PHIBRO-TECH, INC. - Executive Summary
Phibro-Tech, Inc. is committed to the safety and well-being of its employees, neighboring community, and the environment. Our products include etchants for the Printed Wire Board (PWB) industry and copper sulfate for the animal feed industry. Our products provide an important need for our world today. In the production of these products it is necessary for us to use Anhydrous Ammonia. Phibro-Tech's policy is to implement reasonable measures to prevent a release of hazardous material from occuring, to provide early detection of a release in the unlikely event that one would occur, and to have in place a contingency plan to respond promptly yet safely to such a release.
The Risk Management Plan has been prepared to address the handling of the following regulated substance at the Phibro_Tech, Inc. facility located at 1000 N. First Street, Garland Texas 75040.
Anhydrous Ammonia is stored in a 12000 gallon (water) tank. The tank
is periodically filled by experienced Anhydrous Ammonia Manufacturer's Delivery Truck Drivers as needed. Anhydrous Ammonia is used in the recycling of used PWB etchants and in the production of fresh etchant. No repackaging takes place.
WORST CASE & ALTERNATE SCENARIOS
The Environmental Protection Agency (EPA) has defined the Worst Case Scenario as the hypothetical rupture and full release of all contents of the facilities largest storage vessel in ten minutes, assuming all safeguards have failed, during extremely stable weather conditions. Our scenario would involve our 12000 gallon (water) tank filled to 85%. The EPA has also specified in the RMP rule that each facility must define a specific Alternate or Realistic Scenario that could also have off-site impact, based on plant operations. The Realistic Scenarios are to be modeled using the actual active and passive mitigation systems that are in place if they are capable of withstanding the event that triggered the release, duri
ng typical weather conditions. The realistic scenario selected and modeled for anhydrous ammonia was the release that would result from a rupture in the 1-inch schedule 80 pipe network leading from the ammonia tank. This scenario has an offsite impact.
ACCIDENTAL RELEASE PREVENTION PROGRAM
Phibro-Tech, Inc. has a comprehensive release prevention program in accordance with the Federal RMP Prevention Program and OSHA Process Safety Management (PSM) requirements. We have in place, physical safeguards to prevent a release of anhydrous ammonia. We also follow best industry practices for the design and construction of equipment, piping and instrumentation. Our process design includes pressure relief valves and excess flow valving to safeguard against overpressure and pipeline rupture and/or excessive flow.
FIVE YEAR RELEASE HISTORY
There has been NO release of anhydrous ammonia in the five years prior to the submittal date of this program.
Phibro-Tech, Inc. has a comp
rehensive emergency response program that includes the installation of excess flow valving with alarms and remote shut-off and alarm.
Phibro-Tech, Inc. recently replaced the valves and piping coming off the anhydrous ammonia tank. The following additional steps have been made or are being studied to improve safety:
- Water Deluge System to mitigate evaporation of release.
- Containment Structure for the capture of response water.
- Installation of a Scrubbing System to halt and/or mitigate a release.
- Revision of procedures to incorporate addtitional safety requirements.
We are aware and sensitive to the "year 2000" software issue. Our process equipment has been surveyed for compliance with good results. There were no concerns identified.