Farmland Industries, Inc. Conway Ammonia Terminal - Executive Summary
RISK MANAGEMENT PLAN |
FARMLAND INDUSTRIES, INC.
CONWAY, KS TERMINAL
Farmlands Conway ammonia terminal is located on 17 acres in central Kansas, about nine miles west of McPherson. The terminal functions as a storage and distribution facility for fertilizer used by some of Farmlands 600,000 producer-members to grow the crops that provide high-quality, low-cost food for families around the world.
Annual volume of 60,000 to 100,000 tons of ammonia is distributed through the Farmland facility that has been supplying co-ops in central Kansas for 23 years. As a terminal, the facility provides a vital link in the chain of Farmland inputs. Anhydrous ammonia, produced at Farmlands nitrogen manufacturing facilities, is shipped to the Conway terminal where it is stored until needed by local co-ops for their patrons fields. By eliminating much of the shipping costs for the co-ops, the terminal helps contain the cost of fertilizer for Farmland member-o
wners as well as provide a convenient location for them to get their product.
Impact on the community
Farmland is a solid, reliable member of the Conway, KS, community. Its employees are committed to customer service and the facility is available to service member-owners as needed throughout the year. Farmland's Conway employees know their customers are also their neighbors and strive to "always be there if someone needs us."
Farmland has two full-time and two part-time employees, as well as an area manager, with nearly 50 years of combined operating experience at its Conway ammonia terminal. Although few in number, these employees have a large impact on the community in which they live.
Farmland employees recognize community involvement and volunteerism as the most effective way to improve the communities they live in.
Pollution Prevention Policy
Farmland Industries Inc., is committed to protecting the environment and preserving our natural resources fo
r future generations. We pledge to eliminate or reduce our use of toxic substances and 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.
Risk Management Program
This facility is subject to the Environmental Protection Agencies Risk Management Program Rule under the Clean Air Act Amendments of 1990. The Risk Management Program Rule require facilities handling threshold amounts of certain substances to develop a Risk Management Program and submit a Risk Management Plan. The Program requirements include submiss
ion of the risk management plan, hazard assessments defining possible off-site 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 Program for Farmland Industries, Inc.; Conway ammonia terminal at Conway, KS.
Stationary Source and Regulated Substances
Initial construction and operation of the Conway Ammonia Terminal began in 1975. Several changes, additions and improvements since that time have resulted in the current design of the facility. The anhydrous ammonia distributed from this facility is used as agricultural fertilizer.
The Conway Ammonia Terminal is a distribution facility for anhydrous ammonia consisting of a 30,000 ton atmospheric storage tank, with a secondary containment dike, a 30,000 gal and two 18,000 gal pressurized ammonia storage vessels, a product heater, refr
igeration compressors and assorted vessels and piping.
Anhydrous Ammonia is the only substance, regulated by the EPA's RMP rule, that is used, or stored at the Conway facility. The Ammonia storage and transfer process is subject to the RMP rule as a program 3 process.
Accidental release prevention and Emergency Response Policy
It is Farmlands corporate policy to eliminate accidental releases of any substance, in particular hazardous and regulated materials. The management and employees of this facility are committed to the prevention of any accidental releases. Accidental release prevention is critical to the safe operation of this terminal, the safety of its employees and the community.
To achieve its accident and accidental release prevention goals, Farmland is committed to the following:
7 A knowledgeable, motivated and highly trained employee group
7 A well-designed facility that is maintained and operated in a superior manner
7 Implementation of a Comprehensive Process
Safety Management and Prevention Program
7 Continual review and improvements that enhance safety and accident prevention
7 Excellence in safety programs and practices, and a superior safety and accident record
7 Planning, preparation and training for emergency response
The Conway terminal has had a written Emergency Response Plan, as required by the RMP and other EPA and Occupational Safety and Health Administration (OSHA) rules, in effect for many years, and is committed to implement the plan in response to any accidental release to minimize the impact to employees, the community and the environment. The response plan is coordinated with the Local Emergency Response committee and emergency response agencies. Terminal personnel have interacted with these agencies for many years regarding the plan and activities at the terminal.They have conducted facility tours for the Local Emergency Planning Committee ensuring plant familiarity with the community organization.
Employees are train
ed in the implementation of the plan and appropriate response activities that could be required in the event of an emergency.
The Conway ammonia terminal is subject to the OSHA Process Safety Management (PSM) rule, 29CFR1910.119. This rule has required this facility to establish an accident prevention program which is equivalent to that required for Program 3 processes under the EPAs RMP rule.
