Farmers Cooperative Elevator & Supply Co. - Executive Summary |
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The Farmers Cooperative Elevator & Supply Co. P.O. Box 489 Newkirk, OK 74647 For further information contact the General Manager. Risk Management Plan - EXECUTIVE SUMMARY 1. The Facility Policy: The owners, management, and employees of the Farmers Cooperative Elevator & Supply Company of Bender, Oklahoma, are committed to the prevention of any accidental releases of anhydrous ammonia. If an accidental release should occur, the facility is prepared to work with the local fire department, and other authorities, to mitigate any release and minimize the impact of the release to people and the environment. 2. Facility Information: 7 The primary activity at the facility is the storage of fertilizers for sale to farmers. 7 Anhydrous ammonia is received, stored, and distributed for the direct application of fertilizers for crop production nutrients. 7 The maximum quantity stored would be 280,160 pounds in our two-11,000 gallon storage tanks, our one-12,000 gallon storage tank, and our o ne-30,000 gallon storage tank. 3. The worst-case release scenario and the alternative release scenario: a. The worst-case release scenario would be the release of the total contents of a storage tank released as a gas over 10 minutes. The maximum quantity released would be 131,325 pounds, which represents the volume of the largest storage tank at 85 percent capacity as limited by design standards. The distance to the endpoint (point of dispersion to 200 ppm) is 2.41 miles. b. The alternative release scenario based on the most likely potential incident is a release from a break in a transfer hose. The distance to the endpoint (point of dispersion to 200 ppm) is 0.83 miles. 4. The accidental release prevention program: The facility has referred to the provisions of "Safety Requirements for the Storage and Handling of Anhydrous Ammonia, Kk-611.1", published by The American National Standards Institute, Inc., and the standards of the U.S. Occupational Safety and Health Administrat ion (OSHA), 29 CFR 1910.111, "Storage and handling of Anhydrous Ammonia". 5. The Five-year Accident History: a. There have been no accidental releases of anhydrous ammonia in the past five years that: 7 Have caused any deaths, injuries, or significant property damage at the facility; nor 7 To our knowledge, have resulted in offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 6. The Emergency Response Program: The facility has: a. A written Emergency Action Plan, in accordance with OSHA standard, 29 CFR 1910.38; b. Provided state and local authorities the emergency planning and community right-to-know information as required under SARA Title III (EPCRA). c. A written emergency response program, in accordance with OSHA standard 29 CFR 1910.120, including pre-emergency planning and employee training. 7. Planned Changes to Improve Safety: Safety improvement is an on-going process at the facility. Periodic evaluations are perfor med to assess the maintenance of safe conditions. There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. Transok / Custer Gas Plant RMP / Executive Summary A. Accidental Release Prevention and Response Policies The Custer Gas Plant has a commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Transok's policy for the design and operation of gas plants is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, trained personnel will respond to and attempt to control and contain the release. B. Description of the Stationary Source and Regulated Substances Transok operates the Custer Gas Plant located 4 miles north and 3 miles west of Arapaho, Oklahoma in Custer County. The Custer Plant receives natural gas with some condensed hydrocarbon liquids (i.e. condensate) from production wells by pipeline system. The plant separates ethane, propane, butanes, and higher molecular weight hydrocarbon components from natural gas by liquefying them at cryogenic temperatures. The natural gas minus these liquefied components (called "residue gas") is delivered back into the pipeline system for ultimate use as fuel. The natural gas liquids (NGL's or Raw Mix) are sold separately for petrochemical feedstock, fuel, and other uses. The NGL's are delivered into a Koch Company pipeline connected to the plant. The Custer Gas Plant was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, Transok identified the regulated substances and quantities kept on site. The chemicals, largest quantities on site, and associated threshold quantities are presented in Section II - Accident Release Preventio n Program, Table 1. Listed flammable substances, which are stored above threshold quantities at the Custer Gas Plant, are NGL's (product), methane and condensate. However, Transok has determined that condensate has an NFPA rating of 3, which exempts this mixture from threshold determination. There are no listed toxic substances stored above threshold quantities at the Custer Plant. Based on worst-case analysis, the distance to the endpoint exceeds the distance to public receptors. In addition, the Custer Gas Plant is subject to the OSHA Process Safety Management Program (PSM). Therefore, the Custer Gas Plant is classified as a Program 3 process under the Accident Release Program C. Offsite Consequence Analysis Results 1. Worst-Case Releases Flammable Substances The endpoint for a worst-case scenario (WCS) release of a flammable substance is a 1 psi overpressure (i.e., 15.7 psia), resulting from a vapor cloud explosion. The Accidental Release