Culbertson Dealer Fertilize (CDF) and Retail Plant - Executive Summary |
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Culbertson Dealer Fertilizer and Retail Distribution Plant The Culbertson Plant is located in a rural setting on the edge of the corporate limits of Culbertson, Nebraska. The facility converts and blends raw feed stocks to produce a variety of liquid products to be used as agricultural fertilizer in surrounding areas. Kugler Oil Company, the parent of the Culbertson Plant is a family owned corporation located in McCook, Nebraska. The owners live in McCook, surrounded by friends and neighbors who are also their customers. The principal officers of the parent company as well as nearly all the employees at the Culbertson location are very active in the affairs of their local communities and are as interested in the health and welfare of their neighbors as they are of their own families. The facility has six large pressure vessels for the storage of Anhydrous Ammonia. In addition as many as ten, 1000 gallon nurse tanks on wheeled running gear are stored at the location. The various g rades of fertilizers plus all the other chemicals used and stored at this facility are not considered hazardous or are stored below the threshold amounts to be considered under Part 68 of the Risk Management Program. The worst-case release scenario of this facilitys risk management plan is based on the hypothetical rupture of the largest anhydrous ammonia bulk tank whereby all the stored product could be released within a ten minute period of time. The maximum amount of ammonia would be less than 150,000 pounds producing a release rate of 15000 pounds of liquid per minute. Liquid anhydrous ammonia released to any conceivable atmospheric condition existing at this site would immediately turn to vapor which is lighter than air and would consequently rise into the atmosphere out of harms way. One is to be reminded that anhydrous ammonia is by weight 82% nitrogen and the atmosphere also consists of 80% inert nitrogen gas. The model chosen to determine how far the ammonia gas c loud would travel before diluting to less than 200 parts per million in the atmosphere was EPAs OCA Guidance Program which predicted a distance of 4.4 miles from the point of release. Though not taken into consideration in this model, the Culbertson facility is located east of the residential areas of the village of Culbertson. Prevailing winds being northerly or southerly in this area, the vapor cloud would dissipate harmlessly over mostly uninhabited farm land. The plant being located adjacent to an uninhabited forested area would further cause the vapor cloud to be rapidly disbursed into the atmosphere. This facility also stores a fairly large amount of propane gas which is used to enhance the manufacturing and blending process. Were the large propane storage tank to rupture the liquid contents would rapidly convert to vapor and then disperse into the atmosphere. In the very unlikely event that that vapor reached an ignition source the resulting explosion could produce ov er pressure of 1 psi out to a maximum of 0.4 miles. In constructing this plan, many alternative scenarios were envisioned which could involve the accidental release of ammonia or propane gas. The most probable of these unlikely scenarios might be the release of excess pressure due to natural solar heating of an overfilled storage tank. With the release of 100 pounds of liquid material over a ten minute period, the maximum predicted travel of the resulting vapor cloud would only involve about twelve persons residing within the predicted 0.1 mile radius in the case of either toxic or flammable gas. The Kugler Oil Company has always been very pro-active in meeting accepted industry standards for storage and handling of the various chemicals with which they deal. Safety is of paramount concern and to that end they hire an internal Safety Director, provide for a Safety Committee that meets regularly and in addition contract with an outside firm for safety overview and guidance. Part of the Management Directive for the Company safety program states that It is the intent of management that full implementation of the safety program will benefit this facility, and as such it is a high priority of the facility. The benefits will include preventing accidents, reducing overall operating costs by reducing down time, repair costs, time and costs spent in training new employees, reducing workers compensation claims costs, and increasing productivity through a better trained and motivated workforce. To this end, it is the responsibility of management to provide a workplace free of hazards.... By extension the safety of the community surrounding our facilities is of as much concern as for our employees as ourselves. In the unlikely scenario where an ammonia vapor cloud would leave the premises of the Culbertson Plant, our employees are trained to inform the local population. Coordination has been effected with the Hitchcock County Local Emergency Planning Committe e (LEPC) whose agencies can provide for notification of those residents likely to be affected so that they may in turn evacuate the area. The Culbertson Volunteer Fire Department personnel make regular visits to the facility to become familiar with the premises and equipment so that their response to any emergence situation can be appropriately handled. The Kugler Company at this and all similar locations requires that all materials and procedures meet the State of Nebraska and Industry Standards, NASI 61, for construction of ammonia handling facilities and NASI 58 standards for LP gas storage and handling. Culbertson personnel are regularly trained on the maintenance and operation of all the facilitys equipment. A systematic program of preventative maintenance is in effect. Our goal is to be a good neighbor and maintain an operation in consonance with the natural environment and the surrounding residents. Since the time of its acquisition in the early sixtys, there have been no reportable releases (greater than 100 pounds) from this facility, in fact no accidental releases of toxic or flammable gas of any amount have occurred. It is to be noted that in the history of the Kugler Company ownership of this and similar facilities there has been no reportable release of hazardous materials of any kind on site at any facility. The Company attributes their training program of employees and supervisors to be key to this flawless record. Access to this plant is funneled through a single entrance which passes around the administrative building. The storage tanks are in plain sight of employees at this facility and are visually monitored to prevent any unauthorized access to the equipment. Kugler Oil company has met all SARA Title III and Tier Two and EPRCA 312 reporting requirements. |