The OSHA PSM/EPA Prevention Program consists of a set of facility management policies and procedures that promote and recognize process safety and the prevention of accidents in processes that handle, use, store or process hazardous materials. The procedures provide accident prevention process controls to all aspects of terminal activities.
The Conway terminal adheres to the requirements of PSM and has written policies and procedures addressing all aspects of PSM and EPA Prevention Program requirements including routine training and testing of employees and drivers that
operate any part of the process, alarms to indicate operating conditions outside the norm, an off-hours phone notification system for abnormal conditions, video monitoring of truck loading/unloading stations and automatic shutdown of ammonia transfer should control parameters fall outside normal conditions. Additionally, the facility is equipped with terminal perimeter sensors to monitor potential emissions from the facility, continuously. The facility has addressed the elements of accident prevention included in these programs throughout its years of operation.
The facility is diligent in adhering to and maintaining its Process Safety/Prevention Program.
Emergency Response Program
The Conway Ammonia Terminal has established an Emergency Response Program and has a written Emergency Response Plan as required by the Risk Management Program 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.
This facility is an active participant in the Local Emergency Planning Committee and interacts with various local agencies in its emergency planning. These include local fire departments, law enforcement agencies and hospitals.
Employees receive annual training on the facility emergency response plan and also receive additional safety training, both in general, and in the competencies relative to their required roles in the emergency response plan.
Five-year accident history
The RMP rule requires inclusion of the facilitys five-year accident history for all accidental releases of regulated substances that resulted in deaths, injuries or significant property or environmental damage on or off site.
Farmlands Conway terminal has an excellent five-year accident record with no RMP reportable releases.
Synopsis of worst and alternative-case release scenarios:
The hazard assessment element of the RMP rule requires the evaluation of
potential off site effects of "worst-case" and "alternative-case" release scenarios of regulated substances in a program 3 process.
The EPA has defined a worst-case scenario as the release of the largest quantity of a listed chemical from a vessel or process line failure, taking into account passive mitigation and administrative controls. The impact of these potential releases must be quantified in accordance with release criteria dictated in the rule. The projected impact distance is determined using EPA defined atmospheric conditions and is intended to provide a conservative estimate of the maximum possible area that might be affected. According to the EPA, the worst-case scenario is intended to ensure that no potential risks to public health are overlooked, but the distance to an endpoint estimated under worst-case should not be considered a "public danger zone." Possible causes or the extreme improbability that such releases may occur are not considered.
The alternative relea
se scenario definition is a release that is more likely to occur than the worst-case release; however, as with the worst-case, the alternative release improbability is not taken into consideration.
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 used for direct injection into croplands as a fertilizer. A large amount of industrial ammonia is reacted with carbon dioxide to make urea fertilizer, or reacted to make ammonium nitrate fertilizer. Ammonia is also frequently used as a refrigerant for the storage of perishable foods.
Ammonia vapors can be irritating to the nose, throat, eyes and skin. Direct liquid contact to the skin can cause severe burns.
Farmland has considered potential worst-case releases from the refrigerated atmospheric storage tank which is passively mitigated by a seco
ndary containment dike and the largest bullet tank, the two largest vessels onsite.
Farmlands hypothetical worst-case scenario involves an anhydrous ammonia release from the terminals 30,000 ton atmospheric storage tank. The worst case release assumes, as required by the rule, that this entire quantity is released as a result of a catastrophic failure of the tank. This unlikely event was modeled with a publicly available model (DEGADIS) which has been demonstrated to provide reasonable estimates of concentrations and distances associated with release event. The impact of this release scenario is predicted to extend beyond the facility boundary and impact public receptors.
This scenario, we believe, is a hypothetical worst-case event dictated by the rule and extremely unlikely to occur for many reasons. In addition to the stringent design controls for this type of vessel, facility maintenance and inspection programs address the integrity of process and storage vessels, including
this one, and largely preclude such massive and unlikely failures.
Alternate Case Toxic Release - Anhydrous Ammonia
More likely release events than the hypothetical worst-case, tend to concentrate in areas where the ammonia product is handled such as loading and other transport activities. Generally, significantly lower quantities are involved, due to numerous shutdown safeguards present, as they are through out the terminal, and operator intervention which tend to mitigate and limit the consequences of failures.
The hypothetical ammonia alternative release scenario considered for this process is a release of ammonia due to the failure of a 4" transfer pipe. The pipe is assumed to fail and release ammonia for approximatly 1 minute before employees activate the emergency shut down system stoping the flow. The contents of this pipe is assumed to subsequently drain out. The impact of such a release was modeled with the DEGADIS model which shows that, under typical ambient conditio
ns, the impact of the release would extend off-site.
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 revalidation 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.