Farmland Industries, Inc., Beatrice Nitrogen Plant - Executive Summary |
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Farmland Industries Beatrice Nitrogen Plant is located in southeastern Nebraska, about 8 miles northwest of Beatrice, Nebraska. The plant primarily manufactures anhydrous ammonia and urea-ammonium nitrate (UAN) that provide Farmlands half million producer-members with high-quality, cost effective nutrients for the crops they grow to feed families around the world. As a nitrogen fertilizer manufacturing operation, this facility is subject to the Environmental Protection Agencys Risk Management Program rules under the Clean Air Act Amendments of 1990. The Risk Management Program rules require for facilities handling threshold amounts of certain chemical substances to submit Risk Management Plans for the prevention of accidental releases of these substances. The plan requirements include submission of the risk management plan to include hazard assessments defining possible offsite impacts of certain regulated substance release scenarios, a five-year accident history, description of the facilities accidental release prevention program, and an emergency response program. The following is the Executive Summary of the Risk Management Plan for Farmland Industries, Inc., Beatrice Nitrogen Plant at Beatrice, Nebraska. Stationary Source and Regulated Substances The Beatrice Nitrogen Plant is a nitrogen fertilizer manufacturing facility consisting of a large scale natural gas feed ammonia production unit and an integrated urea-ammonium nitrate (UAN) production unit. These products are primarily used as agricultural fertilizers. Carbon dioxide production is also a segment of facility operations. Initial operation began in 1965. The original small UAN unit was replaced in 1969 with a larger plant, which was revamped and upgraded in 1998. The facility produces, handles, and stores large quantities of anhydrous ammonia in its operations. The ammonia unit uses natural gas, air, and water for the production of ammonia. Ammonia is used along with by product carb on dioxide to produce liquid urea in the UAN plant. Ammonia and air in the same plant are used to produce nitric acid that is subsequently neutralized with ammonia to produce ammonium nitrate. The liquid urea and ammonium nitrate are mixed forming the urea-ammonium nitrate solution product. Each of these production units along with the ammonia storage and handling constitute the processes covered by the EPA Risk Management Program rule. Regulated substances include the primary product of the plant, anhydrous ammonia, which is also the main feed stock for urea-ammonium nitrate production. In addition, flammable substances as a class: methane (natural gas), and hydrogen (produced as an intermediate in ammonia production), specifically are regulated under Risk Management. Finally, chlorine is also present in regulated threshold quantities on the site. It is used as a biological control agent in the cooling water systems associated with the production units. Accidental Release Prevention and Emergency Response Policy The management and employees of this facility are committed to the prevention of any accidental releases from this facility. It is this facilitys policy to eliminate significant accidental releases of any substance and, in particular, hazardous and regulated substances; and to minimize and eliminate to the extent possible even minor and inconsequential releases of any type. Prevention of accidental releases is critical to the safe operation of this plant, to the safety of its employees, and to the safety of the general public. To achieve its goals of accident and accidental release prevention, the facility is committed to the following: 7 A knowledgeable and highly trained and motivated employee group 7 A well designed facility that is maintained and operated in a superior manner 7 Improvements that enhance safety and accident prevention where appropriate 7 Excellence in safety programs and practices and a superior safety and acciden t record 7 Preparation and training for emergency response and mitigation The Beatrice Nitrogen Plant has had a written Emergency Response Plan in effect for many years and is committed to respond to and mitigate any accidental release to minimize the impact to employees, the community, and environment. The response plan is coordinated with the Local Emergency Response Committee and emergency response agencies and the plant has interacted with possible responding agencies for many years regarding the plan and activities at the plant. Employees are trained in the implementation of the plan and in possible response activities that could be required in the event of an emergency. Prevention Program The Beatrice Nitrogen Plant is subject to the OSHA Process Safety Management rule, 29CFR1910.119, and is a nitrogen fertilizer manufacturing facility. Therefore, under the EPA Risk Management Rule, the plant is a Program 3 facility with a Program 3 Prevention Program. The OSHA Process Sa fety Management/EPA Prevention Program consists of a set of facility management policies and procedures which promote and recognize process safety and the prevention of accidents in plants that handle, use, store, and process hazardous chemical materials. The procedures address all aspects of plant activities including training, maintenance, operating procedures, process reviews, critical information maintenance and updating, safe work practices, incident investigation, audit, and other activities in a manner to provide controls to prevent errors, failures, and inadvertent changes in a process that could result in accidents. The Beatrice Nitrogen Plant adheres to the requirements of Process Safety Management and has written policies and procedures addressing all aspects of Process Safety Management and EPA Prevention Programs. In all of its years of operation, the facility has addressed the elements of accident prevention included in these programs. The Prevention Program consists of several elements and policies, which are briefly outlined below. 