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Farmland Industries, Inc. Pollock Nitrogen Plant

Parent Companies:
Farmland Industries, Inc.
N/A
EPA Facility ID:
100000033082
Other ID:
71467FRMLNABEHA
Facility DUNS:
81642571
Parent Company #1 DUNS:
7129547
Parent Company #2 DUNS:
0

Location:

Address:
737 Abe Hall Road
Pollock, LA 71467
County:
GRANT
Lat / Long:
31.562, -92.392 (Get map)
Method:
Public Land Survey - Section
Description:
Process Unit
Horizonal accuracy:
m
Horizontal reference datum:
Source map scale:

Owner/Operator:

Name:
Farmland Industries, Inc.
Phone:
(318) 765-3574
Address:
P.O.Box 399
Pollock, LA 71467
Foreign Address:

Person responsible for RMP implementation:

Name:
John T. McDaniel
Title:
Plant Manager
Email:

Emergency contact:

Name:
John McDaniel
Title:
Plant Manager
Phone:
(318) 765-3574
24-hour phone:
(318) 765-3574
Ext or PIN:
110
Email:

Other contacts:

Facility (or company) email:
Facility phone:
(318) 765-3574
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Grant Parish LEPC
Full-Time Equivalent Employees:
49
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1120-00003-V0
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 16, 1998
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Anhydrous Ammonia
RMP ID:
21389
CBI claimed:
No
Program Level:
3
NAICS:
Nitrogenous Fertilizer Manufacturing (325311)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
60,000,000
No
Flammable Mixture
00-11-11
31,000
No
Chlorine
7782-50-5
38,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 14, 1999
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
15494

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Anhydrous Ammonia)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
Model used:
Degadis
Release duration (mins):
5549.40
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Anhydrous Ammonia)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
Degadis
Wind speed (meters per sec):
3.30
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Anhydrous Ammonia)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
degadis
Wind speed (meters per sec):
3.30
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Anhydrous Ammonia)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Anhydrous Ammonia)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Anhydrous Ammonia, Nitrogenous Fertilizer Manufacturing (325311)
Prevention Program ID:
11632
Safety Review Date
June 10, 1999, since latest RMP submission
PHA Update Date
May 31, 1999, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Quench System
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
Oct. 7, 1998, since latest RMP submission
Training Review Date
April 7, 1999, since latest RMP submission
Maintenance Review Date
Jan. 15, 1999, since latest RMP submission
Maintenance Inspection Date
Jan. 25, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 8, 1999
Management of Change Review Date
Dec. 2, 1998
Pre-startup Review Date
June 26, 1998
Compliance Audit Date
May 13, 1998
Compliance Audit Change Completion Date
Dec. 1, 1998
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 20, 1998
Hot Work Review Date
Oct. 1, 1997
Contractor Safety Review Date
Jan. 22, 1999, since latest RMP submission
Contractor Safety Eval. Date
Jan. 26, 1999, since latest RMP submission
Anhydrous Ammonia, Nitrogenous Fertilizer Manufacturing (325311)
Prevention Program ID:
11633
Safety Review Date
April 29, 1998, since latest RMP submission
PHA Update Date
July 1, 1995, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
Oct. 7, 1998, since latest RMP submission
Training Review Date
April 7, 1999, since latest RMP submission
Maintenance Review Date
Jan. 15, 1999, since latest RMP submission
Maintenance Inspection Date
July 1, 1998, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 8, 1999
Management of Change Review Date
Dec. 2, 1998
Pre-startup Review Date
June 26, 1998
Compliance Audit Date
May 13, 1998
Compliance Audit Change Completion Date
Dec. 1, 1998
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 20, 1998
Hot Work Review Date
Oct. 1, 1997
Contractor Safety Review Date
Nov. 1, 1997, since latest RMP submission
Contractor Safety Eval. Date
Jan. 26, 1999, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
June 17, 1999
Local Response Agency:
Local Response Agency Phone:
(318) 627-3041
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

3133 LDEQ Facility ID Number
Risk Management Plan

Executive Summary

Farmland Industries, Inc.
Pollock Nitrogen Plant
737 Abe Hall Road

Pollock, Louisiana



Farmland's Pollock, La., nitrogen manufacturing facility is
located on 300 acres in central Louisiana's Grant Parish. The
plant primarily manufactures anhydrous ammonia that helps provide
Farmland's 600,000 producer-members with high-quality,
cost-effective nutrients for the crops they grow to feed families
around the world. As a nitrogen fertilizer manufacturing
operation, this facility is subject to the Environmental
Protection Agencies Risk Management Program rules under the Clean
Air Act Amendments of 1990.

