FLORENCE - Executive Summary |
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Executive Summary Royster-Clark AgriBusiness Florence, AL A. Introduction The Royster-Clark Florence plant is an ammoniated fertilizer production facility that unloads anhydrous ammonia rail tankcars into a storage tank and 44.8% nitrogen solution (25% aqua ammonia) tank trucks into a storage tank. The ammonia and ammonia solution are then used in the production of fertilizers. The facility has been in operation since 1909. Royster-Clark Florence Plant, has an excellent safety record with no deaths or serious injuries to plant personnel or contractors due to the RMP covered process. The facility safety record is a direct result of much emphasis on safety in the plant on the part of management and employees. B. Accidental Release Prevention Policies and Program: The facility is in compliance with OSHA PSM Standards. Information for P&ID drawings, operations procedures, Management of Change (MOC) documents, and other pertinent documents are on file at the plant office. The F lorence, Al. EHS Administrator furnishes technical assistance and performs safety and environmental audits and training on a regular basis. The ammonia tanks and associated equipment are covered by a mechanical integrity inspection and testing schedule and are constantly monitored. Safety meetings for all employees are held at the facility. In addition, to safety training classes, each employee has taken numerous computer based safety training courses. All supervisory positions, ammonia operators and Hazmat employees are certified in First Aid and CPR. The Royster-Clark management personnel are actively involved in promoting safety and environmental awareness in the community through participation with the LEPC and coordination with the Fire Department. Royster-Clark believes safety and concerns for the environment must be second nature to all employees and contractor personnel. C. Emergency Response Policies and Program: The Royster-Clark Florence, Al. granulation facility e mployees are trained to be familiar with the Emergency Response policies and procedures through safety reviews and other plant safety meetings. All plant personnel have received eight hours of awareness level training as directed by 29 CFR 1910.120. The Emergency Response Plan is reviewed on an annual basis as part of the employee safety meetings to ensure refresher training. Safety policies and procedures are also reviewed on an annual basis or more often if required. These policies and procedures are also revised to stay in compliance with changing government regulations The Emergency Response Plan is followed in the event of an emergency. Included in this plan is the testing of the emergency system each month. Local LEPC and Florence, Al. Fire Department personnel are furnished a copy of the Emergency Response Plan and invited to tour the facility on a regular basis. The facility Emergency Response Plan covers such things as accidental releases of plant chemicals, natural di sasters, and emergency response practices and procedures. The plan is reviewed each year with all employees and reviewed with the local fire department on a regular basis. The Florence, Al. facility maintains a Hazardous Materials Response Team whose duty is to respond to chemical emergencies at the plant and are also trained as Confined Space Rescue Personnel. The Hazardous Materials Response Team is a volunteer group and has received an initial forty hour training with eight hours of refresher training annually. The Hazardous Materials Response Team has coordinated training with the local fire department on several occasions. D. Worst Case Scenario: The facility has one 30,000 gallon anhydrous ammonia storage tank on site. The tank is equipped with four safety relief valves to prevent overpressure. The EPA requires a very conservative worst case scenario to be a catastrophic rupture of that tank with a complete loss of product over 10 minutes. It should be noted that the EPA describes the worst-case scenario as: "Because the assumptions required for the worst-case analysis are very conservative, the results likely will be very conservative...These endpoints are concentrations below which it is believed nearly all individuals could be exposed for one half hour to one hour without any serious health effects. In addition, the worst case analysis is carried out using very conservative assumptions about weather and release conditions. The distance to the endpoint estimated under worst-case conditions should not be considered a zone in which the public would likely be in danger; instead, it is intended to provide an estimate of the maximum possible area that might be affected in the unlikely event of catastrophic conditions." (EPA550-B-98-003, Section4.2) Royster-Clark, Florence, used the results of The Fertilizer Institute's (TFI) Degadis Model. Because of past operating experience, visual inspections performed on the tanks and operations training Royste r-Clark believes the chances for a catastrophic rupture is extremely unlikely. E. Alternative-case Scenario Ammonia: The ammonia tank is filled via railcars. The most likely release scenario would be a rupture of a transfer hose. Railcars are unloaded on a frequency of approximately one every two weeks. The conditions chosen for the alternative scenario are those which would create a maximum amount of anhydrous ammonia lost to the environment. F. Alternative-case Scenario 44.8% nitrogen solution: The 44.8% nitrogen solution tank is filled via tank trucks. The most likely release scenario would be a rupture of a transfer hose. Tank trucks are unloaded on a frequency of approximately 8 per week. The conditions chosen for the alternative scenario are those which would create a maximum amount of 44.8% nitrogen solution lost to the environment. G. Five Year Accident History: Royster-Clark, Florence, has an excellent safety record with no deaths or serious injuries to any of it s personnel or contractors as a result of the RMP covered process. In addition, there have been no accidents resulting in releases of ammonia with off site consequences. Extensive programs and procedures are in place to maintain that record. H. Planned Changes to Improve Safety: The Florence plant continuously looks for ways to enhance the safety of the plant. Monthly safety inspections are conducted which result in corrective actions; Process Safety Management audits are conducted every three years; along with, annual Royster-Clark reviews conducted by the environmental health and safety department. I. Summary: The employees of Royster-Clark are extremely proud of its safety record and the vast improvements in both safety and environmental efforts made over the last twenty years. We believe that with the programs and policies in place, and the continued efforts of 100% of our personnel, we will be able to maintain our safety record and a safe plant environment for all concern ed in the years ahead. |