Kehne Fertilizer Co. - Executive Summary |
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FACILITY POLICY: The owner and employee operating our facility are committed to the prevention of any accidental release of the hazardous chemical transported or stored on our location. In the event that an accidental release should occur, we are prepared to work with our Local Fire Company, Emergency Response Personnel, and other appropriate authorities deemed applicable depending on the specific incident, to best mitigate any release and to minimize the impact of the release to people and the environment. FACILITY INFORMATION: The primary activity of our company is NAICS code 49313 "establishments primarily engaged in farm product warehousing and storage facilities" that includes the receiving, storage, and reloading of Anhydrous Ammonia for delivery to farmers in our area. This product is subject to the EPA Risk Management Program and is the subject of this plan. Only the facility used for this product will be included in this report. Anhydrous Ammonia is received, stored, an d distributed for direct application to farm fields during the early spring and late fall months. During the balance of the year, inventories will be storage only, with little if any product transfer taking place. The maximum quantity stored has been listed earlier in the RMP and will not be disclosed in this summary. The maximum quantity handled at a given time would be the unloading of a semi-trailer vehicle. The facility is operated on an as needed basis with staff present only during the receiving and reloading of product for delivery. Total annual hours for these needs to not meet the 2,080 hour requirement to qualify as a full time employee on site, therefore item number 1.11 is Zero. Our facility has adequate lighting, and is inspected at various times day or night during use, and throughout the off season when not in use. WORST-CASE RELEASE SCENARIO: The worst-case release scenario would be the release of the total contents of our largest Anhydrous Ammonia tank, re leased as a gas over 10 minutes. The maximum quantity released has been identified earlier in this program and would effect some residential population. ALTERNATIVE RELEASE SCENARIO: As we have not had an actual release of Anhydrous Ammonia during the last 5-years at the site, we believe the most likely release would be caused by a break in a transfer hose. Transfer hoses are protected by manual and self closing excess flow valves so our alternative release scenario is based on the loss of contents from the largest hose used (off loading transportation equipment). The distance to the endpoint (point of dispersion to 200 ppm) is 0.06 miles (528 feet) based on EPAs RMP Comp guidance program. ACCIDENTAL RELEASE PROGRAM: For Anhydrous Ammonia, our accidental release program is based on guidelines found in the American National Standards Institute, Inc. (ANSI) standard K-61.1 Safety Requirements for the Storage and Handling of Anhydrous Ammonia"; and the U.S. Occupational Safety an d Health Administration (OSHA) standard 29CFR 1910.111 Storage and Handling of Anhydrous Ammonia. Additionally, we conduct annual employee training on the safe handling, transportation and distribution of Anhydrous Ammonia, and have installed safety equipment including, but not limited to: Excess flow valves, Emergency shut-off valves, and Lock outs to prevent tampering when the site is unattended. Finally, we maintain routine contact with our local fire department and emergency response personnel; and have provided and/or participated in safety training exercises on Anhydrous Ammonia. FIVE-YEAR ACCIDENT HISTORY: We have not had a release of Anhydrous Ammonia within the past five years that has caused any death, injuries, or significant property damage at the facility; nor to our knowledge have resulted in offside deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. EMERGENCY RESPONSE PROGRAM: This facility is included in the written Commu nity Emergency Response Plan as prepared by the Local Emergency Planning Committee (LEPC) and the Nebraska Emergency Management Agency (NEMA) (former Nebraska State Civil Defense Agency). We also include these materials in our own Emergency Action Plan in accordance with OSHA Standard 29CFR 1910.38. We have provided State and Local authorities all Community Right-to-Know information requested as well as that required under SARA Title III (EPCRA). Our written employee safety programs include pre-emergency planning and employee training in accordance with OSHA standards, and are offered for review at any time by our Local Emergency Planning Committee (LEPC) to ensure that they conform to the community plan. We actively encourage participation in our Anhydrous Ammonia training programs by the local fire department, local emergency response team, community planners, etc. that may be expected to respond to an incident at our site. PLANNED CHANGES TO IMPROVE SAFETY: Safety improvement i s an on-going process at our facility. Periodic evaluations are performed to assess the maintenance of safe conditions. There are no additional specific recommendations for implementation at this time. ADDITIONAL INFORMATION: For additional information, response to questions, facility tours, or comments, please contact: Harold Kehne at (402)-847-3355. |