HomeMy WebLinkAbout1977 09-12 .
To: The Brooklyn Center Planning Commission September 12, 1977
.. From: Bill Howe, Vice President
L Howe, Inc.
Subject: Response to the Planning Commission's request
for additional information.
Howe Inc. has been asked by the Brooklyn Center Planning Commission to
supply additional information about our facility and operation of our plant.
Before I respond to each of these items, I feel it necessary to explain what
Howe Inc. is all about.
Howe, Inc. performs two separate operations within the agricultural
industry. The first is the manufacturing and distributing of commercial
fertilizers. Fertilizer is used.throughout the United States and the World
and is responsible to a large degree for the abundant supply and quality of
food enjoyed by us all. Fertilizers, like those produced by Howe, Inc., are
responsible for 400 of all food produced in the United States. We are proud
of being a part of this industry and of our records for safety and 'health.
The second function we perform is the storage and distribution of
agricultural chemicals. These chemicals, like our fertilizers, are purchased
and applied by farmers in P We receive these chemicals prepackaged.
We do not manufacture or repackage any of these chemicals.
I would like to respond separately to the first two items requested by
the Planning Commission: First - agricultural chemicals and second - fertilizers.
T 1.) What types of agricultural chemicals are stored on our premises?
2.) What are the levels of toxicity of these agricultural chemicals?
Included in the documents contained in this statement is a list of our
agricultural chemicals and quantities on hand as of September 1, 1977. It
is important to note that we do not manufacture or alter these chemicals but
are only storing and distributing than. Also attached are letters from Dr.
Gerald Miller and Dr. Phillip Harein of the University of Minnesota- confirming
the safety of handling and storing these chemicals.
The toxicity of these chemicals vary from one chemical to another. Attached
are toxicity statements and labels for most of the major chemicals we handle.
Also included are cover letters from Dow Chemical Co., Ciba -Geigy Corp.,
Dupont, Chevron Chemical Cc. and FMC Corp. attesting to the safety of storing
and handling these chemicals.,
All of the chemicals we handle are registered with the Environmental
Protection Agency and approved by the U.S. Dept. of Transportation, and are
stored in an approved facility.
Secondly, I will respond to the committee's questions regarding fertilizer
materials.
1.) What types of fertilizer materials are stored on our premises?
2.) What are the safety and health hazards of these materials?
• Fertilizer is made of three basic materials: Nitrogen, Phosphorus and
Potassium. We do not mine and process any of these materials but buy them
-2-
processed ready for use.
Potassium is required to sustain plant life, and is essential to human
nutrition. Potassium chloride, the source of potash stored at Howe, Inc.,
is similar to table salt and is what doctors prescribe for lcsa salt diets
in case of high blood pressure and related ailments. It is a common material
used as food for humans and animals as well as fertilizer used for growing
food crops.. These materials are shipped to us from Canada or Carlsbad, New
Mexico.
The second element essential for life is phosphorus. Phosphorus is
intimately associated with all life processes and is a vital constituent of
every living cell. Without phosphorus there could be no life.
The phosphorus we store at Howe, Inc. comes from Florida or North Carolina
where large deposits of phosphates have accumulated.
The third ingredient in the fertilizer we manufacture is nitrogen. Nitrogen
is an inert gas which makes up 80% of the air we breath. Plants use nitrogen
when it is properly combined with oxygen or hydrogen. In these combined forms
it is known as nitrate (NO or ammonia (NH nitorgen.
The materials stored by Howe, Inc. are listed below by element source:
Potassium: Potassium Chloride - Potassium Magnesium Sulfate
Phosphorus: Triple Superphosphate - Di.ar=nium Phosphate - Phosphoric
Acid
Nitrogen: Ammonium. Sulphate - A.mmniuum Nitrate - Urea - Low Pressure
Nitrogen Solutions - No Pressure Nitrogen Solutions
It is important to note we do-not store or use any anhydrous ammonia.
The attached letter from N -Ren Corp., our supplier of nitrogen materials,
• states that they have never shipped anhydrous armnia to our plant. The letter
also states; The products Howe, Inc. uses, "will neither create nor cause
environmental or health problems. This conclusion is supported by the demon-
strated ability and experience of Howe, Inc. and its employees daring the last
twenty years. ". Also enclosed is a letter from our medical clinic which treats
all our employees, stating they have never treated any Howe, Dic. employee
for respiratory or health problems.
The enclosed letter from Ed Wheeler of the Fertilizer Institute, an
organization which compilies statistics for the fertilizer industry across the
United States reads " With hundreds of granulation plants operating in the
country, we are aware of no recorded instances of impaired personal health
of persons in the surrounding vicinity of these plants. Even for workers
within the plant area, we do not know of any documented cases of injury to
health. ".
You will also find copies of letters attached frcm the Potash Institute,
Texasgulf, Inc. (an international supplier of phosphates and potash) and
Amax Chemical Corp. (the third largest North ATwexican producer and supplier
of potash); each stating that fertilizer is a safe natural product which
serves the world by producing food.
We also have underground storage for distillate fuel. We have a 6,000
gallon storage for gasoline, a 10,000 gallon for dietel fuel and a 10,000
gallon for fuel oil. Also included for your inspection is a licence from the
City of Brooklyn Center to pump these fuels from bulk storage. In addition
to this, we have an 8,000 goon sulfuric acid tank,'two- 30,000 gallon phosphoric
acid tanks, three- 22,000 gallon low - pressure nitrogen solution tanks and an
8,000 gallon no pressure nitrogen solution tank.
3.) What measures will be taken to eliminate unauthorized outside trash
disposal and debris?
-3-
With any manufacturing facility there is some debris from normal operations
• and maintenance. We will try to keep rubbish and debris to a minimum. However,
the screening that is included in our proposal would reduce the visability of
the outside trash and debris that can be seen on the Soo Line Property.
4.) The intensity and frequency of blasting and other noise - producing
activities related to the production.
Howe, Inc. occassionally does use blasting, which is a normal procedure
to insure the safety of our payloader operator from overhang in our bins. All
blasting is done within our buildings with no effect to our buildings or neigh-
boring area. We have a state permit issued 5 -17 -77 which is required for this
types of work. A permit copy is attached. Conforming to all regulations per-
taining to use and storage of these materials is necessary before a permit is
issued. The maximum use of these materials in a years time is 300 pounds.
The other nice producing activity mentioned at the first hearing is the
switching brought in by the Soo Line R.R. The Soo Line R.R. gives us one switch
a day when needed. There are many days when we do not need a switch. We feel
that we should not be held responsible for the Soo Line activities not pertain -
ing to the Howe plant.
One more noise producing activity mentioned at the first hearing was the
noise of traffic from our payloader tractor and truck traffic along the north
side of our building. Here again, the building as proposed would curtail any
noise coming from the movement of trucks and equipment.
5.) What provisions forremergency procedures including posting of after-
hours telephone numbers on the building?
There had been an allegation made at the first hearing that the police
and fire department did not have emergency numbers for Howe, Inc. After the
meeting I called the Brooklyn Center Police and Fire Department and talked
to Ken Smith. He had telephone numbers listed for Bill Howe, Tom Howe and
Ralph Howe. In addition to those already on file, I gave him numbers for two
other office employees. To insure that no future confussion occurs, we have
posted these names and numbers on the office and plant doors.
6.) Existing and proposed hours of operation.
Our normal hours are between 7:00 AM and 5:00 PM. monday - friday. Our
production day does not vary much from our normal working hours. Reviewing
our past year - July 1376 through June 1977 - we manufactured fertilizer 142
days.
Start -up time is as follaas: After 7:00 AM 80 days
Between 6;00 - 7:00 AM 31 days
Between 5 :00 - 6:OOAM 21 days
Between 4:00 - 5:00 AM 8 days
Before 4:00 AM + �2 d_a�s
ays
Any start up time before 6:00 AM was in our spring rash season. Shut down
was normal cn all days that we ran. You can see from the schedule that our
hours were not Erratic. At no time did we run two and three shifts and at no
• time did we run at night.
