Farmland Hydro, L.P. (Green Bay Plant) - Executive Summary

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                                                                  RISK MANAGEMENT PLAN 
                                                                     EXECUTIVE SUMMARY 
                                                                      Farmland Hydro, L.P. 
                                                                Green Bay Fertilizer Complex 
Farmland Hydro, L.P. (FHLP) is a limited partnership corporation formed by Farmland Industries, the largest U.S. farmers cooperative headquartered in Kansas City, Missouri, and Norsk Hydro ASA, a large Norwegian company engaged in fertilizer, oil and gas, and specialty metals.  Farmland Industries is a highly diversified company with major business lines in crop production and crop protection products, livestock feeds, petroleum, grain processing and marketing, and the processing and marketing of pork and beef products serving the needs of its 600,000 United States farmer-owners. 
The Farmland Hydro, L.P.  
Green Bay Chemical Complex is located on County Road 640, about 6 miles southwest of Bartow in the southwest part of Polk County Florida.  The facility primarily manufactures phosphate fertilizers commonly known as DAP (diammonium phosphate) and MAP (monoammonium phosphate) which is used to produce high quality fertilizers used in crop production around the world.  The facility was built by Farmland Industries in 1965 and underwent several expansions and modernization resulting in a tripling of production capacity. 
The facility is situated on about 2,500 acres of property bounded by CR 640 on the south and Bonnie Mine road on the west.  The facility contains a phosphogypsum stack and cooling pond system of about 500 acres in size and maintains an NPDES (National Pollution Discharge Elimination System) permit for waste water, a State of Florida issued ground water permit as well as a Title V air permit.  We currently have plans for expansion of the gypstack and the opening of a mine in 
Hardee County which will secure our future as a corporate citizen for at least the next 30 years. 
Farmland Hydro, L.P. employs about 300 Polk, Hillsborough and Hardee County residents at a combined annual salary of nearly $16 million dollars.  FHLP contributes nearly $1,750,000 in state and local taxes annually.  Nearly $17 million dollars is spent locally on miscellaneous purchases for the facility annually.  We are active in the communities where we operate or where our associates live.  We are particularly active in the general categories of cultural arts, education, health and safety and other non-profit organizations.  The facility also sponsors a local citizens advisory panel.  Our employees are active in charity work including United Way, Habitat for Humanity, Christmas Angels, VISTE, and the local blood drive.  In addition, several staff members are active in the Local Emergency Planning Committee Region VII. 
FHLP is com 
mitted to protecting the environment and preserving our natural resources for future generations.  We strive to eliminate or reduce our use of toxic substances and to minimize our use of energy and the generation of all wastes to the extent technically and economically feasible.  We strive to minimize 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 maintain a safe and healthy workplace, improve the quality of our products, achieve cost savings, and increase operational efficiencies. 
Anhydrous ammonia is the only regulated substance at this facility subject to EPA Risk Management Program and the OSHA Process Safety Management Program.  FHLP does not manufacture ammonia but receives it from our Tampa Terminal by pipe line and tanker truck.  Ammonia is used in the production of nitrogen-phosphorus 
bearing granular and liquid fertilizers.  Our onsite storage capacity is sufficient for only 12 hours usage of ammonia.  Inventories are purposely kept low to reduce the risk of exposure should an accidental release occur. 
The management and employees of this facility are committed to the prevention of any accidental releases.  It is the personal challenge and policy of the management and associates of this facility to identify and reduce or eliminate all recognized process hazards, not only involving the regulated substance but of all hazardous substances and circumstances. 
To achieve the goals of accident and accidental release prevention, the facility is committed to the following: 
7 A knowledgeable, highly trained and motivated employee group 
7 A well designed facility that is maintained and operated in a superior manner 
7 Improvements that enhance safety and accident prevention 
7 Preparation and training for emergenc 
FHLP has had a written Emergency Response Plan in effect for many years and is annually reviewed.  Employees are trained regularly in the event of an emergency.  The plan is designed to prevent employee exposure and to coordinate with local emergency response agencies in the event of a release.  A general plant alarm is in operation and also a system of immediate neighbor notification.  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 local fire department. 
