Farmland Industries - Coffeyville Nitrogen Plant - Executive Summary |
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Risk Management Plan Executive Summary Farmland Industries, Inc. Coffeyville Nitrogen Plant Introduction Farmland's Coffeyville Nitrogen Plant is located on 72 acres at the northeast corner of Coffeyville in Montgomery county Kansas. The plant primarily manufactures anhydrous ammonia and urea-ammonium nitrate (UAN) solutions that provide Farmland's half million producer-members with affordable high quality nutrients for the crops they grow to feed families around the world. As a nitrogen fertilizer-manufacturing complex, 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 possi ble 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 the Coffeyville Nitrogen Plant. Facility Overview The Coffeyville facility is a new nitrogen fertilizer-manufacturing complex scheduled to start production in January 2000. The complex will produce for market approximately 550,000 tons of UAN and 180,000 tons of anhydrous ammonia annually for use as agricultural fertilizers. The design of the facility incorporates state-of-art safety and environmental controls for the protection of the employees and the surrounding community. Coffeyville Nitrogen has assembled a staff of knowledgeable personnel to provide the necessary leadership and skills to operate the fertilizer complex in a safe and economical manner. The facility consists of an air separation unit, a ga sification unit, an ammonia synthesis unit, and an UAN unit. The air separation unit, while located on our site, is independently owned and operated by BOC Gases. The air separation unit makes high purity oxygen and nitrogen for use in the gasification unit. In addition, BOC will market these gases along with argon to off-site customers. The gasification unit produces hydrogen gas using the Texaco Hydrogen Generation Process. The gasifier produces raw hydrogen and carbon oxides by the partial oxidation of petroleum coke with oxygen in the presence of water. The petroleum coke will be provided primarily by the neighboring refinery, the Cooperative Refinery LLC, and supplemented with coke from other locations. The hydrogen is purified by shift conversion of carbon monoxide to carbon dioxide, the removal of hydrogen sulfide and carbon dioxide, and pressure swing absorption of trace contaminants. To ensure the reliable operation of the gasification unit, Coffeyville Nitrogen has employed Texaco Syngas, Inc. to startup and operate the unit for the first five years of service. The ammonia synthesis unit reacts the hydrogen from the gasification unit with nitrogen from the air separation unit to make anhydrous ammonia. The ammonia is either sold for direct fertilizer applications or upgraded for UAN solutions. Ammonia along with by-product carbon dioxide from the gasification unit is used to produce liquid urea in the UAN plant. Ammonia and air in the same plant are used to produce weak nitric acid solution 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. Ammonia and UAN solutions can be shipped to the farmers by both truck and railcars. On-site storage tanks have been constructed to safely hold the ammonia and UAN products until the farmers are ready to apply the fertilizers. Impact on the community Coffeyville Nitrogen employs 103 Kansas and Oklahoma residents at a combined annual salary of $6.9 million dollars. Coffeyville Nitrogen supports Coffeyville and the state of Kansas with $220,000 in state and local taxes annually. Approximately $17.5 million dollars is spent locally on electricity, water, and natural gas for the facility annually. Employee snapshot Coffeyville Nitrogen employees are involved in many community activities. Many facility employees are active and participate in public and community groups such as the Chamber of Commerce and Rotary International. Employees are also active in charity work including United Way, the Red Cross blood drive and March of Dimes. In addition, staff members are active with the Local Emergency Planning Committee. Coffeyville Nitrogen employees recognize that community involvement and volunteerism is the most effective way to improve the communities in which they live. Pollution Prevention Policy Coffeyville Nitrogen is committed to protecting the enviro nment 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 to 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. The above goals were applied to the design and construction of the Coffeyville Nitrogen Plant. The gasification process substitutes high grade feedstock, natural gas, with a low-grade feedstock, petroleum coke. Petroleum coke is the end product from the condensation process in oil cracking. Refineries have difficulties findin g a market for their coke due to its poor fuel characteristics. A conventional natural gas based ammonia plant would consume 25,000 cubic feet for every ton of ammonia produced. After considering these facts, Coffeyville Nitrogen chose to utilize Texaco Hydrogen Generation Process using coke as a feedstock. Substituting coke for natural gas conserves over 10 billion cubic feet of natural gas per year, which can be better used for home heating and electrical power generation. Constructing our plant next to a refinery lowers the coke transportation cost. The environmental design objective for this plant was to achieve significant emission reduction compared to the conventional nitrogen plant. No hazardous solids will be produced during normal operations. The water effluent will be clean enough to enter the Coffeyville's municipal water treatment system. The air contaminant emissions will meet the requirements for a minor source under Title V of the Clean Air Act and 40 CFR Part 7 0 (K.A.R. 28-19-500). Additional state-of-art safety features incorporated in the facility design will be described in the "Synopsis of Worst and Alternate Case Release Scenarios" section below. Stationary Source and Regulated Substances The gasification unit, ammonia synthesis unit and the UAN solution unit, along with the associated product ammonia storage and handling areas, 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, such as hydrogen produced by coke gasification, 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. It is this facility's policy to eliminate significant accidental releases of any substance, in particular hazardous and regulated substances; as well as strive to 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 these goals of accident and accidental release prevention, the facility is committed to the following: * A knowledgeable, highly trained, and motivated employee group * A well designed facility that is maintained and operated in a superior manner * Improvements that enhance safety and accident prevention where appropriate * A superior safety and accident record as consequence of an excellent safety program * Preparation and training for emergency response and mitigatio n The Coffeyville Nitrogen Plant has a written Emergency Response Plan and is committed to response and mitigation any accidental release to minimize the impact to employees, the community, and environment. The response plan is coordinated with the Cooperative Refinery, Local Emergency Planning Committee, and emergency response agencies. Employees are being trained in the implementation of the plan and in response activities that could be required in the event of an emergency. Chemical Specific Prevention Program The Coffeyville Nitrogen Plant is subject to the OSHA Process Safety Management rule, 29 CFR 1910.119, 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 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, mechanical integrity, 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 Coffeyville 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. 