7.) A discription of shipping and receiving activities, including the
amount accomplished by over -the road vehicles.
- 4 -
Fertilizer shipments from Howe, Inc. for the past year July 1976 through
June 1977 were over 90% by truck. This due,in fact, that trucks can expedite
the movement of fertilizer to farms over short distances in a shorter period
of time. Loading hours at the plant are 7:00 AM to 5:00 PM.
The deliver, of fertilizer to the plant for the same time period, by
tonnage, was 19% by truck and 81% by railcar. There were 510 truckloads and
556 carloads to Howe, Inc. Also enclosed is a letter from the Soo Line R.R.
showing simuliar figures.
The comments made by the Mpls Alderman regarding industrial zoned property
along - the Soo Line tracks reverting back to residential areas were surprising
when in Mpls. they have allowed future industrial expansion abutting residential
areas, such as Walker Lumber Company.
We have worked and cooperated with the Minnesota Pollution Control Agency.
Enclosed you will find copies of operating permits issued by the Minnesota
Pollution Control Agency. Also attached is the inspection report by the
Occupational Safety and Health Division or OSHA. The report lists three
nonserious violations. Two of the violations were on an obsolete bench grinder
not in eus , which has since been scrapped. The third was no cover guard on a
pulley belt, which also has been corrected. There were no fines imposed.
You will also find enclosed a letter frcm the Tennessee Valley Authority
in Muscle Shoals, Alabama. The TVA people are recognized as the leaders in
fertilizer development and research in the world. Some of their processes
and patents are used in every fertilizer plant in the world.
Within this letter Mr. Hubert Balay expresses his views on Howe, Inc.'s
efferts to improve our pollution control methods. He states Howe, Inc. has
"been willing to use new raw materials and operating techniques, sometimes at
considerable extra cost to you, when they showed evidence of reducing discharge
• from your plant. " .
He also states "You are constantly upgrading your equipment. Two years
ago you installed on your a=,oniator a ventri scrubber with 2 1 + inches of
water pressure drop. This device is accepted in the fertilizer industry as the
best scrubbing device for removing aerosols and fumes from a granulation plant.
I understand you have recently decided, at considerable expense, to increase
the pressure drop on this device to 40 inches of water to improve the sobbing
efficiency of your plant.
He continues by adding, "I believe that this indicates that you are keeping
your facilities equipped with the best equipment and using the best techniques
available. ".
Mr. Balay is also aware of other decisions made by Howe, Inc. which shows
a cooperative attitude towards our neighborhood and environment.
Quote "I have also been impressed by your restraint in adopting practices
which would improve your profit picture, but which might annoy your neighbors.
An example of this is your decision not to use anhydrous ammonia as a nitrogen
source. Anhvdrous ammonia is the most economical form of nitrogen available to
the industry arid, as far as I am able to determine, is used by every granulation
plant in the United States except yours. Your decision not to use this volatile
substance has constantly put you in a bad competitive position over the years."
Unquote.
The letters and documents from manufactures of agricultural chemicals,
Producers of Raw Fertilizer Materials, University of Minnesota, Crystal Medical
Clinic, Minnesota Pollution Control Agency, State of Minnesota, The Fertilizer
Institute, The Potash Institute, OSHA and the Tennessee Valley Authority show
• that Howe, Inc. has an excellent record with the industry and State in concern
for environment and safety. Howe, Inc. has a progressive cooperating attitude
with all the governing agencies and bodies.
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I sincerely hope this is sufficient information for the Planning
Ccnrnission to substantiate the responsive attitude taaard plant safety,
• concern of environment and neighbors and health hazards. I also ask the
Planning Canrnission to reecanrp. d our proposal for rezoning and building
permit to the City Council.
The proposal as it has been submitted would alleviate many of the concerns
raised at the first meeting. First, it would -act as a buffer for noise from
trains, trucks and payloader equipment. Second, it would act as a screen from
any trash or debris. Thirdly, and most important, we are proposing an improvement
and upgrading of the premises which would be beneficial to both the neighborhood
and the City of Brooklyn Center.
Bill M. Howe
Stored Chemicals at Howe Inc.
Aatrex 80W 945 # Norex 50WP 1122 #
Aatrex 4L 495 gal. Paraquat 9 gal.
Amiben 2# 15 gal. Pylac 29 gal.
Amiben 10G 5650 # Pramitol 25EC` 6 gal.
Quanerary Ammonia 20 gal. Pramitol 5PS 280 #
Aquathal' 150 # Prowl 140 gal.
Balan 110 gal. Pyrax 7500 #
Banvel 13.5 gal. Pyramin W 30 #
Basagran 3 gal. Randox 4# 70 gal.
Benlate 50 # Roundup 11 gal.
Bladex 15G 2850 # Serafume 3 gal.
Bladex 80W 30 # Sevin 80W 1280 #
Bladex 4L 150 gal. Sevimol 4# 5 gal.
Bravo 6F 170 gal. Princep 4G 2350 #
Captan 50W 384 # Princep 80WP 65 #
Chloro IPC 135 gal. Spreader Sticker 142 gal.
Citowett Plus 10 gal. Telone C -17 1410 gal.
Crop Oil 475 gal. Temik 10G 300 #
Chlordane 33G 1000 # Terrachlor 20 gal.
Counter 15G 1140 # Thimet 15G 1380 #
Dacthal 75W 1164 # Thiodan EM -2 139 gal.
Dacthal 5G 50 # Tok E -25 100 gal.
Daconate 6 27 gal. Tok 50WP 50 #
Dasanit 10G 200 # Toxaphene 50 #
Desicate 60 gal. Treflan EC 31 gal.
Diazinon 14G 100 # Vapam 32.7 10 gal.
Diazinon 50WP 155 # Vegadex 40 gal.
Diazinon AG500 167 gal. 2, 4 -D 1019 gal.
Dibrome 8E 11 gal. MCPA ' 46 gal.
Difolatan 350 gal. Silvex 13 gal.
Dow General 2140 gal. Trimec 6 gal.
Dow Pon M 1200 # 2D /2T Brush Killer 35 gal.
Dyfonate 20G 4000.#
Dyfonate 4E 120 gal.
Dual 105 gal.
Eptam 7E 5 gal.
Eradicane 6.7E 25 gal.
Evik 80 #
Furdan 10G 750 #
Furdan 4F 487 gal.
Kocide 100 #
Lasso Liquid 1995 gal.
Lasso II 2700 #
Lorox 25W 420 #
Lannate 1 gal.
Liqnasan 25 gal.
Malathion 138 #
Malathion EM -5 97 gal.
Maloran 50WP 1080 #
M -H 30 180 gal.
Manzate 80WP 9300 #
Manzate 200 345 #
Marlate 50WP 364 #
Methoxyclor EM -2 61 gal.
Monitor 4 200 gal.
AGRICULTURAL EXTENSION SERVICE
U09 g0aim
UNIVERSITY OF MINNESOTA Department bfAgronomy and Plant Genetics
• St. Paul, Minnesota 55108
i
(612) 373.1181
August 31, 1977
TO: Whom It May Concern
RE: Safety of herbicides
This letter is intended to verify that the herbicides
handled by Howe Chemical Company are cleared for use
by the Environmental Protection Agency and the Minnesota
Department of Agriculture.
• The herbicides under consideration include Lasso, Treflan,
Sencor, Dual, Lorox, Chloro IPC, Vegadex, P,andox, Banvel,
2,4 -D, Atrazine, Bladex, and TOY.. These chemicals are
used on crops in Minnesota and are safe to handle, store,
and apply within the directions on the labels.
