Farmland Industries-Lawrence Nitrogen Plant - Executive Summary |
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Risk Management Plan Executive Summary Farmland Industries, Inc. Lawrence Nitrogen Plant Farmland Industries, Inc. operates a nitrogen fertilizer manufacturing facility at 1608 North 1400 Road; Lawrence, Kansas. The facility is located on 640 acres in eastern Kansas, midway between Topeka and Kansas City. As a nitrogen fertilizer manufacturing facility, producing anhydrous ammonia and other fertilizer products utilizing ammonia as a feed stock provides Farmlands half million producer-members with high-quality, cost effective nutrients for the crops they grow to feed families around the world. Facility Snapshot The Lawrence facility, in production for nearly 45 years, produces more than two million tons of product annually. The facility participated in EPAs 33/50 emission reduction program with other area industries. Farmland patented air emission reduction process for ammonia and methanol plants that was developed here at the Lawrence facility. The Lawrence facility is cu rrently working on a joint project with EPA and the Army called Project Safeguard. Impact on the community *Farmland employs 215 Kansas and Missouri residents at a combined annual salary of approximately $11.5 million dollars. *Farmland supports Lawrence and the state of Kansas with nearly $900,000 in state and local taxes annually. *More than $5 million dollars is spent locally on electricity, water and miscellaneous purchases for the facility annually. *Natural Gas is an integral part of ammonia production and the facility spends about $43 million dollars annually on the natural gas it uses for processing and fuel. *Farmland sponsors a Community Advisory Panel and has sponsored many area events such as: Household Hazardous Waste Clean-up; Lawrence Community Clean-up; Clinton Lake Clean-up; and Corporate Cup. In addition, Farmland financially supports the United Way, Junior Achievement and participates in a business/education partnership with Kennedy Elementary School. Employee Snapshot Farmland employees are very involved in community activities. Many facility employees are active and participate in many public and community groups and charities including United Way, Junior Achievement, the Rotary Club, Lawrence Chamber of Commerce and the Kansas University Natural History Museum. In addition, plant personnel are active with the Local Emergency Planning Committee. Farmland employees recognize that community involvement and volunteerism is the most effective way to improve the communities in which they live. Pollution Prevention Policy Farmland Industries Inc., is committed to protecting the environment and preserving our natural resources for future generations. We pledge to eliminate or reduce our use of toxic substances and to minimize our use of energy and the generation of all wastes to the extent technically and economically feasible. We strive to prevent the generation of pollution at the source, but, where that cannot be achieved, we are committed t o environmentally sound methods of recycling, treatment and disposal. By preventing pollution at the source, we strive to achieve cost savings, increase operational efficiencies, improve the quality of our products and services, maintain a safe and healthful workplace and improve the environment. RISK MANAGEMENT PROGRAM This facility is subject to the Environmental Protection Agencies 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.; Lawrence Nitrogen Plant at Lawrence, Kansas. Stationary Source and Regulated Substances The Lawrence Nitrogen Plant is a nitrogen fertilizer manufacturing facility consisting of a large scale, natural gas feed ammonia production unit, two urea production units, two nitric acid plants, a nitric acid neutralization unit to produce ammonium nitrate, and an aqua ammonia production unit. The ammonium nitrate produced is mixed with the liquid urea produced to result in a final urea-ammonium nitrate solution product. These products are primarily used as agricultural fertilizers. Although initial construction and operation of the Lawrence facility was in 1954, numerous changes, additions, and improvements have resulted in the facilities and final products as noted above. The existing ammonia unit was completed in 1972 and replaced the original 1954 ammonia facility. The facility produces, handl es, and stores large quantities of anhydrous ammonia in its operations. The ammonia units use natural gas, air, and water for the production of ammonia. Ammonia is used along with by product carbon dioxide to produce liquid urea. Nitric acid is produced using ammonia and air and is subsequently neutralized with ammonia to produce ammonium nitrate. The liquid urea and ammonium nitrate are mixed forming the urea-ammonium nitrate solution product. A limited amount of ammonia is combined with water to produce a 25% aqua ammonia product. Each of these production units along with product ammonia storage and handling constitute the processes covered by the EPA Risk Management Program rule. Regulated substances include anhydrous ammonia and aqua ammonia. In addition, flammable substances as a class, and 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 thr eshold 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 community and the environment. 