The Green Bay facility is subject to OSHA Process Safety Management rule and is therefore under the EPA Risk Management Rule and is a Program 3 facility with a Program 3 Prevention Program.  The OSHA PSM/EPA Prevention Program consists of a set of facili 
ty management policies and procedures which promote and recognize process safety and the prevention of accidents in plants that handle, use, store, and process hazardous chemicals above the threshold quantity specified.  The procedures address all aspects of plant activities including training, maintenance, operating procedures, process reviews, safe work practices, incident investigation, audits, 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 prevention program consists of many 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. 
PROCESS SAFETY INFORMATION - All necessary process information and records are maintained in several convenient locations including information on the hazards of the chemicals, process technology with safe opera 
ting limits, and equipment records and design requirements. 
PROCESS HAZARD ANALYSIS - Several employees have had extensive professional training in the methods of process hazard analysis (PHA) and are available to act as PHA team leaders.  These reviews are updated on a regular basis. 
OPERATING PROCEDURES - Operating procedures are in place for all aspects of operation including emergency operation and shutdown. 
OPERATIONS TRAINING - All operators are trained initially in the process and its operating procedures and are supervised by an experienced operator for a lengthy training period before being allowed to control the process on their own.  They must demonstrate competency in all aspects of the plant operation including unexpected malfunctions. 
CONTRACTORS - Contractor selection includes review of safety performance and programs.  All contractor employees are required to attend an initial 16 hour OSHA/MSHA structured class offered at several local community training facilities. 
 Contractors are also required to have had a recent site specific training and periodic evaluations are made to assure work is completed in a safe manner. 
PRE-STARTUP REVIEW - A safety review is conducted on any new process equipment or any significant modification of the process.  This assures 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. 
MACHANICAL INTEGRITY - This is a quality assurance procedure to assure that 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.  Inspections, procedures and testing are conducted under this part of the program. 
SAFE WORK PRACTICES - Procedures and policies for work permits and maintenance lock-out-tag-out pro 
MANAGEMENT OF CHANGE - No changes in process or procedures are allowed without review and authorization.  Safety impacts, technical review, required procedure modifications, and training are all considered in the review. 
INCIDENT INVESTIGATION - Any accident, near-miss, or incident that resulted in or could have resulted in a release is promptly investigated by a facility team.  Findings of the investigation and recommendations for corrective action are documented, as is the resolution of the recommendations and corrective actions. 
COMPLIANCE AUDIT - Compliance with the program is audited at least every three years to verify compliance with these procedures.  Findings of the audit are documented and any deficiencies are corrected and documented. 
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 
off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.  This facility has had one incident that occurred on December 6, 1996, which resulted in a release of 142 tons of ammonia and one employee was hospitalized for an extended period of time.  Within a year the employee has returned to full duty. As a result of this incident an investigation team was formed to thoroughly evaluate the causes of this incident.  The team recommended and the companys engineering department instituted a variety of improvements and mitigation systems to prevent a future occurrence.  No off-site impacts resulted from this release.  
The Risk Management rule requires a hazard analysis for worst case and alternate case accidental release scenarios for regulated substances.  The rule requires an analysis involving the release of the total contents of the largest storage vessel of ammonia at this site.  This 
is called the "worst case toxic release scenario" (worst case scenario) and involves the release of 186 tons of ammonia.  This release must be considered to occur over a 10-minute period and all of the ammonia must be considered to convert to gas instantly.  We have retained a consultant to model this unlikely release utilizing a model known as DEGADOSE.  His results, modeling according to the rule, determined that there would be only minor off-site impact.  This worst case is a requirement of the rule regardless of whether the event is likely, or, could even reasonably occur. 
An alternate scenario, which is a more likely event, is required to be submitted.  The alternate chosen involved the release of ammonia from a transfer pipe where 60,000 pounds would be released over a 15 minute period.  A significantly lower quantity is involved because various shutdown safeguards are present and operator intervention all tend to mitigate and limit the quantity of failures.  The same modeling  
techniques were applied and resulted in even lesser off-site impact. 
PLANNED CHANGES FOR SAFETY IMPROVEMENTS:                                                                                                                                                                                                                                                                                                                             Safety improvements are a continual and ongoing process at the Green Bay facility which is facilitated by the Prevention Program/Process Safety Management Program.  Many process safeguards have been implemented as a result of the Process Hazard Analysis and incident investigation activities.  Such things as remote shut-down systems, early detection sensors, surveillance monitors and water deluge systems have all been installed within the last two years in response.  It is the understanding of FHLP that through the diligent application of the elements of the Preventi 
on Program/Process Safety Management Program that our employees and the community can be assured that emergency response will never be necessary.
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