Sincerely, �Q
Gerald R. Miller
Extension Agronomist
GRM /lbw
I
•
UNIVERSITY OF MINNESOTA, U.S DEPARTMENT OF AGRICULTURE, AND MINNESOTA COUNTIES COOPERATING
AGRICULTURAL EXTENSION SERVICE
' I
n, UNIVERSITY OF MINNESOTA Department of Entomology, Fisheries and Wildlife
Hodson Hall
1980 Folwell Avenue
St. Paul, Minnesota 55108
,
August 31, 1977
Mr. William Howe
Howe Incorporated
4821 Xerxes Ave. N.
Minneapolis, MN 55430
Dear Bill:
I understand that your neighbors are concerned regarding the storage
and distribution of pesticides from your facility at the above address.
We have to agree that pesticides are poisons and whenever we handle
large amounts at points of distribution, etc. all safety measures
should be applied to ensure that undue hazards are not allowed.
• There is always the possibility that natural disasters might result
in a fire, flood or excessive wind damage. If such would occur where
pesticides are concentrated, there would be increased concern to clear
up the damaged area correctly. As you know, all of us in the agricultural
chemical business are prepared for such possible mishaps.
The potential for environmental contamination where pesticides are only
stored and distributed is relatively low compared to any pesticide
manufacturing, formulating or repackaging facility. Consequently,
I doubt that your operation should be of any concern to other personnel
or facilities near you or in the immediate area.
Sincerely yours,
Phi U'T`p Harei n
Extension E tcmologist
PKH /bam
UNIVERSITY OF MINNESOTA, U.S. DEPARTMENT OF AGRICULTURE, AND MINNESOTA COUNTIES COOPERATING
FMC Corporation
Agricultural Chem ical "Division
11128 John Galt Boulevard
• Omaha Nebraska 68137
(402) 592 5090 Twx 910 622 8205
rwM
August 29, 1977
To Whom It May Concern:
Howe Chemical. Company located at 4821 Xerxes Avenue North,
Minneapolis, Minnesota is a distributor of F240's Thiodan
Miscible formulation (Code 5010. They are distributors of
this product and are not involved in any formulation processes
of FMC Thiodan.
Thiodan Miscible is an EPA registered compound (EPA Reg. No.
279- 1182AA).
Howe Chemical Company has in the past received their Thiodan
Miscible in five gallon cans and thirty gallon drums.
Freight Classification: INSECTICIDE, LIQUID; Flammable Liquid:
• (as Insecticides, Agricultural)
Product Specification: Thiodan Miscible contains 2 pounds Thiodan
(endosulfan) per gallon.
Thiodan is a registered trademark of Canadian Hoechst Limited.
J e {
� Jo
ca Sales Manager
Agricultural Chemical Group
jcs
awron
Chevron Chemical Company
7524 -42 Hickman Road, Des Moines, IA 50322
• August 29, 1977
Mr. Bill Howell
Howell, Inc.
4321 Xerxes Avenue North
Minneapolis, Minnesota 55430
Dear Mr. Howell:
At the request of our District Manager, Mr. Roger Carter,
we wish to advise you that the products which we sell to
your firm are all registered commercial size agricultural
chemicals and they are all currently registered with the
Environmental Protection Agency (EPA). They are packaged
to comply with Department of Transportation specifications.
It is our understanding that materials sold, shipped or picked
• up by your firm are resold, warehoused and reshipped by your
firm in the original containers with no repackaging or other
processing being performed.
Very truly yours,
"—p . E- ( /&. D/'
R. C. Yapp
Regional Manager, Pesticides
JEH:mm
I
® DOW CHEMICAL U.S.A.
4901 WEST 77TH STREET
MINNEAPOLIS, MINNESOTA 55435
612 • 835 -4200
September 2, 1977
Mr. Bill Howe
Howe Fertilizer, Inc.
4821 Xerxes Avenue North
Minneapolis, Minnesota 55430
Dear Mr. Howe:
The attached Material Safety Data Sheets accurately represent
the Dow agricultural products that you presently distribute
for us. The Dow products that you distribute, to our knowledge,
are resold by you unaltered and in the original Dow containers.
Therefore, the Material Safety Data Sheets provide a very
accurate profile of each of these agricultural chemical products
under normal storage conditions. All of the Dow agricultural
chemical products distributed by Howe Fertilizer, Inc. have
• received approval from the Environmental Protection Agency,
the Federal Department of Transportation, and the Minnesota
State Department of Agriculture. Furthermore, these products
are recommended for use on the Minnesota crops by the University
of ;Minnesota, Agricultural Extension Department.
Howe Fertilizer, Inc. has been a distributor for Dow Agricultural
Chemicals for approximately 10 years and, to our knowledge, has
never had an accident with any Dow agricultural product. There-
fore, I can only anticipate that our business relationship will
continue in a like manner for the future, and as the growth of
Minnesota agriculture requires additional growth in your company.
Best regards,
FP G. Bo_��
Agr.icu`ftural Department
Minneapolis Office
enc.
klm
•
AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY
N— a ` Oorpor - alloll Post Office Box 418, South St. Paul, Minnesota 55075 (612)437-3101
!°' TWX 910-578-3816
ST. PAUL. AMMONIA PRODUCTS DIVISION
August 31, 1977
Mr. William Howe
Howe, Inc.
4821 Xerxes Avenue North
Minneapolis, Minnesota 55430
SUBJECT: Nitrogen products shipped to Howe, Inc. plant
Dear Mr. Howe:
Confirming our telephone conference of last week,
N -ReN ships to your fertilizer plant at the above address the
following nitrogen products:
a. Low Pressure nitrogen solution
b. Non - Pressure 28% UAN solution, and
• c. Agricultural Ammonium nitrate prills.
These products properly stored and handled will neither
create nor cause environmental or health problems. This con-
clusion is supported by the demonstrated ability and experience
of Howe and its employees during the last twenty (20) years.
It may be of interest that we have produced, stored
and shipped these three well known products, essential for
agriculture, in very large quantities to Upper Midwest processors
and dealers since 1957 and have experienced no difficulty in
their transportation or handling.
In view of the recent widely publicized accident near
Osseo, involving the rupture of a hose on a truck transporting
anhydrous ammonia, I reviewed our records; and they show that
since you and we commenced doing business in the late 1950's we
have shipped no anhydrous ammonia to your Xerxes Avenue North
address.
Sincerely, 1
N- N CO ORATION
S PAUL` IA RODUCTS DIVISION
• George Van Nost - and
Sr. Vi e President & Gen. Mgr.
GCV /nj
Production and Terminal Facilities Drawer D East Dubuque, III. 61025 (815) 742.3101 TWX 910 - 642 -3790
CRYSTAL MEDICAL CLINIC
5636 WEST BROADWAY
MINNEAPOLIS, MINN. 55428
537-8413
• FAMILY PRACTICE
R. L. ANDERSON, M.D.
R. H. OPHEIM, M.D.
.I. C. MUESING, M.D.
SURGERY 29 August 1977
B. H. McLAUGHLIN, M.D.
To Whom It May Concern:
Re: Howe Fertilizer Inc.
To my knowledge, none of the employees of the above -named company
have been treated here for respiratory problems or any other health
problem.
bg
J. C. Ymesing, M. D.
I
I
•
The Fertilizer Institute
1015 18th Street, N.W.
Washington, D.C. 20036
• 202) 466 -2700 • Telex 89 -2699
EDWIN M. WHEELER
Ffesident
August 29, 1977
M r. Bill M. Howe
Vice President
Howe, Incorporated
4821 Xerxes Avenue, North
Minneapolis, MN 55430
Dear Bill:
We are disappointed to learn of the questions being
raised regarding your application for a rezoning parmit
to allow an expansion of the storage facilities at your
fertilizer plant in Brooklyn Center. Not having detailed
information on these questions, we can only surmise what
they may be.
With hundreds of granulation plants operating in the
country, we are aware of no recorded instances of impaired
personal health of persons in the surrounding vicinity of
these plants. Even for workers within the plant area, we
do not know of any documented cases of injury to health.
Admittedly, there can be visible levels of dust in many
operations handling solid fertilizers, just as in handling
sand, limestone and other bulk solids. We know too that
modern technology can hold this to a minimum.