7 Employee Participation - Employees are involved in all aspects of the program and are provided any information developed in the program. Employees participate in process reviews, assist with development of procedures, and all other aspects of the program. 7 Process Safety Information - All necessary process information and records are maintained including information on the hazards of the chemicals, process technology with safe operating limits, and equipment records and design requirements 7 Process Hazard Analysis - Employee teams to identify and correct any perceived hazards have conducted Process hazard analysis and review. These reviews are updated on a schedule or more often if changes indicate the necessity of additional review. 7 Operating Procedures - Operating procedures are in place for all aspects of operation including emergency operation and shutdown, operating limits and methods to correct or avoid deviations from limits, safety and health considerations of operations and the chemicals involved, and safety system operation and function. 7 Operating Training - All operators are trained initially in the process and its operating procedures and receive refresher training not less than every three years. In reality, operator training is a continual and ongoing process. Operator training includes on-the-job training with experienced operators and classroom type instruction. 7 Contractors - Contractor selection includes review of safety performance and programs. Contractors are oriented to known hazards in the facility, the emergency plan, and are required to adhere to facility safe work practice procedures. Contractor performance is periodically evaluated as necessary to assure work is completed in a safe and correct manner. 7 Pre-startup Safety Review - A safety review is conducted on any new facility and for any significant modification of the facility. This assures that construction and equipment is installed in accordance with design, all necessary procedures including safety procedures are in place, training is completed, and that hazard analysis or requirements of management of change are completed. 7 Mechanical Integrity - Procedures for inspection and testing and correction of equipment deficiencies are in place. A quality assurance procedures assures equipment, parts, materials, and installations are suitable for the applications intended. Maintenance employees are trained in the process hazards and in safety procedures applicable to their work. 7 Safe Work Practices - Procedures and policies for work permits and maintenance and operating actions are in place for accident prevention. 7 Management of Change - No changes are allowed in the process or procedures without review and authorization. Safety impacts, technical basis, required procedure modification, and training are all considered in the review. The procedure is to assure the safety of the change and to prevent unintended consequences as a result of change. 7 Incident Investigation - Any incident that results in a significant release or could have reasonably resulted in such a release is promptly investigated by a facility team. Findings of the investigation and recommendations for corrective action are documented, as is the resolution of the recommendations and corrective actions. 7 Emergency Planning and Response - The Process Safety Management/Prevention Program includes the facility Emergency Response Plan. 7 Compliance Audit - Compliance with the program is audited at least every three years to verify compliance with these procedures. Findings, if any, of the audit are documented and any deficiencies are corrected and documented. The audit is conducted by persons knowledgeable of the facility processes, but not directly connected with the facility. The facility is diligent in adhering to and maintaining its Process Safety/Prevention Program. Emergency Response Plan The Beatrice Nitrogen Plant has a written Emergency Response Program as required by the Risk Management Plan rule and other Environmental Protection Agency and OSHA rules. This Plan is coordinated with the local community response plan and is available to those responding agencies. Emergency planning and Community Right-To-Know information as required under SARA Title III has been provided to the State Emergency Response Commission, Local Emergency Planning Committee, an d other appropriate agencies such as the local fire department. The facility participates with the Local Emergency Planning Committee and interacts with various local agencies in its emergency planning such as local fire departments; law enforcement agencies such as the police, highway patrol, and sheriffs office; and hospitals. Employees receive annual training in the response plan and also receive various safety training, both in general, and in the competencies relative to their required roles in the plan. Periodically the plan is practiced in a tabletop, classroom type setting. 