ET-4 Trilla Terminal - Executive Summary |
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KOCH FERTILIZER STORAGE & TERMINAL COMPANY Trilla Terminal Mattoon, Illinois EXECUTIVE SUMMARY FOR THE RISK MANAGEMENT PLAN (RMPlan) Introduction and Policies Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public. Our KEEP management philosophy goals are achieved by the personal commitments of our employees and contractors, and by open communication with our employees, customers, neighbors, and with regulators. The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP. Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be unintentional and acknowledged as unaccepta ble, by remedying any shortcomings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by law. The Trilla Terminal is one of many facilities operated by KOCH Fertilizer Storage & Terminal Company (Koch) along a 2,500 mile pipeline supplying ammonia to the Midwest farming area where it is used as fertilizer. Anhydrous ammonia is the only toxic substance and propane is the only flammable substance regulated under the Risk Management Program (RMP) that are present at the Trilla Terminal. The terminal is classified as Program Level 3 under the regulation. At the terminal we receive anhydrous ammonia from a central pipeline and store it until it is loaded on trucks for distribution. In addition to ammonia, propane is stored and used at the terminal for the purpose of heating the refrigerated ammonia prior to loading into trucks and as a fuel source for the flare. The purpose of this R isk Management Plan (RMPlan) is to provide information about our operations at the terminal, our programs to prevent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the terminal. Worst Case and Alternative Release Scenarios As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for toxic chemicals would be the loss of all of the ammonia in our largest vessel within 10 minutes. In the case of the Trilla Terminal, this would involve our 30,000 ton refrigerated ammonia storage tank. Such a scenario is highly unlikely, however, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that ammonia vapors could travel, in this hypothetical case, would be greater than 25 miles from our facility. Although we have numerous controls to prevent such releases (high level alarms, emergency shutd own, and others) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this scenario. The alternative release scenario, characterized as a more likely scenario that could involve an offsite exposure to ammonia vapors, is calculated to reach 1.0 miles from the release point. This distance calculation is also based on the EPA OCA methods, which are known to overpredict the impact of any potential release from such a scenario. Once again, no credit for any controls or mitigation measures was taken into account when evaluating this alternative release scenario. We selected the alternative release scenario based on the piping at our loading station developing a 1" hole and releasing liquid ammonia. The 1-inch diameter hole could release the ammonia at a rate of approximately 1.6 tons per minute. We have mitigation measures in place to greatly reduce the chance that such an event could ever occur. For example, the tr uck driver as well as Koch personnel are present at the loading station to monitor and control the loading operations. Also, an emergency shutdown button is within arms reach and can be activated if any problems such as this proposed alternative release scenario were to occur. The presence of these mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur. Our worst case release scenario for flammables would be the loss of all of the propane in our largest vessel causing a vapor cloud explosion. In the case of the Trilla Terminal, this would involve our 18,225-gallon propane bullet. Using the EPA OCA methods, the distance that the resulting vapor cloud explosion could cause an overpressure of 1 psi would be approximately 0.3 miles (approximately 1,600 feet). An overpressure of 1 psi is EPAs threshold for measurable impacts. The alternative release scenario, characterized as a more likely scenario that would involve offsit e damage, is calculated to reach approximately 0.2 miles (approximately 1,050 feet) from the release point. This distance calculation is also based on the EPA OCA methods, which are known to overpredict the impact of any potential release from such a scenario. No credit for any controls or mitigation measures was taken into account when evaluating this scenario. We selected the alternative release scenario based on a release of propane due to a transfer hose failure during truck unloading. We have several active mitigation measures in place to greatly reduce the chance that such an event could ever occur. To prevent a liquid release of propane from the bullet, we have installed a back pressure check valve on the liquid fill pipe that will automatically shut off the line in case of a liquid hose rupture. Also, an excess flow valve is positioned on the vapor return line that will shut off the line to prevent a release of propane from the bullet in the event of a vapor hose rupture. The presence of these active mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur. We have discussed these potential ammonia and propane releases with our employees and with local emergency response officials in Coles County, thereby further reducing the possibility of any impact on the public. Prevention Program The Trilla Terminal has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1992. Our ongoing analysis of the potential hazards of our process, detailed training of our employees, and constant emphasis on safety have helped us avoid any serious accidents over the last 5 years. Part of this program has also involved identifying and taking steps to avoid potential accidental chemical releases. A few examples of the additional prevention features implemented at this facility include: 7 We require a brake lock system that prevents truck drivers from driving away before the transfer hose is properly disconnected. 7 We installed continuous pilots in our flares in order to ensure no interruption in the combustion of ammonia vapors, even during high winds. 7 We have a 5-minute air pack on top of the tank in case of emergencies when working on the tank. 7 We have a backup connection to a second power grid to ensure both refrigeration systems and flares operate with minimal interruptions. 7 We have ammonia detectors in our process area to ensure that an ammonia release is detected and terminated as soon as possible. 7 We provided truck drivers with personal protective equipment training annually to ensure personal safety. 7 During propane unloading, truck drivers are required to comply with the Department of Transportation Regulation that states that the driver must remain present within arms reach of a manually operated shut-off valve in order to take prompt action in the event of any transfer hose f ailure. These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it in 1990. Five Year Accident History No incident resulting in onsite or offsite impacts from a propane or an ammonia release has occurred at the Trilla Terminal within the last five years. Although we take pride in that record, we also place daily emphasis on our prevention and safety programs to ensure this record continues. Emergency Response Program We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the Trilla Terminal with the Trilla Fire Department. Also involved in emergency response would be the Coles County Sheriff and, as appropriate, the Sarah Bush Hospital, the Utility Company, the Local Emergency Planning Committee, and the Illinois State Highway Patrol. The Trilla Terminal Manager is responsible for coordinating all emergency actions. A specifi c Emergency Response Plan for the terminal is in place, and that plan has been coordinated with local officials, along with evacuation procedures, regular drilling, and training. Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Planned Changes to Improve Safety Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the Trilla Terminal. Some of the key components of the safety improvements we expect to achieve are as follows: 7 The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures. 7 The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards . 7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program. 7 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection. 7 An ongoing dialogue with the Coles County Emergency Management Director or his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In this way, we shall bolster our strong commitment to the safety of our workers and the community. We encourage all interested citizens or community organizations to contact the Coles County Emergency Management Director for the latest information on emergency response for the county. We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoi ng basis. |