Thus, I hope members of your local zoning board will not
impose undue limitations on expansion of your operation
solely on the basis of apprehension. With all available
information we have at hand, we see no grounds for such
fear.
Sin re ,
Edwin M. Whee
EMW /sm
AMAX Chemical Corporation
i a Cominco American Incorporated
Duval Corporation
P I
Great Salt Lake Minerals G Chemicals Corpora non
A t International Minerals G Chemical Corporation
i
® ,� Kolium Chemicals
Mississippi Chemical Corporation 214! -f
Dosw Avenue
•� Pat." Company of America St. Paul, Pinnesota 55108
Potash Company of Canada Limited Telephone 612 - 644 -3264
Potash Corporation of Saskatchewan
Sylvrte of Canada (l
Texasgulf Inc. August 29, 1977
United States Borax G Chemical Corporation
Ms.. Cecilia Scott, Chairperson
Planning Commission
4104 Lakeside Avenue, N.
Minneapolis, Minnesota 55429
Dear 'is. Scott:
This letter is to fr1low - up in a general way on a conversation with Mr. Bill
Howe about sore of the concerns raised on fertilizers by people attending the
meeting on his rezonin•- and building permit. I will comment on the agronomic
and mineral nutrition aspects of fertilizers for plants and crops.
In order for crops, i::cluJ in, flowers, lawns, shrubs, trees or vegetables, to
grow they usually require 16 of the 100+ chemical elements. Fortunately, most
of a crop is :-lade up of carbon, hydrogen and oxygen, which comes from carbon
dioxide from the air and water. The other thirteen elements, including nitrogen,
phosphorus, potassiur, sulfur, calcium, magnesium, boron, chlorine, copper, iron,
• manganese, molybdenum and zinc, rust come from the soil or fertilizers that are
applied to supplement the soil's supply when inadequate amounts are present under
natural conditions.
In the 1840's scientists eiscovered that it was possible to manufacture fertilizers
and apply them to supplement the soils supply. Since that time research has been
developed so that it is possible to manufacture fertilizers that carry these
essential elements. 'lost fertilizers carry nitrogen, phosphorus and potassium,
because these are the elements that are required by plants in largest quantities
or are most often deficient in soils. These are part of every living cell and
are essential for life. The secondary elements such as sulfur, calcium and
magnesium are needed in lesser amounts, while the other elements, often referred
to as micronutrients, are required in only minute amounts.
Fertilizers are made up of salts which contain the essential elements which are
applied judiciously to soils. Like any salt, such as table salt which we use to
flavor our food, as well as to provide sodium and chloride and /or iodine in our
diet, fertilizer salts have to be used wisely. Just because some fertilizer
enhances plant growth and crop yield, more is nor- necessarily better. That is
the reason why research on soils and added rates of various fertilizers has been
used to establish recommended rates for soils and crops in Minnesota: and other states.
Fertilizers are used throughout the United States and the world and are responsible
to a large degree for the abundant supply of food enjoyed in the U.S. and developed
countries of the world. The manufacture of fertilizers, such as is being done at
• your Howe plant, in a vital initial link in providing farmers and vegetable growers
with fertilizers containing the plant food essential to grow their crops.
If you have any further questions that you believe agronomic research facts could
answer, please do not hesitate to contact me.
Sincerely yours,
cc�A Mr. Bill Howe ` - , , 4.
Dr. R. E. Wagner Robert D. Munson, Ph.D.
•sea..__. n�..�..
TexasgUITInc.
• P. O. Box 30321, 4509 Creedmoor Road Raleigh, North Carolina 27612 (919) 782 -7070
Agricultural Chemicals Division
August 29, 1977
Mr. W. C. Howe, Vice President
Howe Inc.
4821 Xerses
.North Minneapolis, Minnesota 55430
Dear Bill:
As you know, the Agricultural Division of Texasgulf produces a complete line
of phosphate products at our Lee Creek, North Carolina plant and a complete
line of potash products at two potash facilities which are located in Moab,
Utah and Allan, Saskatchewan, Canada.
The production facilities maintain a close control on the products as they
are being manufactured. The phosphate and potash products produced at these
plants meet governmental standards.
• The loading crews at the various plants load phosphate and potash product
for shipment to the export market as well as domestic shipments for use in
manufacturing fertilizer. Our shipping record shows that Texasgulf has
shipped to 46 of the 50 United States.
In the past, we have shipped various phosphate and potash materials to your
Minneapolis plant .... Run -of -Pile Triple Superphosphate, Granular Triple
Superphosphate, Di.am-nonium Phosphate, 54% Phosphoric Acid, Code 45 Super -
phosphoric Acid, Standard Potash, and Coarse Potash. We look forward to the
opportunity to continue to supply phosphate and potash material to you in
the future.
Minnesota farmers used in excess of 2 million tons of fertilizer materials
in 1976. The U.S. Department of Agriculture, the University of Minnesota
Ag Experiment Station, Ag Extension Service and others have been constantly
analyzing the use of fertilizers and the resulting yields. Because of this
research, recommendation regarding rates of application, handling and place-
ment of the fertilizer, time of year to apply and other items relating to
use of fertilizers have been developed to aid the fertilizer dealer and the
farmer to do a professional and scientific job of increasing yields. America
is not only growing more, but the nutritional quality of what we are growing
is much better.
When you consider the fact that 25 -35% of the crop harvested is due to the
use of fertilizer and that the food cost in this country is the lowest in
the world (16 -170 of our spendable income versus 30 -60o in other
• developed countries), and that the American farmer produces in sufficient
abundance to allow the united States to sell in excess of 22 billion dollars
to other countries, which helps our trade deficit, then the real importance
of fertilizer comes into proper perspective.
i
Mr. W. C. Howe
Page 2
August 29, 1977
We appreciate your business and are proud to be a part of an industry
that contributes to the tremendous efficiency and productivity of the
American farmer.
Si ly y rs,
R. Rowan j
RWR:rhm
APAAXChemical Corporation
A BU6BIOIARY OF AMAX INC
35 MASON STREET, GREENWICH, CONNECTICUT 06830 • (203] 622 -3500
August 26, 1977
To Whom It May Concern:
Amax Chemical is the third largest North American
producer and supplier of muriate of potash (potassium
chloride) which is the source of potassium in most fer-
tilizers. Potassium is one of three major nutrients
required to sustain plant life, and is essential to
human nutrition. It is a natural material found in
seawater and was accumulated by solar evaporation many
ages ago in Saskatchewan, New Mexico and a few other
places on earth. Potassium chloride is similar to table
salt and, in fact, is what doctors prescribe for low
salt diets in case of high blood pressure and related
ailments. In short, it is a common material used as
• food for humans and animals as well. as in fertilizers
used for growing food crops. Other materials used in
producing fertilizers, sources of nitrogen, potash,
magnesium, etc. needed to grow crops are equally harm-
less.
It is important to recognize that commercially
sold fertilizers, such as those produced by Howe, Inc.,
account for at least 40 of all food produced in the
United States. Without use of these fertilizers there
would be a lot less meat and potatoes on tables at
mealtime.
Rodger QC. Smith
Director of Marketing Development
RCS:gb
CITY OF BROOKLYN CENTER
STATE OF MINNESOTA., COUNTY OF HENNEPIN
WHEREAS, N? 3822 ��
5.00 first pump
Inc. Fee, $ ...... 3 0 . 0 ... each ... add ..........
..................... ............................................. ...........................
4821 Xerxes Ave x
. N. New ................ Renewal .....
............................................. ...........
...................................................
Brooklyn Center 535-1030
, W! 55429 Tephone .....................................
......................... .................................................................. le
has paid the sum of ...... Eight and no/100 .............................................. DOLLARS
, .............................. T .........................................
to the City of Brooklyn Center . as required by the Ordinances of said City and has complied with all the
requirements of said Ordinances necessary for obtaining this License:
NOW, THEREFORE, By order of the City Council, City of Brooklyn Center, and by virtue hereof,
Howe, Inc.
... is hereby licensed and authorized to
.. ......... Pp .........................
