WT-5 Marshalltown Terminal - Executive Summary
KOCH FERTILIZER STORAGE & TERMINAL COMPANY |
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 u
nacceptable, 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 Marshalltown Terminal is one of many facilities operated by Koch Fertilizer Storage & Terminal Company (Koch) along a 2,500 mile pipeline supplying anhydrous ammonia to the Midwest farming area where it is used as a fertilizer. Anhydrous ammonia is the only toxic substance regulated under the Risk Management Program (RMP) that is present at the Marshalltown Terminal. There are no RMP flammable substances at the site. 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. The purpose of this Risk Management Plan (RMPlan) is to provide information about our ammonia 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 Regulation, our worst case release scenario would be the loss of all of the ammonia in our largest vessel within 10 minutes. In the case of the Marshalltown 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 alarms, emergency shutdown, and others) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this scenar
io. 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.
We have also discussed this potential release with our employees and with local emergency response officials in Marshall County, thereby further reducing the possibility of any impact on the public.
The Marshalltown Terminal has been operating under the strict guidelines of the Occupational Safety and Health Ad
ministration (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 replaced propane tanks and associated propane vaporizers with natural gas for use in heating and use in flares to avoid the potential of propane releases.
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 installed backup generators to ensure that the flare continues to operate, even du
ring a power failure.
7 We have ammonia detectors in our process area to ensure that an ammonia release is detected and terminated prior to any negative impacts.
These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it in 1988.
Five Year Accident History
No incident resulting in onsite or offsite impacts from an ammonia release has occurred during the past five years at the Marshalltown Terminal. 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 Marshalltown Terminal with the Green Mountain Fire Department. Also included in emergency response would be the Marshalltown Police Department, the Marshall County Sheriff and, as appropriate, the Marshal
ltown Hospital and Utility Company. The Marshalltown 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 drills, 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 Marshalltown 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) p
rovisions 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 Marshall 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 Marshall County Emergency Management Director for the latest informati
on 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.