Sterlington Facility - Executive Summary |
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23941 LDEQ Facility ID Number KOCH NITROGEN COMPANY Sterlington Facility Sterlington, 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 acknow ledged as unacceptable, 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 Sterlington Facility is one of several facilities operated by Koch Nitrogen Company (Koch) along a 2,500 mile pipeline supplying ammonia to the Midwest farming area where it is used as fertilizer. Anhydrous ammonia and chlorine are the only toxic substances regulated under the Risk Management Program (RMP) that are present at the Sterlington Facility. There are no RMP flammable substances present at the site in greater than threshold quantities. The facility is regulated under the Program Level 3 requirements. At the facility we produce anhydrous ammonia and inject it into the main pipeline to be transported north to distribution terminals. We also store anhydrous ammonia at the facility until it is loaded on rail cars, trucks and barges for distribution. The pur pose of this Risk Management Plan (RMPlan) is to provide information about our operations at the facility, 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 facility. Worst Case and Alternative Release Scenarios As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case 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 Sterlington Facility, 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, emer gency 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 2.5 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 a release of liquid ammonia during barge loading due to a loading arm failure and emergency shutdown failure at the barge loading area. This scenario would then require a manual shutdown of the loading pump. We have several active mitigation measures in place to prevent the occurrence of this incident. These active mitigation measures include the following: 1) Koch personnel and barge company personnel are present at the barge loading area throughout the loading operation to monitor and control the loading operations; 2) Koch personnel and barge company personnel present at the barge loading area can initiate immediate response actions such as hitting the emergency shutdown button or manually shutting off the loading pump; and 3) An excess flow valve is in place on the line that is used to transfer liquid ammonia from the cryogenic tank to the barge in order to prevent a release of ammonia from the cryogenic tank in the event of loading arm failure. The presence of these active mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur. The alternative release scenario reported for chlorine is based on a leaking valve at the connection on the chlorine cylinder. This scenario is calculated to reach 0.4 miles from th e 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. This scenario is unlikely to occur because the facility is manned 24 hours a day and Koch personnel routinely inspect the entire facility for any problems including leaking valves on these chlorine cylinders. We have discussed these potential ammonia and chlorine releases with our employees and with local emergency response officials in Ouachita Parish, thereby further reducing the possibility of any impact on the public. Prevention Program The Sterlington Facility has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1993. 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 required a brake lock system that prevents truck drivers from driving away before the loading arm is properly disconnected. 7 We installed a new flare system and continuous pilots on our flares in order to ensure no interruption in the combustion of ammonia vapors, even during high winds. 7 We provided an interlock system, which will shutdown ammonia loading pumps upon high pressure during product movement, in order to prevent release of ammonia due to overpressurization. 7 We installed ammonia detectors at our perimeter to ensure that an ammonia release is detected and terminated as soon as possible. 7 We required personal protection equipment at all loading areas and supply emergency air in the control rooms. Five Year Accident History There have been two incide nts in the past five years that would qualify as RMP-defined accidents. These were relatively minor accidents in that they involved only treatable onsite injuries. The Sterlington Ammonia Plant places daily emphasis on our prevention and safety programs to ensure that accidents do not occur. However, the following incidents were beyond the control of the employees at the facility. The most recent incident occurred on July 24, 1998 and involved a plant wide power outage caused by an off-site electrical equipment failure. The power failure caused a buildup of ammonia in the vent header which began to relieve about two hours after the power went down. A shelter-in-place was sounded for the facility approximately two hours after the initial release because higher concentrations of ammonia were being observed. The duration of the incident was approximately five hours. Monitoring was conducted along the fence line and only a small amount of ammonia was detected, however, there were n o offsite impacts from this release. During the initial release, two employees inhaled ammonia vapors. They were treated at the facility, sent to the local hospital for observation and released later that same day. On February 27, 1997, a maintenance crew was replacing tubes in the ammonia condenser. It was presumed that the condenser had been cleared of ammonia and through a visual check this was confirmed. When the contractor removed the plugs in the existing tubes in order to replace them with the new tubes, a small amount of trapped ammonia sprayed out and an employee and a contractor inhaled ammonia vapors. They were treated at the facility and sent to the local hospital for observation. Emergency Response Program We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the Sterlington Facility with the Ouachita Parish Fire Department and the Ouachita Parish Sheriff. Also involved in emergen cy response for the facility would be North Monroe Hospital in Monroe, the Louisiana State Police, the U.S. Coast Guard, and Louisiana Power and Light. The Sterlington Plant Manager is responsible for coordinating all emergency actions. A specific Emergency Response Plan for the facility is in place, and that plan has been coordinated with local officials, along with evacuation procedures, regular drilling, 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 Sterlington Facility. 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 a ny 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 Ouachita 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 citizen s or community organizations to contact the Ouachita 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 ongoing basis. |