Prevention (ARP) Program req uirement for flammables assumes an instantaneous release and vapor cloud explosion. A yield factor of 10 percent of the available energy released in the explosion shall be used to determine the distance to the explosion endpoint. Since the worst-case release scenario for a flammable substance is based on the assumption that the entire quantity of the substance forms a vapor cloud, passive mitigation systems are not applicable. The worst-case release scenario is from the NGL storage tank (i.e. product surge tank) with an endpoint 1 psi overpressure distance of 0.40 miles. This is based on using the Environmental Protection Agency (EPA) equations found in the "RMP Offsite Consequence Analysis Guidance" dated May 24, 1996. The storage capacity of the largest (& only) NGL storage tank is 40,000 gallons, which is limited to 80% or 32,000 gallons by administrative controls. It assumes the entire contents of the tank (32,000 gallons or 119,607 pounds) is released instantaneously and is involved in the vapor cloud explosion. Toxic Substances The Custer Gas Plant does not have any toxic substances above the threshold quantity; therefore, analysis of worst-case release scenarios for toxic substances is not required. 2. Alternative Releases Alternative releases scenarios are those that are more likely to occur than the worst-case release scenario. Alternative release scenarios for toxic substances should be those that lead to concentrations above the endpoints beyond the facility's fenceline. Alternative release scenarios for flammable substances should have the potential to cause substantial damage, including on-site damage. Flammable Substances A single alternative release scenario for all flammable substances is required under the ARP program. A hypothetical, but likely to occur, release scenario has been identified for NGL's as follows: A 2 inch valve on the 40,000 gallon, 250 psi, product surge tank fails and releases contents undetected for a period o f 30 minutes. This volume released of 30,785 pounds then participates in a vapor cloud explosion resulting in a 1 psi overpressure endpoint distance of 0.25 miles. This is based on EPA equations found in the "RMP Offsite Consequence Analysis Guidance" document. Toxic Substances The Custer Gas Plant does not have any toxic substances held above the threshold quantity. Therefore, analysis of each regulated toxic substance is not required. D. General Accidental Release Prevention Program The following is a summary of the accident prevention program in place at the Custer Gas Plant. The processes at the gas plant are regulated by EPA's Risk Management Program (RMP) regulation. They are also subject to the Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the Accident Release Prevention (APR) Program under EPA's RMP. 1. Emp loyee Participation Active employee participation and involvement in the development and implementation of the Custer Gas Plant's PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of the flammable substances at the plant. Employee involvement will help ensure that all perspectives regarding PSM are considered, and that the best ideas are implemented. Open communications are encouraged between supervisors and employees regarding all safety and health issues. In addition, this is mandated as part of Transok Corporate Policy #SA4 - Employee Participation and is further identified in Section II, Part C of the PSM Manual. The Custer Gas Plant strongly encourages employees to participate in all facets of process safety management and accident prevention. Examples of this include a cross-section of employees and management ad hoc teams participating in: * Process Hazard Analysis * Pre-Startup Safety Reviews * Audits * Operating Procedures Development The Custer Gas Plant also actively seeks employee involvement in the development and conduct of all accident prevention activities through existing safety programs. Accident prevention is discussed at monthly safety meetings and/or during special training sessions if necessary. Employee suggestions on improving safety processes are encouraged at these meetings. Specific ways that employees can be involved in the accident prevention program are also documented in Section II, Part C of the PSM Manual. 2. Process Safety Information Complete and accurate written process safety information (PSI) concerning process chemicals, process technology, and process equipment is essential to an effective PSM and RMP program and to completing and maintaining a process hazard analysis (PHA). The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and tho se in charge of updating the emergency preparedness plans. Process Safety Information is readily available to all employees. The Custer Gas Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. The documents include the PSM Process Hazard Analysis, process flow diagrams, piping & instrument diagrams, vendor data books (equipment specifications & operation), description of process chemistry, inventory of hazardous chemicals, operating manual (upper/lower operating limits, startup, shutdown, etc.) and electrical classification drawings. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS's). The Custer Gas Plant also ensures that operating processes are maintained within limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. See also Section II, Part D of the PSM Manual. 