Farmland Greenwood Ammonia Facility - Executive Summary |
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Risk Management Plan Executive Summary Farmland Industries, Inc. Greenwood, NE Facility Farmlands Greenwood, NE ammonia facility is located on approximately 7 acres leased from the MAPCO Ammonia Pipeline, Inc. in eastern Nebraska. The facility functions as a storage location for the fertilizer used by Farmlands 600,000 producer-members to grow the crops which provide high-quality, low-cost food for families around the world. Facility Snapshot Annual volume of 40,000 tons of anhydrous ammonia is put through the Farmland facility that has been supplying co-ops in eastern Nebraska and western counties in Iowa for 26 years. As a storage facility, the Greenwood location provides a vital link in the chain of Farmland inputs. Anhydrous ammonia, produced at Farmlands nitrogen manufacturing facility in Enid, OK, is shipped to the Greenwood facility by pipeline 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 facility helps contain the cost of fertilizer for Farmland member-owners as well as provides a convenient location for them to get their product. Impact on the Community With an annual budget of over $400,000, Farmland provides a considerable economic benefit to the Greenwood community. Farmland is committed to customer service and the facility is available to service member-owners as needed throughout the year. Employee Snapshot Farmland contracts the operation of the facility to the MAPCO Ammonia Pipeline, Inc. The contractors 8 full-time employees provide years of experienced service to the area cooperatives. Major maintenance projects for this facility are performed by Farmland maintenance personnel. These Farmland employees are trained in all aspects of facility maintenance including electrical and mechanical troubleshooting. Pollution Prevention Policy Farmland Industries, Inc. is committed to protecting the environment and preserving our natural resources for 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 economical 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 Agencys Risk Management Program Rule under the Clean Air Act of 1990. The Risk Management Program Rule requires facilities handling threshold amounts of certain substances to develop a Risk Management Program. The Program requirements include submission of a Risk Management Plan, hazard assess ments defining possible offsite impacts of certain regulated substance release scenarios, a five-year accident history, development of a process accidental release prevention program and an emergency response program. The following is the Executive Summary of the Risk Management Plan for the Farmland Industries, Inc. Greenwood ammonia facility at Greenwood, NE. Stationary Source and Regulated Substances Initial construction and operation of the Greenwood Ammonia Facility began in 1973. Several changes, additions and improvements since that time have resulted in the current design of the facility. The anhydrous ammonia stored at this facility is used as agricultural fertilizer. The Greenwood Ammonia Facility is a storage facility for anhydrous ammonia consisting of a 30,000 ton atmospheric pressure, refrigerated liquid storage tank with a dike for secondary containment, a product heater, refrigeration compressors and assorted vessels and piping. Anhydrous ammonia is the only sub stance regulated by the EPAs RMP rule that is used or stored at Farmland's Greenwood facility. Accidental Release Prevention and Emergency Response Policy It is Farmlands corporate policy to eliminate accidental releases of any substance, particularly hazardous and regulated materials. Consistent with Farmland policy, the contract employees of this facility are also committed to the prevention of accidental releases. Accidental release prevention is critical to the safe operation of this facility, 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 progra ms and practices and a superior safety and accident record 7 Planning, preparation and training for emergency response The Greenwood facility has had a written Emergency Response Plan in effect for many years, as required by the RMP and other EPA and Occupational Safety and Health Administration (OSHA) rules. The response plan is coordinated with the Local Emergency Planning Committee and emergency response agencies. On behalf of Farmland, the contract personnel have interacted with these agencies for many years regarding the plan and activities at the facility. Contract employees are trained in the implementation of the plan and appropriate response activities that could be required in the event of an emergency. Prevention Program The Greenwood ammonia storage process is subject to the OSHA Process Safety Management (PSM) rule, 29CFR1910.119. This rule has required the facility to establish an accident prevention program for this process 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 facility activities. The Greenwood process operators adhere to the requirements of PSM and have written policies and procedures addressing all aspects of PSM and EPA Prevention Program requirements including routine training and testing of employees, alarms to indicate operating conditions outside the norm and an off-hours phone notification system for abnormal conditions. Additionally, the facility is equipped with perimeter sensors to continuously monitor potential emissions from the process. The facility has addressed the elements of accident prevention included in these programs throughout its years of operation. The process operators are diligent in adhering to and maintaining the Process Safety/Prevention Program. Emergency Response Program The Greenwood Ammonia Facility 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 and made available to the Local Emergency Planning Committee and the local emergency responders. The operators of the facility are active participants in the Local Emergency Planning Committee and interact with various local agencies in emergency planning. Process operators 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 offsite. Farmlands Greenwood facility has an excellent five-year accident record with no RMP reportable releases. Hazard Assessment Synopsis of worst-case and alternative release scenarios: The hazard assessment element of the RMP rule requires the evaluation of potential offsite effects of "worst-case" and "alternative" release scenarios of regulated substances. 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 tha t 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 the 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 release 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 ni trate 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 liquid, atmospheric pressure storage tank which is passively mitigated by a secondary containment dike. Farmlands hypothetical worst-case scenario involves an anhydrous ammonia release from the facilitys 30,000 ton refrigerated liquid storage tank. As required by the rule, the worst-case release assumes that this entire quantity is released as a result of a catastrophic failure of the tank and subsequently evaporates from the diked pool. This unlikely event was modeled with a publicly available model (DEGADIS) and the resulting end point distance is expected to be conservative. The impact of this release scenario is predicted to extend beyond the facility boundary and impact public receptors. We believe this scenario is a hypothetical worst-case event dictated by the rule and is extremely unlikely to occur for many reasons. In addition to the stringent design controls for this type of storage 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. Alternative 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 in areas where refrigeration, loading and other transport activities occur. Generally, significantly lower quantities are involved due to numerous shutdown safeguards present throughout the facility. Also, operator intervention tends 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 f ailure of a liquid relief valve on the product heater. The valve is assumed to fail and release ammonia for one (1) minute before employee intervention stops the release. The impact of such a release was modeled with the publicly available model (DEGADIS) which shows that the impact of the release would extend offsite under typical ambient conditions. 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. In a formal procedure, conducted at least every five years, the process hazard analysis is updated and revalidated but review is also 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. |