Taft Terminal - Executive Summary |
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28032 LDEQ Facility ID Number KOCH NITROGEN COMPANY Taft Terminal Taft, Louisiana EXECUTIVE SUMMARY FOR 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 unac ceptable, 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 Taft Terminal is one of several ammonia storage and terminal facilities operated by Koch Nitrogen Company. Anhydrous ammonia is the only substance regulated under the Risk Management Program (RMP) that is present at the facility in amounts greater than threshold quantity. The terminal is classified as Program Level 3 under the regulation. At the terminal we receive liquid ammonia from a central pipeline and store it until it is loaded on barges and ships for further transport and distribution. In addition to ammonia, propane is stored and used at the terminal as a fuel source for the flare. However, the quantity of propane that is stored at the terminal is below the RMP threshold quantity. The purpose of this Risk Management Plan (RMPlan) is to provide information about our op erations 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 Regulations, our worst case release scenario for toxic chemicals would be the loss of all of the ammonia in our largest vessel within 10 minutes. In the case of the Taft Terminal, this would involve our 50,000 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 scenario. The alternative release scenario, characterized as a more likely scenario that could involve an offsite exposure to ammonia vapors, is calculated to reach 0.07 miles from the release point. This distance calculation is based on the CALPUFF model. We selected the alternative release scenario based on an actual incident that happened on July 20, 1995. This incident involved a release of anhydrous ammonia from the vessel relief valves and the flare. We have implemented several active mitigation measures to prevent the recurrence of this incident. These active mitigation measures include the following: 1) a liquid recirculation system has been installed; 2) a backup generator has been installed to ensure uninterrupted power supply to the flare; 3) the main flare is kept lit continuously to ensure uninterrupted combustion of ammonia vapors; and 4) a backup flare has been installed to ensure uninter rupted combustion of ammonia vapors even during failure of the main flare. 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 these potential releases with our employees and with local emergency response officials in St. Charles Parish, thereby further reducing the possibility of any impact on the public. Prevention Program The Taft Terminal has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1992. 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 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 a backu p flare to ensure no interruption in the combustion of ammonia vapors in the unlikely event of the main flare going out. 7 We installed a backup power generator to ensure uninterrupted power supply to the process control system and the flare system. 7 We have ammonia detectors in our process area to ensure that an ammonia release is detected and terminated as soon as possible. 7 We have provided emergency shutdown capabilities at our central control room at Wichita in order to shutdown the facility in case of emergencies. 7 We have provided emergency shutdown buttons at the barge and ship loading area that can be activated by both the Koch personnel and ship/barge crew in case of ammonia release. 7 We provided surge bladders on our ship/barge loading lines to absorb the shock during sudden closure of the valve due to emergency shutdown. 7 We provided a fire water deluge system on top of our largest ammonia tanks. 7 We provided fire water cannons at the terminal for fire fighting and va por control. These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since our acquisition in 1995. Five Year Accident History We had two incidents at the Taft Terminal during the last five years which resulted in significant on-site property damage or off-site impact. These incidents are detailed below: July 20, 1995: A series of ammonia releases occurred at the Taft Terminal on July 20, 1995. Approximately 11,500 pounds of ammonia were released between 5:35 AM and 3:05 PM. During the event, three types of releases occurred: an initial spill of liquid ammonia from a flare stack, which wetted the outer surface of the stack and formed a rapidly evaporating pool; a continuous release of ammonia vapor due to evaporation of residual liquid ammonia in the flare throughout the duration; and periodic releases of ammonia vapor from the pressure relief valves on a storage vessel. This incident resulted in offsite impa cts including evacuation of neighboring residents and an unknown number of hospitalizations. March 19, 1997: At approximately 11:40 PM on March 19, 1997, due to extremely high water conditions on the Mississippi River, several barges struck Kochs river dock causing severe damage to the dock and rendering the ammonia loading equipment and piping inoperable. The ammonia loading pipe was broken due to the barge strike resulting in the release of approximately 6,000 pounds of ammonia vapor. This incident resulted in on-site property damage which was estimated to be $650,000. Emergency Response Program Any emergency response necessary for the Taft Terminal would be coordinated with the Hahnville Fire Department, the St. Charles Parish Sheriff, the St. Charles Parish Emergency Operations Center and, as appropriate, the St. Charles Parish Hospital Ambulance Service, the Louisiana State Police, and the U.S. Coast Guard. The Taft 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 the Community Emergency Response Plan. 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 Taft 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) provisions 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 St. Charles Parish 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 St. Charles Parish Emergency Management Director for the latest information on emergency response for the Parish. We plan to diligently integrate our response capabilities and personnel with those of the Parish on an on going basis. |