3. Process Hazard Analysis (PHA) The Custer Gas Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Custer Gas Plant primarily uses the "What-if / Checklist" method analysis technique to perform these evaluations. The analyses a re conducted using a team of people who have extensive operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes recommendations for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team recommendations are forwarded to local and corporate management for resolution. The PHA team will ensure that potential accident scenarios with a high risk of imminent danger receive immediate attention. All approved mitigation options in response to PHA team recommendations are tracked until they are completed. The final resolution of each recommendation is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis re sults. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and recommendations from these updates are documented and retained. Once again, the team recommendations are forwarded to management for consideration, and the final resolution of the recommendations is documented and retained. The details of this program are also identified in Section II, Part E of the PSM Manual. 4. Operating Procedures The Custer Gas Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed to determine if they are current and accurate. The pr ocedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities. To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees. Operating procedures are specific instructions or details on what steps are taken or followed in caring out the stated procedures. The specific instructions include the applicable safety precautions and appropriate information on safety implications. See also Section II, Part F of the PSM Manual. 5. Training To complement the written procedures for process operations, the Custer Gas Plant has various training programs available for operations personnel. New employees receive basic training in gas p lant operations. In addition, all operators periodically receive refresher training on operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. New operators are also paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. All of this training is documented for each operator, including the means used to verify that the operator understood the training. See training and certification requirements also in Section II, Part G of the PSM Manual. 6. Contractors The Custer Gas Plant uses contractors to supplement its workforce during periods of increased maintenance or co nstruction activities. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with an orientation session and video that covers (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, Transok evaluates contractor safety programs and performance during the selection of a contractor. Gas plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Detailed contractor orientation and work rules are also identified in Section II, Part H of the PSM Manual. 7. Pre-Startup Safety Reviews (PSSRs) The Custer Gas Plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that Accident Prevention Program requirements are properly implemented. See also Section II, Part I of the PSM Manual 8. Mechanical Integrity The Custer Gas Plant ha s well-established practices and procedures for maintaining process equipment. The basic aspects of this program include: (1) training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting equipment deficiencies, when identified, (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Procedures are in place to ensure that work is performed in a consistent manner. Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is ident ified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Custer Gas Plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper material and spare parts are used when repairs are made. Mechanical integrity procedures are also covered in Section II, Part J of the PSM Manual. 9. Safe Work Practices The Custer Gas Plant has safe work practices in place to help ensure worker and process safety. Examples of these include: (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, ( 3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. See also Section II, Part K "Hot Work Permit" of the PSM Manual. 10. Management of Change The Custer Gas Plant has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, chemicals, technology (including process-operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. The details of the management of change system are also identified in Section II, Part L of the PSM Manual. 11. Incident Investigation The Custer Gas Plant promptly investigates all incidents (no later than 48 hours after incident) that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. See also Section II, Part M of the PSM Manual. 12. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Custer Gas Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. The audit shall be conducted by at least one person knowledgeable in the process. The audit team develops findings that are forwarded to management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. See Section II, Part O of the PSM Manual. 13. Chemical Specific Prevention Steps The processes at the Custer Gas Plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility: Universal Prevention Activities The accident prevention program summarized previously is applied to all RMP-covered processes at the Custer Gas Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The Custer Gas Plant has safety features on many units to help (1) co ntain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes: Release Detection 1. Hydrocarbon detectors with alarms. Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases 2. Valves to permit isolation of the process (manual or automated) 3. Automated shutdown systems for specific process parameters (e.g., high temperature) 4. Curbing or diking to contain liquid releases 5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system) 6. Atmospheric relief devices Release Mitigation 1. Fire suppression and extinguishing systems 2. Deluge system for specific equipment 3. Personnel trained in emergency procedures 4. Personal protective equipment E. Five -Year Accident History The Custer Gas Plant has an excellent record of accident pre vention. Transok acquired the ownership and operation of the plant from ANR in 1998. According to information provided by ANR, and based on Transok's experience operating the plant, there have been no incidents that have had offsite effects in the last five years. F. Emergency Response Program Information The Custer Gas Plant maintains written emergency response procedures, which are in place to protect worker and public safety as well as the environment. The procedures are for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address notification of local emergency response agencies if a release occurs and post incident cleanup and decontamination requirements. Employees receive training in emergency procedures. The emergency response procedure is updated when necessary based on modifications made to plant facilities. The emergency response procedure changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Custer Gas Plant is coordinated with the Custer County, Oklahoma, Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which may include local emergency response officials, local government officials, and industry representatives. The Custer Gas Plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Custer Gas Plant conducts periodic simulated emergency drills in monthly safety meetings. The Spill Prevention Control and Countermeasure (SPCC) Plan for the plant also identifies emergen cy response procedures and notification contacts. G. Planned Changes To Improve Safety The Custer Gas Plant resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned over the next few years in response to PHA, safety audit, and incident investigation findings: * Revisions/enhancements to personnel training programs * Revisions to operating procedures * Revisions/enhancements to contractor safety programs * Revisions/enhancements to mechanical integrity program Custer RMP 10 03/10/99 B-5 The Farmers Cooperative Elevator & Supply Co. P.O. Box 489 Newkirk, OK 74647 For further information contact the General Manager. Risk Management Plan - EXECUTIVE SUMMARY 1. The Facility Policy: The owners, management, and employees of the Farmers Cooperative Elevator & Supply Company of Bender, Oklahoma, are committed to the prevention of any accidental releases of anhydrous ammonia. If an accidental release should occur, the facility is prepared to work with the local fire department, and other authorities, to mitigate any release and minimize the impact of the release to people and the environment. 2. Facility Information: 7 The primary activity at the facility is the storage of fertilizers for sale to farmers. 7 Anhydrous ammonia is received, stored, and distributed for the direct application of fertilizers for crop production nutrients. 7 The maximum quantity stored would be 280,160 pounds in our two-11,000 gallon storage tanks, our one-12,000 gallon storage tank, and our one-30,000 gallon storage tank. 3. The worst-case release scenario and the alternative release scenario: a. The worst-case release scenario would be the release of the total contents of a storage tank released as a gas over 10 minutes. The maximum quantity released would be 131,325 pounds, which represents the volume of the largest storage tank at 85 percent capacity as limited by design standards. The distan ce to the endpoint (point of dispersion to 200 ppm) is 2.41 miles. b. The alternative release scenario based on the most likely potential incident is a release from a break in a transfer hose. The distance to the endpoint (point of dispersion to 200 ppm) is 0.83 miles. 4. The accidental release prevention program: The facility has referred to the provisions of "Safety Requirements for the Storage and Handling of Anhydrous Ammonia, Kk-611.1", published by The American National Standards Institute, Inc., and the standards of the U.S. Occupational Safety and Health Administration (OSHA), 29 CFR 1910.111, "Storage and handling of Anhydrous Ammonia". 5. The Five-year Accident History: a. There have been no accidental releases of anhydrous ammonia in the past five years that: 7 Have caused any deaths, injuries, or significant property damage at the facility; nor 7 To our knowledge, have resulted in offsite deaths, injuries, evacuations, sheltering in place, property damage, or environm ental damage. 6. The Emergency Response Program: The facility has: a. A written Emergency Action Plan, in accordance with OSHA standard, 29 CFR 1910.38; b. Provided state and local authorities the emergency planning and community right-to-know information as required under SARA Title III (EPCRA). c. A written emergency response program, in accordance with OSHA standard 29 CFR 1910.120, including pre-emergency planning and employee training. 7. Planned Changes to Improve Safety: Safety improvement is an on-going process at the facility. Periodic evaluations are performed to assess the maintenance of safe conditions. There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. |