.pp�!:� service station.. .........................................
. .................. 19.71....
I for the period ........................ .......................... through ........... iy
subject to all conditions and provisions of said Ordinances.
Gi tinder my hand and the corporate seal of the City f P
....................
..... Mayor
P- M 1).e r ........... A. D. 19-7.6-- .. ............. ..................... � t.
day of .......... .....................
... . .. Clerk
"
NON -T ANS "ALE Attest:
OQU
•
BCA -04 -039
UJanuary 19761 APPLICATION FOR USER PERMIT PERMIT IWMBER
Under Minnesota Statute 299F.74 A 1
EPARTMENT OF PUBLIC SAFETY
B UREAU OF CRIMINAL APPREHENSION (Please read carefully and follow instructions) (Upon approval this becomes permit)
Form BCA -04 -039 must be filed in triplicate. Please make all entries of the form and any separate sheets legible on both the original and
the copies. Print with ball point pen or typewriter. Any separate sheets used should be prepared in triplicate and identified by your name
and address. Explanations on additional sheets should be numbered to match the items on the form that are being explained.
SECTION A
1. NAME (Individual, Corporation, Partnership, etc.) 2. SOCIAL SECURITY NUMBER 3. DATE OF BIRTH
Howe Incorporated
4. TELEPHONE NUMBER 5. DRIVERS LICENSE
535 -103
6. ADDRESS (RFD, Street No., City, County, State, Zip) 7. SHOW WHAT USE WILL BE MADE OF EXPLOSIVES
4 821 Xerxes Ave. N ❑ MINING Z9 GRI Y�1� TURE [1 ROAD
Brooklyn Center, Minnesota 551130 lr'egilizer Mfg.
❑ QUARRYING ❑ CONSTRUCTION
❑ SEISMOGRAPHIC RESEARCH
❑ OTHER LAWFUL ACTIVITY (specify)
8. EXPLOSIVE MATERIALS WILL BE STORED AT 9. DATE OF USE 10. EXPLOSIVE MATERIALS WILL BE USED AT:
(Show complete address, including county) (Show complete address, including county)
4821 Xerxes Ave. N. (Hennepin) 1821 Xerxes Ave. N. (Hennepin)
Booklyn Center, Minnesota Brookl Ce nter, Minnesota 5500
1. APPLICANT INTENDS TO USE: (List yuanhty) 12. APPLICANT INTENDS TO PURCHASE EXPLOSIVES FRONT:
M � t p � n (Give name and complete address)
XX HIGH EXPLOSIVES, CLASS A er Y WCN
*STING OR ELECTRIC BLASTING CAPS 125
❑ DETONATING CORD ❑ ANFO
❑ OTHER
uestions 1315 below refer to the person(s) listed on Item 1 above. If any answers are yes, give full details on a separate sheet. Number
ach explanation to match the item explained. YES NO
a. UNDER INDICTMENT OR INFORMATION IN ANY COURT FOR A FELONY OR GROSS MISDEMEANOR
INVOLVING MORAL TURPITUDE? X
b. ON PAROLE OR PROBATION FOR A FELONY OR GROSS MISDEMEANOR INVOLVING MORAL
TURPITUDE? X
1 3. IS ANY PERSON
NAMED IN ITEM 1 c. A FUGITIVE FROM JUSTICE? X
d. UNDER 18 YEARS OF AGE? X
e. A HABITUAL AND EXCESSIVE USER OF INTOXICATING LIQUORS? X
a. EVER BEEN ADDICTED TO ANY NARCOTIC, DEPRESSANT OR STIMULANT DRUG? X
b. BEEN CONVICTED IN ANY COURT WITHIN THE PAST YEAR OF A FELONY OR GROSS MISDE-
MEANOR INVOLVING MORAL TURPITUDE? X
HAS ANY PERSON
NAMED IN ITEM 1 c. EVER BEEN ADJUDICATED AS MENTALLY DEFICIENT OR BEEN COMMITTED TO ANY MENTAL
INSTITUTION? X
d. EVER BEEN CONFINED TO ANY HOSPITAL FOR TREATMENT AS AN "INEBRIATE PERSON "? X
BE COM- a. IS THE CORPORATION UNDER INDICTMENT OR INFORMATION IN ANY COURT FOR A FELONY OR
_ETED IF GROSS MISDEMEANOR? X
APPLICANT IS A b. HAS THE CORPORATION EVER BEEN CONVICTED IN ANY COURT WITHIN THE LAST YEAR OF A
CORPORATION FELONY OR GROSS MISDEMEANOR? X
SECTION B
This certification must be executed on the original and all copies of Form BCA -04 -039 by individual, partner, or in the cas .
corporation, association, etc., by an official duly authorized to sign for the applicant.
Under penalties of perjury and the penalties imposed by Minnesota Statute 609.48, I declare that I have examined this application,
and documents submitted in support thereof, and to the best of my knowledge and belief, they are true, correct, and complete.
I also certify that I am familiar with all published state laws and local ordinances relating to explosive materials for the location in which
I intend to do business or conduct storage of explosives and explosive devices:
APPLICANT'S SIGNATURE TITLE DATE
Vice ;resident 5-11t- 77
SECTION C
AUT RIZEDSIGNATURE DATE OF ISSUANCE
APPLICATION APPROVED, BECOMES
PERMIT / —
1;✓ ✓F.LL INFORMATION ON FORM POST OF DUTY FEE RECEIVED
BCA -04 -039 HAS BEEN VERIFIED AND
ISCORRECT
❑ APPLICATION DISAPPROVED
UPON APPROVAL, THIS PERMIT IS VALID FOR THE LOCATION FOR WHICH IT IS ISSUED (ITEM 10) FOR ONE Y
FROM DATE OF ISSUANCE.
NOTICE TO BUYER:
1. A user permit authorizes the holder to acquire and transport explosive materials within the State of Minnesota for use at the location
indicated in Item 10.
2. Explosive materials must be stored in conformance with requirements set forth in 260FR Part 181. It shall be unlawful for any person
to store any explosive material in a manner not in conformity with these regulations.
3. Any person who has explosives in his possession and who incurs a loss or theft of all or a portion thereof upon discovery of such loss
or theft immediately, and in no event longer than twenty -four (24) hours from the time of discovery, shall inform the office of the
County Sheriff or the local Police Department of the loss or theft, the amount of explosives missing and the approximate time of the
occurrence.
4. Prior to the storage of explosives, the applicant shall notify the appropriate local f ire o
INSTRUCTIONS:
1. Distribution of Form BCA -04 -039: Upon its approval, the first copy becomes the permit and will be returned to applicant to be posted
at the user location, the second copy will be retained by- the local authority, and the third copy is to be filed by the local official to
the Department of Public Safety, Bureau of Criminal Apprehension, 1246 University Avenue, St. Paul, Minnesota 55104.
Soo Line Railroad Company Soo Line Building
j` Box 530
!� Minneapolis, Minnesota 55440
(612) 332 -1261
• August 29, 1977
File: Hove, Inc. , TJpls. /CFR?
Mr. Bill Howe
Howe,I,Inc.
4821 Xerxes Avenue North
Minneapolis, Minnesota 55430
Pear Bill:
With reference to our recent phone conversaticn rebardin' carloads handled into
your plant within the last four years. In 1973, we handled 721 cars; in 1974,
583 cars; 1975, 396 cars and in 1976, 446 carloads.
We are very pleased with the number of cars we have handled to your plant. 'ale
hope we have not caused production delays to your plant due to our s:•ritching
operation. Vle are trying to do our s:vitching at the Hum - boldt Yard during the
daylight hours. ;9e do have an engine that goes to aork at 3:00 O'clock in the
afternoon doing work at the vrest end of the yard and at 7:00 or 8 :00 O'Clock
continues on to the CAF Roofing Corporation and mritches for several hours at
that plant, then continues on to cur Shoreham Yard. If I can be of further
assistance to you, Bill, do not hesitate to call.
