Wood River Terminal - Executive Summary |
|
KOCH NITROGEN COMPANY Wood River Terminal East Alton, 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 unacceptable, by remedy ing 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 Wood River Terminal is one of several facilities operated by Koch Nitrogen 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) present at the Wood River 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 rail cars, trucks, and barges 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 Risk Manage ment 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 Wood River 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 shutdown, 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 2.5 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 a release of liquid ammonia during barge loading due to separation of the barge from the loading hose caused by rough water conditions on the river. We have several active mitigation measures in place to greatly reduce the chance that such an event could ever occur. These active mitigation measures include the following: 1) Koch personnel and barge company personnel are present at the barge loading cell throughout the loading operation to monitor and control the loading operations; 2) Koch personnel and barge company personnel present at the barge loading area can initiate immediate response actions such as activating the emergency shutdown or manually shutting off the pump. The presence of these active 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 Wood River Terminal, this would involve our 12,300 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 offsite 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 that 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 and an excess flow 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 va por 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 Madison County, thereby further reducing the possibility of any impact on the public. Prevention Program The Wood River Terminal has been operating under the strict guidelines of the Occupation Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1992. At the Wood River Terminal, we emphasize continual analysis of the potential hazards of our process, annual training of our employees, and on-going safety awareness. 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 installed a back-up generator to ensure both instrumentation and flares operate with minimal interruptions. 7 We have a connection to a second power grid to ensure both refrigeration systems and flares operate with minimal interruptions. 7 We require truck drivers to wear personal protective equipment during loading operations. 7 We provided emergency shutdown buttons at our central control room in Wichita to safely shutdown the entire terminal in the event of an emergency. 7 We provided emergency shutdown buttons at the barge loading cell to safely shutdown the barge loading system in the event of an emergency. This button can be activated by either the terminal personnel or the barge company personnel. These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it in 1992. Five Year Accident History No incident resulting in onsite or offsite impacts from a propane or an ammonia release has occurred at the Wood River 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 Wood River Terminal with the Wood River Fire Department, the Wood River Police Department, and the East Alton Police Department. Also involved in emergency response for the facility would be the Madison County Sheriff and, as appropriate, Alton Memorial Hospital, the Illinois State Patrol, th e Illinois Power Company, and the U.S. Coast Guard. The Wood River Terminal Manager is responsible for coordinating all emergency actions. A specific 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 Wood River 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 An alysis (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 Madison 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 Madison County Emergency Management Director for the late st information on emergency response for the county. We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis. |