Farmland Industries, Ft Dodge Nitrogen Plant - Executive Summary |
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Risk Management Plan Executive Summary Farmland Industries, Inc. Ft. Dodge Nitrogen Plant Ft. Dodge, Iowa Farmland Industries, Inc. operates a nitrogen fertilizer manufacturing facility at Ft. Dodge, Iowa. As a nitrogen fertilizer manufacturing facility, producing anhydrous ammonia and other fertilizer products utilizing ammonia as a feed stock, this facility is subject to the Environmental Protection Agency's Risk Management Program rules under the Clean Air Act Amendments of 1990. The amended Risk Managment Plan which this summary is part of, contains one major mitigation measure which has altered the worst case scenario. The facility has installed dikes around each of the ammonia tanks. Modelling of the worst case scenario has indicated a substantial reduction in distance to endpoint, and a reduction in affected populations. The Risk Management Program rules require facilities handling threshold amounts of certain chemical substances to submit Risk Management Plans for t he prevention of accidental releases of these substances. The plan requirements include submission of the risk management plan, which includes 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., Ft. Dodge Nitrogen Plant at Ft. Dodge, Iowa. Stationary Source and Regulated Substances The Fort Dodge Nitrogen Plant is a nitrogen fertilizer manufacturing facility consisting of a large scale, natural gas feed ammonia production unit and an integrated urea-ammonium nitrate (UAN) production unit. These products are primarily used as agricultural fertilizers. Initial operation of the ammonia plant began in 1967. In 1997, the UAN unit was completed and the ammonia plant was revamped and upgraded. The facility produces, handles, and stores large quantities of anhydrous ammonia in its operations. The ammonia unit uses natural gas, air, and water for the production of ammonia. Ammonia is used along with byproduct carbon dioxide to produce liquid urea in the UAN plant. Ammonia and air in the same plant are used to produce nitric acid which is subsequently neutralized with ammonia to produce ammonium nitrate. The liquid urea and ammonium nitrate are mixed forming the urea-ammonium nitrate solution 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 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, 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 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 from this facility. It is this facility's 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 general public. To achieve its goals of accident and accidental release prevention, the facility is committed to the following: * A knowledgeable and highly trained and motivated employee group * A well designed facility th at is maintained and operated in a superior manner * Improvements that enhance safety and accident prevention where appropriate * Excellence in safety programs and practices and a superior safety and accident record * Preparation and training for emergency response and mitigation The Ft. Dodge 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 Planning 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 Ft. Dodge Nitrogen Plant is subject to the OSHA Process Safety Management rule , 29CFR1910.119, 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, 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 Ft. Dodge Nitrogen Plant adheres to the requirements of Process Safety Management and has written policies and procedures addressing all aspects of Pro cess Safety Management and EPA Prevention Programs. In all of its years of operation, 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 process 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 th e necessity of additional review. * 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. * Operating Training-All 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. * 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 is periodically evaluated as necessary to assure work is completed in a safe and correct manner. * Pre-startup Safety Review-A 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. * Mechanical Integrity-Procedures 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. * 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 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. * 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 Ft. Dodge 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 sh eriff's 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 Fort Dodge Nitrogen Plant had two qualifying injuries in the past five years. One ocurred on December, 2nd, 1999. A mechanic was working on an ammonia pump in the UAN unit, when ammonia contained in the pump leaked out. He was given first aid and treated and released at a local hospital. He returned to work later that day. The pump had been inadequately cleared. Since the incident, pump clearing procedures were changed to make the possibility of ammonia escaping during pump maintenance less likely. Training on the new procedures was done immediately after the incident. The Fort Dodge Nitrogen Plant had another qualifying injury in the past five years which occurred on October 17, 1998. On that date, a relief valve lifted in the ammonia loading and unloading area of the plant which released ammonia in the loading area relief header system. An experienced shift production foreman was in the area to correct the problem and a drop of liquid ammonia bypassed the safety glasses which he was wearing and ended up in his eye. Since that incident, every employee at the Plant has received additional training on the importance of appropriate eye safety equipment and its proper use. Synopsis of Worst and Alternate Case Release Scenarios The Risk Mana gement 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 and chlorine as regulated toxics, and flammables as a class which include methane and hydrogen. The 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 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 wo rst 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 an atmospheric storage tank, each of which contains 30,000 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 a 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 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 possibility of such an event as described by the worst case is so low as to be non-existent. Many identical and similar tanks are in existence all over the world and have been in service for many years. We are aware of no such failure of these tanks nor, even, lesser failures of a nature that would provide for an accidental release of quantities even orders of magnitude less than indicated above. 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 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, especially considering the quantity of inert gasses and steam mixed with the flammable gases. Impact distance is relatively limited as a result. 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 throughout the plant, and operator intervention all tend to mitiga te 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 consisted of an anhydrous ammonia truck driver leaving the loading station with the loading equipment still attached to his trailer. This in turn, discharges the contents of the piping from the loading area up to the excess flow valves located at the loading area bullets. Modeled impact distance is substantially lower for more reasonable, but not necessarily likely, release events. 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 m odeled using the DEGADIS dispersion program. 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 likely flammable release events include failures of smaller pipes and lines in comparison to the large release contemplated in the worst case analysis. More reasonable and likely events result in minimal impact distances. The alternate scenario assumed a vapor cloud explosion as a result of a pressure relief valve in the ammonia synthesis loop lifting for 45 seconds. The impact distance of this event utilized the EPA Offsite Consequence Analysis Look Up Tables. Planned Changes for Safety Improvements Safety improvements are a continual and ongoing process at the facility which is facilitated 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. |