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 su perior manner 7 Improvements that enhance safety and accident prevention where appropriate 7 Excellence in safety programs and practices and a superior safety and accident record 7 Preparation and training for emergency response and mitigation The Lawrence 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 Lawrence Nitrogen Plant is subject to the OSHA Process Safety Management rule, 29CFR1910.119, and is a nitrogen fert ilizer 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 Safety Management/EPA Prevention Program consists of a set of facility management policies and procedures which promotes and recognizes 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 Lawrence 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 Preventio n Programs. 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 ParticipationEmployees are involved in all aspects of the program and are provided any information developed in the program. Employees participate in process reviews, development of procedures, and 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--Process hazard analyses and reviews have been conducted by employee teams to identify and correct any perceived hazards. These reviews are updated on a regular 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 TrainingAll 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 ContractorsContractor 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 Rev iewA safety review is conducted on any new facility and for any significant modification of the facility to assure 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 IntegrityProcedures for inspection and testing and correction of equipment deficiencies are in place. A quality assurance procedure 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 PracticesProcedures and policies for work permits and maintenance and operating actions are in place for accident prevention. 7 Management of ChangeNo changes are allowed in the process or procedures without review and authorization. Safety impacts, technical basis, r equired 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 InvestigationAny incident which 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 are the resolution of the recommendations and corrective actions. 7 Emergency Planning and ResponseThe Process Safety Management/Prevention Program includes the facility Emergency Response Plan. 7 Compliance AuditCompliance 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 fac ility. The facility is diligent in adhering to and maintaining its Process Safety/Prevention Program. Emergency Response Plan The Lawrence 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, and other appropriate agencies such as the local fire department. The facility is an active participant in 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 table top, classroom type setting, and it also is drilled in mock emergencies including participation by outside responding agencies. 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 Lawrence Nitrogen Plant has had nine unintentional releases resulting in employee injury, in the past five years involving regulated substances. All of these accidents have resulted in injuries to plant employees requiring medical treatment. In general, the injuries were burns from either flammables, aqua ammonia, or anhydrous ammonia. In only one instance, was the accidental release of a quantity sufficient to require reporting of the release under other regulations. On another occasion there was an incident that resulted in an off-site consequence when a nearby business voluntarily evacuated its building. Investigation of the building found the ammonia concentration to be less than 10 ppm. Details of these accidents are provided elsewhere in this Risk Management submittal. 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, aqua ammonia, and chlorine as regulated toxics, and flammables as a class which include methane and hydrogen. Worse case analysis were done for all three toxics. The ammonia case was found to have the greatest distance to the endpoint. Th e 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 Ammonia is a colorless gas with a strong pungent odor, and is one of the most widely used industrial chemicals. It is prepared industrially from natural gas, steam and air. Some of this ammonia is chilled to a liquid for direct injection into croplands as a fertilizer which conditions the soil to produce higher yields and better quality crops. A large amount of industrial ammonia is reacted with other compounds to produce urea, ammonium nitrate, and urea/ammonium solution fertilizers. More than 80 percent of manufactured ammonia is used as fertilizer. Because of the seasonal nature of fertilizer use and application in agriculture, large quant ities 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 two diked atmospheric storage tanks. Each tank holds 7500 tons. The worst case release assumes, as required by the rule, that this entire amount is released as a result of a catastrophic failure of one tank. This unlikely event was modeled by a publicly available model (DEGADIS) which is known to provide reasonable estimates of concentrations and distances associated with release