The Risk Management Program rules require for facilities handling
threshold amounts of certain chemical substances to submit Risk
Management Plans for the prevention of accidental releases of
these substances. The plan requirements include submission of the
risk management plan to include hazard assessments defining
possible offsite impacts of certain regulated substance release
scenarios, a five-year accident history, description of the
facilities accidental release prevention program, and an
emergency response program.

The following is the Executive Summary of the Risk Management
Plan for Farmland Industries, Inc., Pollock Nitrogen Plant at
Pollock, Louisiana.

Facility snapshot

Nearly eight million tons of ammonia have been produced at the
Pollock facility since it began production in the spring of 1977.
It was the last ammonia facility built by Farmland in the United
States and the first Farmland ammonia facility to have its own
captive natural gas supply - ensuring a dependable supply during
uncertain times in the gas industry.

Impact on the community

7 Farmland employs 49
central Louisiana residents at a
combined annual salary of approximately $3 million dollars.

7 Farmland supports Grant Parish and the state of Louisiana
with nearly $1 million dollars in state and local taxes annually.

7 Approximately $3 million dollars is spent locally on
electricity and miscellaneous purchases for the facility
annually.

7 Natural Gas in an integral part of ammonia production and
the facility spends about $40 million dollars annually on the
natural gas it uses for processing and fuel.

7 Farmland is a member company of the Louisiana Chemical
Association and Louisiana Ammonia Producers.

Employee snapshot

Farmland employees are very involved in community activities.
Many facility employees are active and hold key positions in
public and community groups. These positions include school board
members, constable, Justice of the Peace, Pollock Chamber of
Commerce, Pollock City Council, Grant Economic Development
District, District 5 Volunteer Fire Department, Grant Parish
Local Emergency Planning Committee and Rotary Club.

Farmland employees recognize that community involvement and
volunteerism is the most effective way to improve the communities
in which they live.

Pollution Prevention Policy

Farmland Industries Inc., is committed to protecting our
environment and preserving our natural resources for future
generations. We pledge 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 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 o
f our products and services, maintain a safe and
healthful workplace and improve the environment.

Stationary Source and Regulated Substances

The Pollock Nitrogen Plant is a nitrogen fertilizer manufacturing
facility consisting of a large scale, natural gas feed ammonia
production unit. The anhydrous ammonia produced is used primarily
as an agricultural fertilizer. A carbon dioxide production
facility is also a part of the facility operation.

Initial operation of the facility began in 1977.

The facility produces, handles, and stores large quantities of
anhydrous ammonia in its operations. It uses natural gas, air,
and water for the production of ammonia.

The ammonia plant, along with product ammonia storage and
handling, constitute the processes covered by the EPA Risk
Management Program rule. The primary regulated substance is the
anhydrous ammonia product. In addition, flammable substances as a
class, and methane (natural gas) and hydrogen produced as an
intermediate in ammonia production specifically, are regulated
under Risk Management. Finally, chlorine is also present in
regulated threshold quantities on the site. It is used as a water
treatment chemical in the cooling water systems associated with
the production units.

Accidental Release Prevention and Emergency Response Policy

The management and employees of this facility are committed to
the prevention of any accidental releases from this facility. It
is this facilities policy to eliminate significant accidental
releases of any substance and, in particular, hazardous and
regulated substances; and to minimize and eliminate to the extent
possible even minor and inconsequential releases of any type.
Prevention of accidental releases is critical to the safe
operation of this plant, to the safety of its employees, and to
the safety of the general public.

To achieve its goals of accident and accidental release
prevent
ion, the facility is committed to the following:

7 A knowledgeable and 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
where appropriate
7 Excellence in safety programs and practices and a superior
safety and accident record
7 Preparation and training for emergency response and
mitigation

The Pollock Nitrogen Plant has had a written Emergency Response
Plan in effect for many years and is committed to respond to and
mitigate any accidental release to minimize the impact to
employees, the community, and environment. The response plan is
coordinated with the Local Emergency Response Committee and
emergency response agencies and the plant has interacted with
possible responding agencies for many years regarding the plan
and activities at the plant. Employees are trained in the
implementation of the plan and in possible response activities
that could be required in the event of an emergency.

Prevention Program

The Pollock Nitrogen Plant is subject to the OSHA Process Safety
Management rule, 29CFRI910.119, and is a nitrogen fertilizer
manufacturing facility. Therefore, under the EPA Risk Management
Rule the plant is a Program 3 facility with a Program 3
Prevention Program.