Yours truly,
r Ples ix y ChH. P y
Assistant District Sales Manager
CHP /nma
I
t ,
MINNESOTA POLLUTION CONTROL ROL ACENICY
• 1935 W. County rietiad 2, / RossvtfiE0, Minnesota 55113
612 -296 -7373
May 12, 1975
Mr. William Howe
Howe, Incorporated
4821 Xerxes Ave. N.
Minneapolis, MN 55430
Dear Mr. Howe:
Enclosed are operating permits #155- 75 -0--3 and #155- 75 -0 -4 for
an acid storage tank and an ammonia fume scrubber.
The attached Exhibits B are incorporated into the permits.
• Sincerely,
THOMAS TOWNSEND
Engineering and Enforcement Section
Division of Air Quality
TT /mp
Enclosures:
Operating Permit #155- 75 -0 -3
Operating Permit #155- 75 -0 -4
Exhibit B (2)
cc: DAQ File #155
R. Hamilton
Permit File (RG)
AN EQUAL OPPORTUNITY EMPLOYER
MINNESOTA POLLUTION CONTROL AGENCY
• 1935 W. County Read 62, 1 Roseville, Minnesota 55113
c
612 -296 -7373
OPERATING PERMIT
for
Bulk Dty Inorganic Fertilizer Manufacturer
Air Pollution Control Equipment
and Production Equipment with
Potential Non - Permissible Emissions
HOWE, INCORPORATED
Brooklyn Center, MN
OPERATING PERMIT #155- 75 -0 -3
Pursuant to authorization by the Minnesota Pollution Control Agency and
in accordance with the provisions of Minnesota Statutes, Chapters 115
and 116, plans are approved & an Operating Permit is hereby issued to
Howe, Incorporated for air pollution control equipment to abate and
control emissions emanating from its bulk dry fertilizer plant loca-
ted at 4821. Xerxes Ave. N., Minneapolis, MN 55430.
The facility subject to this permit is a 30,000 gal. stainless steel
tank for the storage of superphosphoric acid. This tank will insure
an uninterrupted supply of superphosphoric acid to the ammoniation
granulation plant. Permittee's Operating Permit is issued on the basis
of information contained in Installation Permit Number 155- 74 -I -5 and
a field inspection of said abatement equipment on March 28, 1975. The
facilities are further described in a letter dated January 27, 1975.
This permit is contingent upon future effective performance of the air
pollution control equipment subject hereto, and compliance with the
general conditions attached hereto as Exhibit B and hereby incorpo-
rated into this permit.
DATED: May 12, 1975
EDWARD M. WIIK, P.E.
Director
EMW:TBT /mp Division of Air Quality
Enclosure: Exhibit B
• cc: DAQ File #155
R. Hamilton
Permit File (RG)
AN EQUAL OPPORTUNITY EMPLOYER
6. The Permittee shall allow the Agency, or any
• authorized employee or agent of the Agency, when authorized
by law and.upon presentation of proper credentials, to enter
upon the property of the Permittee for the purpose of obtaininE
information or examining records or conducting surveys or
.investigations pertaining to the operation of the emission
facility or control equipment covered by this Permit.
7. The Permittee shall, when requested by the Agency,
submit such information and reports which are relevant to
control of pollution regarding the operation of the emission .
facility or control equipment covered by this.Permit.
8. The Permittee shall notify the Agency immediately
of a breakdown of more than one hour duration of the control
equipment covered by this Permit and, if the breakdown causes
an increase in the emission of air contaminants, of the
breakdown of any process equipment included in the emission
facility covered by this Permit.
9. The Permittee shall notify the Agency at least
24 hours in advance of a shutdown of any control equipment
covered by this Permit and, if the shutdown would cause an
increase in the emission of a.j_r contaminants, of a shutdown
of any process equipment included in the emission facility
covered by this Permit.
10. This Permit shall expire on
(;not to exceed five ( 5 ) years from the date of thi ' Permit) .
2
EXI {I FIT
EMI EI T L
GENERAL CONDITIONS
• FOR OPERA ".PING PERMIT NO.
I. This Permit shall not release the Permittee
from any liability, penalty, or duty imposed by Minnesota or
federal statutes or regulations or local ordinances except the
obligation to obtain this Permit.
2. This Permit shall not prevent the future
adoption by the Agency of any pollution control regulations,
standards, or orders more stringent than those now in existence
or prevent the enforcement of such regulations, standards or
orders against the Permittee.
3• The Permittee shall operate the emission facility
or control equipment coverer[ by this Permit in accordance with
plans and specifications submitted to the Agency and referenced
in this Permit.
4. The Permittee shall not knowingly make any false
statement, representation or certification in any record,
report, plan, or other document required to be submitted to the
Agency under this Permit. The Permittee shall immmediately
upon discovery report to the Agency any errors in such records,
reports, plans, or other documents.
5• The Permittee shall allow the Agency, or any
authorized employee or agent of the Agency, when authorized
by law and upon the presentation of proper credentials, to
examine and copy any books, papers, records or memoranda
• pertaining to the operation of the emission facility or
control equipment covered by this Permit.
• 11. This Permit may not be assigned or transferred
by the Permittee without the approval of the Agency.
12. This Permit is subject also to any Special
Conditions contained in this Permit.
- 3 - cvu i ITT F
MINNESOTA P(,4 OT1C?P1 COWWROL AGENCY
1935 W. County [,Qi Rassveb', Minnesota 55113
612 - 2'96 -7373
OPERATING PERMIT
for
Bulk Dry Inorganic Fertilizer Manufacturer
Air Pollution Control Equipment
and Production Equipment with
Potential Non - Permissible Emissions
HOWE, INCORPORATED
Brooklyn Center, MN
OPERATING PERMIT #155- 75 -0 =4
Ammonia Fume Scrubber
Pursuant to authorization by the Minnesota Pollution Control Agency and
in accordance with the provisions of Minnesota Statutes, Chapters 115
and 116, plans are approved & an Operating Permit is hereby issued to
0 owe, Incorporated for air pollution control equipment to abate and
control emissions emanating from its bulk dry fertilizer plant located
at 4821 Xerxes Ave. N., Minneapolis, MN 55430. Permittee's produc-
tion equipment is an ammoniator- granulator, dryer, and cooler. Each
unit is followed by a primary cyclone dust collector.
The air pollution abatement facility subject to this permit is a stain-
less steel scrubber. The scrubber has two beds of Intalox saddles each
seven inches in depth #6or a total depth of 14 ") and a stainless steel
demister pad. Permittee's Operating Permit is issued on the basis of
information contained in Installation Permit Number 155 ?74 -I -4 and field
inspections of said abatement equipment on February 25, 1975 and March
28, 1975. The facilities are further described in a letter dated Janu-
ary 22, 1975.
This permit is contingent upon future effective performance of the air
pollution control equipment subject hereto, and compliance with the
general conditions attached hereto as Exhibit B and hereby incorpo-
rated into this permit.
DATED: May 12, 1975
EDWARD M. WIIK, P.E.
EMW :TBT /mp Director
Enclosure: Exhibit B Division of Air Quality
cc: DAQ File #155
R. Hamilton
Permit File (RG)
AN EQUAL OPPORTUNITY EMPLOYER
EXH I FIT E
GENERAL CONDITIONS
• FOR OPERATING PERMIT NO.
1. This Pt -rmit shall not release the Permittee
from any liability, penalty, or duty imposed by Minnesota or
federal statutes or regulations or local ordinances except the
obligation to obtain this Permit.
2. This Permit shall not prevent the future
adoption by the Agency of any pollution control regulations,
standards, or orders more stringent than those now in existence
or prevent the enforcement of such regulations, standards or
orders against the P(.,rmittee.
3. The Permittee shall operate the emission facility
or control equipment covered by phis Permit'in accordance with
• plans and specifications submitted to the Agency and referenced
in this Permit.
.
b. The Permittee shall not knowingly make any false
statement, representation or certification in any record,
report, plan, or other document required to be submitted to the
Agency under this Permit. The Permittee shall immmediately
I
upon discovery report to the Agency any errors in such records,
reports, plans, or other documents.
