Perry Fertilizer Plant - Executive Summary |
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The Perry Distribution Plant is located in a rural setting on Highway 83 half way between McCook and Culbertson, Nebraska. The facility unloads from rail car and highway transport tankers, stores and eventually delivers anhydrous ammonia to be used as agricultural fertilizer in surrounding areas. Kugler Oil Company, the parent of the Perry 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 the manager of Perry and the majority of the employees are all 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 two 30,000 gallon (maximum capacity) pressure vessels for the storage of anhydrous ammonia. In addition as many as one hundred, 1000 gallon nurse tanks on wheeled running gear are stored at the location . Additionally as many as five rail cars all containing NH3 may be located on the rail siding at the Plant. 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 one the anhydrous ammonia rail cars whereby all the stored product could be released within ten minute period of time. The maximum amount of ammonia in a rail car would be 160,000 pounds producing a release rate of 16,000 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 cloud would travel before diluting to less than 200 parts per million in the atmosphere was EPAs OCA Guidance Program which predicted a distance of 6.9 miles from the point of release. Though not taken into consideration in this model, the Perry Plant is located on an east/west line between the two nearest population centers. Prevailing winds being northerly or southerly would allow the vapor cloud to dissipate harmlessly over mostly uninhabited farm land. In constructing this plan, many alternative scenarios were envisioned which could involve the accidental release of ammonia gas. The most probable of these unlikely scenarios might be the release of excess pressure due to natural solar heating of an overfilled anhydrous ammonia 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 thre e persons in the two residences located within the predicted 0.1 mile radius. 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 t his 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 Perry Plant, our employees are trained to inform the local population. Coordination has been effected with the Red Willow County Local Emergency Planning Committee (LEPC) whose agencies can provide for notification of those residents likely to be affected so that they may in turn evacuate the area. The Red Willow Western Rural Fire Department personnel make regular visits to the facility and are familiar with the premises and equipment. 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. Perry personnel are regularly trained on th e maintenance and operation of all facility 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 1987, there have been no reportable releases (greater than 100 pounds) from this facility, in fact no accidental releases of any amount of 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 releases of hazardous materials on any of the facility sites. The Company attributes their training program for employees and supervisors to be key to this flawless track record. 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 require ments. |