events. Details of the results of this modeling are provide d in the Risk Management Plan Submittal. This scenario does have an off-site impact. This distance does take into account the passive mitigation of the earthen dike that exist around the ammonia storage tank thus reducing the release rate to 52.25 kg/s. These storage tanks are inspected on a regular frequency as part of our mechanical integrity program. To assure that the event indicated above was, in fact, the worst case as the rule defines it; failure of ammonia storage present at the site where ammonia is stored at higher pressure, but much lower quantities was also modeled. In addition, a worst case failure of a chlorine cylinder was similarly modeled. Also, the failure of one of the aqua ammonia storage tanks was analyzed under worse case conditions. 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. Many identical a nd similar tanks are in existence all over the world and have been in service for many years. We are not aware of any such failure of these tanks or even failures of a lesser nature that would allow accidental releases of smaller quantities of ammonia. Analysis of this scenario is required by the rule, and, as such, was completed. Facility maintenance and inspection programs address the integrity of process and storage vessels, including these, and largely preclude such massive and unlikely 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 conversion loop constitutes the largest flammable release. This quantity is assumed to result in a vapor cloud explosion with impact distance determined by the EPA Offsite Consequence Analysis Guidance document (Equation C-1). Details of the results of this modeling are provided in the Risk Management Plan Submittal. The only receptor this reaches is the facility visitor parking lot which is accessible to the public. Although large volumes of flammable gases are handled daily by the plant, actual in-process inventory is relatively small especially considering the quantity of inert gases and steam mixed with the flammable gases. Impact distance is relatively limited as a result, but it does have off-site impact. Alternate Case Toxics Ammonia More reasonably likely release events tend to concentrate in areas where the ammonia product is handled such as loading and other transport activities. Significantly lower quantities are involved, various shutdown safeguards are present as they are through out 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 usi ng DEGADIS, for this facility is the failure of a 4 inch loading hose that requires 10 minutes to secure and stop the flow. Details of the results of this modeling are provided in the Risk Management Plan Submittal. The 10 minute time frame is longer than what we feel would actually be required, but we used 10 minutes in an attempt to be conservative. Modeled impact distance is substantially lower for this more reasonable, but not necessarily likely, release events. This scenario will have an off-site impact. Aqua Ammonia Aqua Ammonia is another nitrogen-based fertilizer made by combining ammonia with water. Our product contains 25 percent ammonia and is either directly applied or used to manufacture phosphate fertilizers. Aqua Ammonia is also known as ammonia water, ammonium hydroxide and household ammonia. It is a colorless liquid with a strong characteristic odor. The alternate release scenario, modeled using DEGADIS, for this facility is the failure of a 4 inch loading hose . Details of the results of this modeling are provided in the Risk Management Plan Submittal. This scenario will have an off-site impact. Chlorine Chlorine is used at several locations in this plant as a biocidal 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 0.5 inch connecting tubing from the cylinder resulting in the release of gaseous chlorine. This release was modeled using the DEGADIS dispersion program. Details of the results of this modeling are provided in the Risk Management Plan Submittal. This scenario will have an off-site impact. Flammables Large volumes of flammable gases are handled throughout the plant, even though actual physical inventory is relatively low especially considering the quantity of inert gases and steam mixed with the flammable gases. More lik ely flammable release events include failures of smaller pipes and lines in comparison to the large release contemplated in the worst case analysis. The alternate release scenario chosen was to have an event that resulted in the relief valve on the discharge of the 103-J synthesis relieving gas for four minutes and this quantity is assumed to result in a vapor cloud explosion with impact distance determined by the EPA Offsite Consequence Analysis Guidance document (Equation C-1). Details of the results of this modeling are provided in the Risk Management Plan Submittal. This type of event is not likely to occur, but since the worse case scenario reached a receptor the regulations require that the alternate case reaches a public receptor thus this is a very conservative scenario. Most more reasonable and likely events result in minimal impact distances. Planned Changes for Safety Improvements Safety improvements are a continual and ongoing process at the facility which is facilitate d 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. |