5. The Permittee shall allow the Agency, or any
authorized employee or agent of the Agency, when authorized
by law and upon the presentation of proper credentials, to
examine and copy any books, papers, records or memoranda
• pertaining to the operation of the emission facility or
control equipment covered by.this.Permit.
• 6. The Permittee shall.allow the Agency, or any
authorized employee or agent of the Agency, when authorized
by law'and upon presentation of proper credentials, to enter
upon the property of the Permittee for the purpose of obtaining
information or examining records or conducting surveys or
investigations pertaining to the operation of the emission
facility or control equipment covered by this Permit.
7. The Permittee shall, when requested by the Agency,
submit such information and reports which are relevant to
control of pollution regarding the operation of the emission
facility or control equipment covered by this Permit.
8. The Permittee shall notify the Agency immediately
• of a breakdown of more than one hour duration of the control
equipment covered by this Permit and, if the breakdown causes
an increase in the emission of air contaminants, of the
breakdown of any process equipment included in the emission
facility covered by this Permit.
9. The Permittee shall notify the Agency at least
24 hours in advance of a shutdown of any control equipment
covered by this Permit and, if the shutdown would cause an
increase in the emission of air contaminants, of a shutdown
of any process equipment included in the emission facility
covered by this Permit.
10. This Permit shall expire on
(not to exceed five (5) years from the date of thYs Permit).
- 2 -
r_vus ITT
• 11. This Permit may not be assigned or transferred
by the Permittee without the approval of the Agency.
12. This Permit is subject also to any Special
Conditions contained in this Permit.
I
I
I
--3- I F
TENNESSEE VALLEY AUTHORITY
National Fertil:i7.er Development Center
• Muscle Shoals, Alabama 35660
Se- otemper 1, 1977
Mr. Bill Howe, Vice President & Treasurer
Howe, Inc.
4821 Xerxes Ave. N
Minneapolis, Mff 54430
Dear Bill:
Recently you asked me to evaluate the steps you have taken over
the years to improve your facilities. Following is my evaluation.
We at TVA have tried to keep you informed of the latest techniques
and equipment for operati_n, your plant efficiently and with as
little discharge as possible. I believe that results of tests
by the Minnesota Air Pollution Authorities show that we have had
considerable success in this endeavor.
Also, you have been willing; to use new raw materials and operating
techniques, sometimes at considerable extra cost to you, when they
• showed evidence of reducing discharge from your plant. An indi-
cation of this is the interest of the industry at larg
_,e in your
operation. This is showr by their request last fall that you and
your son, Tom, present a paper at the Fertilizer Industry Round-
table in Atlanta, Georgia, the major technical meetin of the
fertilizer industry. After that meeting, I heard many comments
on the value of the information Tom presented and its contribution
to the knowledge of pollution control methods in the fertilizer
industry.
I have also been impressed by your restraint in adoptinE practices
which would improve your profit picture, but which might annoy
your neighbors. An example of this is your decision not to use
anhydrous ammonia as a nitrogen source. Anhydrous ammonia is the
most economical form of nitrogen available to the industry and,
as far as I am able to d termine, is used by every granulation
plant in the United Stat s except yours. Your decision not to use
this volatile substance as constantly put you in a bad competitive
position over the years.
As I mentioned in an earlier paragraph, you are constantly upgrading
your equipment. Two years ao you installed on your ammoniator
a venturi scrubber with 2'+ inches of water pressure drop. This
An Equal Opportunity Emplo✓er
• 2
Mr. Bill. Howe
Septemher 1, 1977
device is accepted in the fertilizer industry as the best
scrubbing device for remo ing aerosols and fumes from a gran-
ulation plant. I understand you have recently decided, at
considerable expense, to increase the pressure drop on this
device to 40 inches of water to improve the scrubbing efficiency
of your plant.
I believe that this indicates that you are keeping your facilities
equipped with the best equipment and using the best techniques
available. I am certain that you plan to continue this upgrading;
as new information becomes available and we at TVA plan to con-
tinue to assist you with this.
I am looking forward to working with you in the future, and to
seeing; you at the Roundtable meeting in Washington, D. C. next
month.
• Sincerely yours,
Hubert L. Balay
Chemical EnUineer
Process and Product Improv ment Section .
Division of Agricultural Development
•
-- OSHI NO. OSHI -1 rJO. CV
MINNESOTA DEPARTMENT OF LABOR AND INDUSTRY
r Occupational Safety and Health Division pJf+ (�'] -� `�
I I.
REGION
• 444 Lafayette Road
St. Paul, Mn. 55101
L J
r ------------------ - - - - --
TO: I *SEND PROGRESS REPORTS TO:
a. Mr. Bill ?iowe I.P.
! ?ewe Inc
3321 Xerx Ave. North I DEPARTMENT OF LA;:Oi;
Pipls. ?ITN 55/► 0 I OCCUPATION , c•.� , .. [ INDUSTRY.
444 LAr au t: _ .. �IH DIVISION
---- - - - - -- --------- - - - --� ST. PAUL, hliwIVE'_A0 5530,>n
Subject: Citation(s) for Alleged Occupational Safety and Health Violation(s)
• An inspection of a place of employi tent under your operation, ownership cr control has revealed conditions which we believe do not
comply with the provisions of the N innesota Occupational Safety and Health Act of 1973. The nature of such alleged violation(s) is
described in the enclosed citations with reference to applicable standards, rules, regulations and provisions of the said Act. These
conditions must be corrected on or 3efore the date shown on the right of each alleged violation therein. Also, you are hereby notified
whether or not penalty(ies) are proposed as a result of the cited violation(s).
The Act requires that a copy of the enclosed citation(s) and proposed penalty(ies) be prominently posted at or near each place a
violation referred to in the citation ccurred. It must be posted immediately upon receipt and must remain posted until ail violations
cited therein are corrected, or for 15 days, whichever period is longer. A sufficient number of copies of the attached citation(s) and
proposed penalty(ies) should be prepared to permit posting in accordance with the requirements of the Act. The Act provides for
penalties for violation of the posting equirements.
You have the right to contest any qr all parts of either the citation(s) or the proposed penalty(ies) or both before the Occupational.
Safety and Health Review Board, The Review Board is an independent quasi judicial agency with authority to issue decisions regarding
citation(s) or proposed penalty(ies). If you wish to contest, you must submit a letter to the Deputy Commissioner at the address
i shown above within 15 working days" after receipt of this certified mail notice. If you choose not to contest the citation and
proposed penalty(ies), they shall be deemed to be a final order of the Review Board and not subject to review by any court or agency.
1
If you require clarification concerning any results of the inspection (abatement dates, citations, penalties, etc.) please irect your
a correspondence to the Director of the Occupational Safety and Health Division. A request for such clarification cannot extend the 15
r • working day period allowed for filing a notice of contestation.
If an employer contests the citation, the abatement period specified therein does not begin to run until the date of the Board's final
order in the case PROVIDED the employer initiated his contest in good faith and not solely for delay or avoidance of penalties.
An employee or representative of a ployees may file a notice (letter) to contest the citation(s), the type of alleged violation(s), the
x' proposed penalty(ies), or die reason bleness of the time stated in the citation(s) for the abatement of the alleged violation(s).
r $
Alleged violations that are not contested shall be corrected within the abatement period specified in the citation. A followup
1 inspection may be made for the purpose of ascertaining that the employer has posted the citation(s) as required by the Act and
f corrected the alleged violations. Failure to correct an alleged violation within the abatement period may result in further proposed
penalties for each day the alleged violation has not been corrected.
s Correction of alleged violations whi h have an abatement period of 30 days or less shall be reported in writing to the Director no later
j than the latest abatement date (of 3 days or less) for all such violations. Reports of corrections should show specific corrective action
on each such alleged violation and the date of such action. On alleged violations having an abatement date of more than 30 days,a
written progress report shall be submitted each 30 days. The progress report should detail what has been done, what remains to be
done, and the time needed to fally abate each such violation. When the alleged violation is fully abated, the Director shall be so
advised.
