y 
 
 
 
Y     
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?    Y     
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?    N/A     
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 Edition?    N/A     
23.  Are all above ground lines securely fastened to structural memb 
ers of adequate strength and supported at proper intervals?         
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     
3.  Are your operators whose job duties require the use of the above listed equipment understand the operating limits of the system in rega 
rds to: 
 
Capacity? 
 
Pressure? 
 
Temperature? 
 
Adverse Weather or Natural Conditions? 
    
 
 
 
 
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     
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     
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 
 
N/A 
 
 
N/A     
Gene 
ral 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?    ?     
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/A 
 
 
 
N/A 
 
N/A 
 
N/A 
 
N/A 
    
4.  Has a federal, state, or local agency or fire authority required: 
 
Local Gas Detection Monitors? 
 
Perimeter Gas Monitors and Public Alarms?     
 
 
N 
 
N     
This Hazard Review was Completed by:        On (Date): 
EDNA WAGNER, KENT MEYER        06-09-99 
 
The latest date by which all changes resulting from the process hazard review are expected to be completed is _________LATE 1999. 
OPERATING PROCEDURES 
(a)  NORTHEAST COOP shall prepare written operating procedures that provide clear instructions or steps for safely conducting a 
ctivities 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 _____61800__ 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-identical, except that the pump method pressure in the two tanks is equal throughout the process. 
Before attaching any hos 
es 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 before connecting any hoses  
5. All delivery tank and storage piping system valves are confirmed closed. 
6. All hoses, hose c 
onnections, 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 slowly opened and inspected for leaks. 
13. Before starting the pump, check the liquid in the bulk storage tank.  If the ta 
nk 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 relieved, 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 throughout 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, hit 
ch 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 ha 
ndle; 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 their 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     
KENT MEYER     
DEAN SCHULTZ     
RICHARD BRAHMER     
GARY MCBRIDE     
    
    
 
Certified by:________Kent Meyer_________   ____06-09-99____ 
_______________ 
       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 Management Plan the type(s) of competency testing we use.  We will also keep an attendance log for any formal training or refre 
sher 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 tr 
ained 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________03-16-99__________ 
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 tr 
ain 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 t 
heir 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 
 
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?    N    IN FUTURE 1999
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