Vernon Satellite Location - Executive Summary |
|
Vernon Satellite Plant The Vernon Anhydrous Ammonia facility is located on the west edge of the small town of Vernon, Colorado. The facility unloads from 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 Vernon 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 Kugler Retail Facility at Burlington, Colorado which satellites the Vernon facility and a majority of the employees are very active in the affairs of their local communities. Each of us is as interested in the health and welfare of our neighbors as we are of our own families. The facility has one 18, 000 gallon pressure vessel for the storage of Anhydrous Ammonia. In addition as many as ten 1000 gallon nurse tanks on wheeled r unning gear may be at the location during off season. No other chemicals are used or stored at this facility. The worst-case release scenario of this facilitys risk management plan is based on the hypothetical rupture of the largest anhydrous ammonia storage tank whereby all the stored product could be released within ten minute period of time. The entire contents would empty at release rate of 8,000 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 5.1 miles from the point of release. Though not taken into consideration in this model, the Vernon Plant is located directly west of the only city in the area. Prevailing winds being northerly or southerly would most likely 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 only 7 residents within the predicted 0.1 mile radius of exposure. 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 Vernon Plant, our employees are trained to inform the local population. Coordination has been effected with the Local Emergency Planning Committee (LEPC) whose agencies, primarily the Vernon Fire Department which is located nearby the Plant can provide for notification of those residents likely to be affected so that they may in turn evacuate the area. The Vernon Fire Department personnel are invited make regular visits to the facility to become 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 Colorado and Industry Standards, NASI 61, for construction of ammonia handling facilities. The Burlington personnel which service the Vernon plant are regularly trained on the 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 mai ntain an operation in consonance with the natural environment and the surrounding residents. At this site there have been no reportable releases (greater than 100 pounds) from the 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 release of hazardous materials of any kind. The Company attributes their training program for employees and supervisors to be key to this flawless track record. Kugler Oil company has met all SARA Title III and Tier Two and EPRCA 312 reporting requirements. |