The Act provides that whoever kno tingly gives false information is subject to a fine up to $10,000, imprisonment up to 6 months, or
both.
j If you wish additional information you may direct such request to the undersigned at the address listed above or the Area Office
R listed in the upper right -hand corner of this cover letter.
• Progress reports are to be sent to I he Area Office listed in the upper right -hand corner of this cover letter.
..Under the Minnesota Occupational Safety and Health Act of 1973, the term "Working Day" means Mondays .,.rough Fridays but
does not include Saturdays, Sundays, or State Holidays as defined in Minnesota Statutes Sec. 645 --0.
i, Quantity Ciution(s) Enclosed
Page, MINNESOTA DEPARTMENT OF LABOR AND INDUSTRY
• T
Nnnsrrious Occupational Safer and Health Division
t;3
7 1 —
Srrinus y it ��` _ZZ
' B • Director
Willful andlor 5.
Repeated
.
• � •1, Notitii uion of Proposed Penalty end Date 19 sad I -
0 V 0 No — . - �
JE- 1/76
-- P
f _
MINNESOTA DEPARTMENT CF LABOR AND INDUSTRY OSHI OSHD•1 N0. CY
Occupational Safety and Health Division
F1 1;SC )1 �3 77
Deputy Commissioner
• Department of Labor and Industry
444 Lafayette Road
1
St. Paul, Minnesota 55101
L
I TO:
1 2. Mr. iil
1 � ;?nw_, V.P. i 3.
Powe, Inc. i Date M ?V 16, 1977
4821 Xerxes : Ve. ^ *0•'`1' I 4 • 1 1
1 MPIs. Mrd 55 i Pa of
L------------------- - - - --j
NOTIFICATION OF PROPOSED PENALTY
j You are hereby notified of the propos d penalties for citations of Violations as indicated below. You have the right to contest any or all parts of either
the citation(s) or the proposed penalty(ies) or both before the Occupational Safety and Health Review Board. The Review Board is an independent
quasi - judicial agency with authority tc issue decisions regarding citation(s) and proposed penalty(ies). if you wish to contest, you must submit a letter
he Deputy Commissioner at the address shown above within 15 working days' after receipt of the certified mail notice regarding proposed
to t p y C g
P
enalty (ies). If you choose not to co test the citation and penalty(ies) as proposed, they shall be deemed to be a final order of the Review board and
shall not be subject to review by any court or agency.
Payment of all penalties shown is to be made by check or money order payable to the order of "Minnesota Department of Labor and Industry".
Payment of penalties should be remittc d to the Commissioner at the address shown above.
(M S. § 182.666), subdivision 7 of the Act states: "Fines imposed under this act shall be paid to the Commissioner for deposit in the general lurid and
may be recovered in a civil action in i he name of the department brought in the distract court of the county where the violation is alleged to have
occurred or the district court where th Commissioner has an office."
The law requires that a copy of this Proposed penalty shall be promptly posted at or near each place that at.. alleged violation referred to in [he cita-
tion occurred. The proposed penalty must remain posted until all alleged violations cited therein are corrected, or for 15 days, whichever period is
longer.
5. � �J �] .+I1
On the �L day of 19 , a citation(s) was issued to you in accordance with the provisions of (M.S. § 182.658)
of the Minnesota Occupational Safety a Health Act of 1973 hereinafter referred to as the Act. You were thus notified of certain alleged v:olations
jjh A t as oe if ed 'n thaatt CCa[io(s
elf AVt HJ B�' ISO h1VIV [n
ha rsuant to the provisions of (M.S. § 162.661), subdivision 1 of the Act, the penalty(ies) se[ forth below is /are
• being proposed, based on the citation s).
i
i 6. 7.
g j VIOLATIONS TC^T 0 - FRIOUS VIOLATIONS
6a. 6b. 6c. 7a. 7b. 7c.
Citation No. Item No. Proposed Penalty Citation No. Item No. Proposed Penalty
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Total Proposed Penalty for TTO*lE
All Alleged Violations $ —
eputy t net Datc '^7
OSHD -3
(1/76)
g
MINNESOTA DEPARTMENT OF LABOR AND INDUSTRY OSHI OSHD t NNO. Cv
Occupational Safer and Health Division
P Y ACC Ci] q '77
REGION
• l ATION 1. Deputy Commissioner
Department of Labor and industry
444 Lafayette Road
St. Paul, Minnesota 55101 J
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r 77 : ----- - - - - -- -------- - - ---1
i 1 2. Mr. Bill Howe, V P. I 3. Citation Number 1
Howe, Inc, I
t L821 Xerxes Aire. Prortb 1 4. Page 1 of 5. 1
j Mrils. ?2 59430 I
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6. TYPE OF ALLEGED VIOLATION(S): _ NONT —S 'RIOUS
- An inspection was made on 7. ! "V - 11 of a place of
employment located at: 8. tQJZL e ri °. a, Fr7 E. i = and described
as follows: 9. erl. 7 zer an
On the basis of the inspection it is alleged that you have violated the Minnesota Occupational Safety and Health Act of 1973 in the following
respects:
10. 11. 12. 13.
Item Standard. regulation Dare by which
number or section of the Act Description of alleged violation alleged violation
allegedly violated must be corrected
1 1.�3?.f).21�(•9)(l)S<
Fail-:0 to nrovine ward -)ver. exposed. B -bet` x/5/77
i) rrl DU'_1P:r' on fp in r!RriU�acturin,3 buildirlE,
1.�1C,275(�)( ?ti ailej. to hr 1 /Rt:i inch rr less cleara:t ^p b— 6/0;,/7
ween the 'cork rest F.nd t,1, tihpc. "- o bench F�_
Pr in thA lnaintemnc s?^op.
3 ].9].0.21.5(b)(C`) I Failed to properly ?d. -iust and /or instal]. r, 106177
ph °rFl protecting member (ton,3u l?aret.) on
• liench Grinder' in mintenan ^ ..P shop.
9
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ter`
The law requires that a copy of this citation shall be promptly posted at or near each plate that an aL'c Ertl t iolation
referred to in the citation occurred. The citation must remain posted until all alleged %iolations t itt•d [herein are
corrected, or for 15 days, whicil ever period is longer.
RIGHTS OF EMPLOYEES
Am employee or represen tat ive of employees who wishes to contest the citations. the t%pe of tiolation or the f
proposed penalty, or who believes that any period of time fixed in this citation for the correction of a %iolatiun i� S
unreasonable has the right to c ntest anv or all of these matters by submitting a letter to the Deputy Connnis�ioner 1
of the Department of Labor and Industry at the address shown above within 15 working days* of the issuance of
this citation.
"No employee shall be.di charged or in any way discriminated against because such employee has filed am j
• complaint or instituted or cause to be instituted any proceeding or inspection under or related to this \4-t or has
testified or is about to testify in any such proceeding or because of the exercise by such employ ee off behalf of
himself or others of any right afforded by this Act." Section S, subd. 9 of the Minnesota Occupational �,It'et� and
licalth Act of 1973.
'Under the Minnesota Occupational Safety and Health Act, the term "Working Day" means Mondays through Fridays but does not
include Saturdays, Sundays or Fe I Holida
14. Director's Signature Issuance Date 19 7-7.
(NOTICE: Additional Important Information on Reverse Side) Form OSHD-2 18751 t
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the required interval„ ___;,) a�
abated. _` 'O .,e :e:t -- a'_ i.e=s nave bey^ full
''!•� rtj.r Total I tee
A cover Puard has been made and installed on the feeders
In mam,t'ncttirinp huilAirp,. 5 -20-
We have rii ;rontinueri use of thr
this machine used i tftn g nth nAnce r And scrappe 5_ ?0 -
maintenance shop,
We have disr,ont.inued ' of the perch grinder and scrapped 5
this machine used ii the maintenance shop. �
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May 20, 1977