WT-11 David City Terminal - Executive Summary
KOCH FERTILIZER STORAGE & TERMINAL COMPANY |
David City Terminal
David City, Nebraska
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 un
acceptable, 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 David City 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 David City 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 pu
rpose of this Risk 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 David City 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 alarm
s, 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 1.5 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 our ammonia storage bullet being overfilled when ammonia is being delivered by pipeline into the facility. If such an incident occurred, three relief valves on top of the bullet would be activated during the filling process. These valves ensure that the entire bullet does not rupture and
only a minor controllable release results. The 2.5 inch diameter valves could release the ammonia at a rate of approximately 1.6 tons per minute. We have several active mitigation measures in place to greatly reduce the chance that such an event could ever occur. We measure the level of liquid ammonia in the bullet on a continuous basis. If this level becomes too high, the motor-operated valve on the inlet pipe to the bullet is automatically closed. If higher levels are then detected in the bullet, an additional reverse check valve will automatically be closed on the inlet pipe. High pressure in the ammonia storage bullet will similarly result in the check valve being closed. 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 Dav
id City Terminal, this would involve our 30,000 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 0.4 miles (approximately 2,100 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 to greatly reduce the chance t
hat 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 Butler County, thereby further reducing the possibility of any impact on the public.
The David City 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 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 tr
aining 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 failure.
These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it.
Five Year Accident History
No incident resulting in onsite or offsite impacts from a propane or an ammonia release has occurred at the David City 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 David City Terminal with the Dav
id City Fire Department. Also involved in emergency response would be the Butler County Sheriff and, as appropriate, the Butler County Hospital, Utility Company, Local Emergency Planning Committee, and the Nebraska State Highway Patrol. The David City 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 David City 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 Butler 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 Butler 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 ongoing basis.