The OSHA Process Safety Management/EPA Prevention Program
consists of a set of facility management policies and procedures
which promotes and recognizes process safety and the prevention
of accidents in plants that handle, use, store, and process
hazardous chemical materials. The procedures address all aspects
of plant activities including training, maintenance, operating
procedures, process reviews, critical information maintenance and
updating, safe work practices, incident investigation, audit, 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 Pollock Nitrogen Plant adheres to the requirements of Process
Safety Management and has written policies and procedures
addressing all aspects of Process Safety Management and EPA
Prevention Programs. In all of its years of operation, the
facility has addressed the elements of accident prevention
included in these programs.

The Prevention Program consists of several elements and policies
which are briefly outlined below.

7 Employee Participation-Employees are involved in all aspects
of the program and are provided any information developed in the
program. Employees participate in process reviews, assist with
development of procedures, and all other aspects of the program.

7 Process Safety Information--All necessary process
information and records are maintained including information on
the hazards of the chemicals, process technology with safe
operating limits, and equipment records and design requirements

7 Process Hazard Analysis--Process hazard analysis and review
has been conducted by employee teams to identify and correct any
perceived hazards. These reviews are updated on a schedule or
more often if changes indicate the necessity of additional
review.

7 Operating Procedures--Operating procedures are in place for
all aspects of operation including emergency operation and
shutdown, operating limits and methods to correct or avoid
deviations from limits, safety and health considerations of
operations and the chemicals involved, and safety system
operation and function.

7 Operating Training--All operators are trained initially in
the process and its operating procedures and receive refresher
training not less than every three years. In reality, operator
training is a continual and ongoing process. Operator training
includes on the job train
ing with experienced operators and
classroom type instruction.

7 Contractors-Contractor selection includes review of safety
performance and programs. Contractors are oriented to known
hazards in the facility, the emergency plan, and are required to
adhere to facility safe work practice procedures. Contractor
performance is periodically evaluated as necessary to assure work
is completed in a safe and correct manner.

7 Pre-startup Safety Review-A safety review is conducted on
any new facility and for any significant modification of the
facility to assure 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.

7 Mechanical Integrity-Procedures for inspection and testing
and correction of equipment deficiencies are in place. A quality
assurance procedure assures 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.

7 Safe Work Practices-Procedures and policies for work permits
and maintenance and operating actions are in place for accident
prevention.

7 Management of Change-No changes are allowed in the process
or procedures without review and authorization. Safety impacts,
technical basis, required procedure modification, and training
are all considered in the review. The procedure is to assure the
safety of the change and to prevent unintended consequences as a
result of change.

7 Incident Investigation-Any incident which results in a
significant release or could have reasonably resulted in such a
release is promptly investigated by a facility team. Findings of
the investigation and recommendations for corrective action are

documented as are the resolution of the recommendations and
corrective actions.

7 Emergency Planning and Response-The Process Safety
Management/Prevention Program includes the facility Emergency
Response Plan.

7 Compliance Audit-Compliance with the program is audited at
least every three years to verify compliance with these
procedures. Findings, if any, of the audit are documented and any
deficiencies are corrected and documented. The audit is conducted
by persons knowledgeable of the facility processes, but not
directly connected with the facility.

The facility is diligent in adhering to and maintaining its
Process Safety/Prevention Program.

Emergency Response Plan

The Pollock Nitrogen Plant has a written Emergency Response
Program as required by the Risk Management Plan rule and other
Environmental Protection Agency and OSHA rules. 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 other appropriate
agencies such as the local fire department.

The facility is an active participant in the Local Emergency
Planning Committee and interacts with various local agencies in
its emergency planning such as local fire departments; law
enforcement agencies such as the State Police, sheriff s office
and ambulance services.

Employees receive annual training in the response plan and also
receive various safety training, both in general, and in the
competencies relative to their required roles in the plan.
Periodically, the plan is practiced in a table top, classroom
type setting, and it also is drilled in mock emergencies
including participation by outside responding agencies.

5-Year Acc
ident History

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 offsite deaths, injuries, evacuations, sheltering
in place, property damage, or environmental damage.

The Pollock Nitrogen Plant has had no qualifying accidents in the
past five years.

Synopsis of Worst and Alternate Case Release Scenarios

The Risk Management Plan rule requires a hazard analysis for
worst case and alternate case accidental release scenarios for
regulated substances present in threshold quantities at the site.
For this facility, the regulated substances include anhydrous
ammonia and chlorine as regulated toxics, and flammables as a
class which include methane and hydrogen. The rule requires an
analysis of the worst case toxic as that scenario affecting the
greatest distance and a worst case flammable accident as a vapor
cloud explosion. Alternate scenarios, which are more reasonably
likely events, for each regulated toxic and flammables in general
must also be presented.