5-Year Accident History The Risk Management rule requires inclusion of the five-year accident history of the facility for all accidental releases that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. The Beatrice Nitrogen Plant has had no qualifying accidents in the past five years. Synopsis of Worst and Alternate Case Release Scenarios The Risk Management Plan rule requires a hazard analysis for worst case and alternate case accidental release scenarios for regulated substances present in threshold quantities at the site. For this facility, the regulated substances include anhydrous ammonia and chlorine as regulated toxics, and flammables as a class, which include methane and hydrogen. The rule requires an analysis of the worst case toxic as that scenario affecting the greatest distance and a worst case flammable accident as a vapor cloud explosion. Alternate scenarios, which are more reasonably likely events, for each regulated toxic and flammables in general, must also be presented. Worst Case Toxic Release-Anhydrous Ammonia Considering the seasonal nature of fertilizer use and application in agriculture, large quantities of the ammonia produced at this facility must be stored until needed by the ultimate consumer. The RMP rule requires that the largest amount in a single vessel be considered the release quantity for the worst case event unless smaller quantities handled at different conditions result in a greater distance to the regulated endpoint of consideration. This is a requirement of the rule regardless of whether the event is likely, or, could even reasonably occur. For this facility, the largest single quantity of anhydrous ammonia is held in the atmospheric storage tanks, each of which contains 33,000 tons. However, the worst release pertains to the 200-ton anhydrous ammonia high-pressure non-diked bullet tank. The worst case release assumes, as required by the rule, that this entire amount is released as a result of a catastrophic failure of a single tank. A publicly available model (DEGADIS) which is known to provide reasonable estimates of concentrations and distances associated with release events modeled this unlikely event. Details of the results of this modeling are provided elsewhere in the Risk M anagement Plan submittal. To assure that the event indicated above was, in fact, the worst case as the rule defines it; failure of the other on-site ammonia storage tanks, were also modeled. In addition, a worst case failure of chlorine containers was similarly modeled. Neither of these resulted in a distance greater than the circumstance noted above. It should be emphasized that the possibility of such an event as described by the worst case is so low as to be non-existent. Analysis of this unlikely scenario was completed as required by the rule. Facility maintenance and inspection programs address the integrity of process and storage vessels, and preclude such massive and improbable failures. Worst Case - Flammable As the rule requires, the largest quantity flammable release and a subsequent vapor cloud explosion must be analyzed as the worst case for these substances. In this facility, a failure releasing the entire contents of the ammonia synthesis loop constitutes the larg est flammable release. This quantity is assumed to result in a vapor cloud explosion with impact distance determined by the EPA Offsite Consequence Analysis Look up Tables. Although large volumes of flammable gases are handled daily by the plant, actual in-process inventory is relatively small, considering the quantity of inert gases and steam mixed with the flammable gases. Consequently, impact distance is relatively limited as a result. Alternate Case Toxics Ammonia More reasonable and likely release events tend to concentrate in areas where the ammonia product is handled such as in the loading and other transport activities. Significantly lower quantities are involved, various shutdown safeguards are present as they are throughout the plant, and operator intervention all tend to mitigate and limit the consequences of failures. Such events can include failure of smaller valves, lines, and hoses. The alternate release scenario, modeled with the DEGADIS model for this facilit y is the overpressure of the loading surge tank with a 10-minute release. Modeled impact distance is substantially lower for more reasonable, but not necessarily likely, release events. Chlorine Chlorine is used at several locations in this plant as a biocide agent for cooling water systems, much as it is also used in swimming pools. It is used as a gas from one ton chlorine cylinders through an injection system to the circulating cooling water. The alternate release scenario assumed is failure of the connecting tubing from the cylinder and release of gaseous chlorine. This release was also modeled using the DEGADIS dispersion model. Flammables Large volumes of flammable gases are handled throughout the plant, even though actual physical inventory is relatively low. More likely flammable release events include failures of smaller pipes and lines in comparison to the large release contemplated in the worst case analysis. More reasonable and likely events result in minimal impac t distances. The alternate scenario assumed a vapor cloud explosion as a result of a pressure relief valve in the ammonia synthesis loop lifting for a duration of 4 minutes. The impact distance of this event utilized the EPA Offsite Consequence Analysis Look Up Tables. Planned Changes for Safety Improvements Safety improvements are a continual and ongoing process at the plant, which is facilitated by the Prevention Program/Process Safety Management Program. Formal process hazard analysis is conducted at least every five years, but review is constant through management of change procedures, operator training, incident investigation, and mechanical integrity programs. As a result, changes relevant to safety occur continuously, as needs are identified through these procedures and policies. |