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. * Employee Participation-Employees are involved in all aspects of the program and are provided any information developed in the program. Employees participate in proc ess reviews, assist with development of procedures, and all other aspects of the program. * 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 * Process Hazard Analysis--Process hazard analysis and review has been conducted by employee teams to identify and correct any perceived hazards. These reviews are updated on a schedule or more often if changes indicate the necessity of additional review. * Operating Procedures--Operating procedures are being prepared 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. * Operating Training-All operators are being trained initially in the process and i ts operating procedures and will 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. * 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 will be periodically evaluated as necessary to assure work is completed in a safe and correct manner. * Pre-startup Safety Review-A safety review will be conducted on the Coffeyville Nitrogen facility before startup and for any significant modification of the facility after startup 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. * Mechanical Integrity-Procedures for inspection and testing and correction of equipment deficiencies are being prepared. A quality assurance procedure assures equipment, parts, materials, and installations are suitable for the applications intended. Maintenance employees will be trained in the process hazards and in safety procedures applicable to their work. * Safe Work Practices-Procedures and policies for work permits and maintenance and operating actions are in place for accident prevention. * 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. * Incident Investigation-Any incident which results in a significant release or could ha ve 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. * Emergency Planning and Response-The Process Safety Management/Prevention Program includes the facility Emergency Response Plan. * 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 Coffeyville Nitrogen Plant has a written Emergency Response Program as required by the Risk Management Plan rule and other Environmental Protection Ag ency and OSHA rules. This Plan is coordinated with Cooperative Refinery, 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 sheriff's office; and hospitals. Employees will 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 will be practiced in a tabletop classroom type setting and also tested in mock emergencies inclu ding 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. As a new facility under construction, Coffeyville 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 in the toxic class are ammonia and chlorine. The regulated substance in the flammable class is synthesis gas, which includes hydrogen. The rule requires an analysis of the worst case toxic as that sce nario 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 Because of 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 tank. The quantity for the tank is 20,000 tons. The worst case release assumes, as required by the rule, that this entire amount is released as a result of an instantaneous catastrophic failure of a tank. The rate of ammonia released is calculated from the vaporization rate from the liquid ammonia pool contain by the storage dike. A publicly available model (DEGADIS) which is known to provide reasonable estimates of concentrations and distances associated with release events modeled this unlikely event. This scenario has an off site impact. Details of the results of this modeling are provided elsewhere in the Risk Management Plan Submittal. 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 chlorine containers was similarly modeled. Neither of these resulted in a distance greater than the circumstance noted above. It should be emphasized that the probability of such an event as described by the worst case is nil. Many identically constructed and similar size tanks are in existence all over the world and have been in service for many decades without structural failure. Facility maintenance and inspection programs address the integrity of process and storage vessels, and largely preclude such massive and unlikely failures. Coffeyville Nitrogen has taken extraordinary precautions to insure the atmospheric storage tank will never structurally fail. The storage tank is completely enclosed in a second tank built to same design standards. The walls and floor are doubled, only the roof is common to both tanks. If the inside wall or floor of the interior storage tank should spontaneously fail the exterior tank will provide complete containment of the ammonia. The entire vessel is resting on concrete pilings, isolating the tank floor from the ground protecting it from water and ice. Due to the requ irements of the regulation, these safety features could not be considered when calculating the worst case release event. The worst case release event also is predicated on the assumption there would be no mitigating response during the release. Atmospheric storage tanks leak very slowly compared to pressurize tanks, which in a real release event, allows time for mitigating actions. 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 largest 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. This scenario has an off s ite impact. Impact distance is relatively limited as a result. Unlike most conventional ammonia plants, the Coffeyville Nitrogen plant has all major loop relief valves discharge to a flare, significantly reducing the probability of a vapor cloud explosion. 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 with the DEGADIS model for this facility is the accidental breakage of the four inch ammonia pipe that goes to the loading rack. Modeled impact distance is substantially lower for more reasonable, but not necessarily likely, release events. This scenario has 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 connecting tubing from the cylinder and release of gaseous chlorine. This release was modeled using the DEGADIS dispersion program. This scenario has an off site impact. Alternate Case Flammables Large volumes of flammable gases are handled throughout the plant, even though actual physical inventory is relatively low. More likely flammable release event is a failure of a small-bore pipe. The impact distance of this event utilized the EPA Offsite Consequence Analysis Look Up Tables. This scenario has an off site impact. Most reasonable and likely events result in minimal impact distances. Planned Changes for Sa fety Improvements Safety improvements will be a continual and ongoing process at the facility that is facilitated by the Prevention Program/Process Safety Management Program. Formal process hazard analysis are 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. |