Worst Case Toxic Release-Anhydrous Ammonia

Because of the seasonal nature of fertilizer use and application
in agriculture, large quantities of the ammonia produced at this
facility must be stored until needed by the ultimate consumer.
The RMP rule requires that the largest amount in a single vessel
be considered the release quantity for the worst case event
unless smaller quantities handled at different conditions result
in a greater distance to the regulated endpoint of consideration.
This is a requirement of the rule regardless of whether the event
is likely, or, could even reasonably occur.

For this facility, the largest single quantity of anhydrous
ammonia is held in the atmospheric storage tank. This quantity
totals 30,000 tons. The worst case release assumes, as required
by the rule, that this entir
e amount is released as a result of a
catastrophic failure of a tank. This unlikely event was modeled
by a publicly available model (DEGADIS) which is known to provide
reasonable estimates of concentrations and distances associated
with release events. By using the worst case conditions of
ambient temperature, humidity and wind speed for this area (as
required by the regulation), the model results determine an
ammonia concentration of 200 parts per million (ppm) could result
as far away as 2.61 miles from the plant.
To assure that the event indicated above was, in fact, the worst
case as the rule defines it; failure of ammonia storage present
at the site where ammonia is stored at higher pressure, but much
lower quantities was also modeled. In addition, a worst case
failure of chlorine containers was similarly modeled. Neither of
these resulted in a distance greater than the circumstance noted
above.

It should be emphasized that the possibility of such an event as
described by the worst case is so low as to be non-existent. Many
identical and similar tanks are in existence all over the world
and have been in service for many years. We are aware of no such
failure of these tanks nor, even, lesser failures of a nature
that would provide for an accidental release of quantities even
orders of magnitude less than indicated above. Analysis of this
scenario is required by the rule, and, as such, was completed.
Facility maintenance and inspection programs address the
integrity of process and storage vessels, including these, and
largely preclude such massive and unlikely failures.

Worst Case Flammable

As the rule requires, the largest quantity flammable release and
a subsequent vapor cloud explosion must be analyzed as the worst
case for these substances. In this facility, a failure releasing
the entire contents of the ammonia conversion loop constitutes
the largest flammable release. This quantity is assumed to r
esult
in a vapor cloud explosion with impact distance of 0.16
miles (855 feet) as determined by the EPA Offsite Consequence
Analysis Look up Tables. Although large volumes of flammable
gases are handled daily by the plant, actual in-process inventory
is relatively small. Impact distance is relatively limited as a
result.

Alternate Case Toxics

Ammonia

A more reasonable release event tends to concentrate in areas
where the ammonia product is handled such as loading and other
transport activities. Significantly lower quantities are
involved, various shutdown safeguards are present as they are
through out the plant, and operator intervention all tend to
mitigate and limit the consequences of failures. Such events can
include failure of smaller valves, lines, and hoses.

The alternate release scenario, modeled with the DEGADIS model
for this facility is the breaking off of a one inch pipe
connected to the ammonia pipeline injection pump releasing 6.65
tons of ammonia. The DEGADIS model results for this alternative
case determined an ammonia concentration of 200 ppm could result
as far away a 0.97 mile distance from the plant. Modeled impact
distance is substantially lower for more reasonable, but not
necessarily likely, release events.




Chlorine

Chlorine is used at several locations in this plant as a biocidal
agent for cooling water systems, much as it is also used in
swimming pools. It is used as a gas from one ton chlorine
cylinders through an injection system to the circulating cooling
water.

The alternate release scenario assumed is failure of the
connecting tubing from the cylinder and release of gaseous
chlorine. This release was modeled using the DEGADIS dispersion
program. Results for this alternate case determined a chlorine
concentration of 3 ppm could result as far away as 0.43 mile from
the plant.

Flammables

Large volumes of flammable gases
are handled throughout the
plant, even though actual physical inventory is relatively low.
More likely flammable release events include failures of smaller
pipes and lines in comparison to the large release contemplated
in the worst case analysis.

The impact distance of this event utilized the EPA Offsite
Consequence Analysis Look Up Tables. Most more reasonable and
likely events result in minimal impact distances.

Planned Changes for Safely Improvements

Safety improvements are a continual and ongoing process at the
facility which is facilitated by the Prevention Program/Process
Safety Management Program. Formal process hazard analysis is
conducted at least every five years, but review is 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.