MT. STERLING - Executive Summary |
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Executive Summary Royster-Clark Agribusiness Mt. Sterling, OH A. Introduction The Royster-Clark Agribusiness, Mt. Sterling plant is an ammonium polyphosphate liquid fertilizer production facility. The facility unloads ammonia railcars and trucks into storage tanks. The ammonia is then used in the production of ammonium polyphosphate liquid fertilizer. The facility has been in operation since 1976. Royster-Clark Agribusiness, Mt. Sterling Plant has an excellent safety record with no deaths or serious injuries to plant personnel or contractors due to RMP covered process. The facility's 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 including piping and instrumentation diagrams (P&ID's), operating procedures, management of change (MOC) documentation, and other pertinent documents are on file in the plant office. The Royster-Clark Agribusiness Technical Services staff furnishes assistance and performs safety and environmental audits. Additionally, the Royster-Clark Agribusiness Safety Coordinator performs safety training on a regular basis. The ammonia tanks and associated equipment is covered by a mechanical integrity inspection and testing schedule and is 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 training courses. The Ohio Department of Agriculture annually inspects the ammonia tanks, safety devices, and safety equipment. Royster-Clark Agribusiness believes safety and concerns for the environment must be second nature to all employees and contractor personnel. C. Emergency Response Policies and Program: Each Royster-Clark Agribusiness facility employee is trained to be familiar with the Emergency Response policies and procedu res through safety reviews and other plant safety meetings. The Emergency Action Plan is reviewed on an annual basis as part of the employee meeting to provide refresher training. Safety policies and procedures are also reviewed on an annual basis. Local LEPC and Mt. Sterling Fire Department personnel are furnished a copy of the Emergency Action Plan and invited to tour the facility on a regular basis. The facility Emergency Action Plan covers such things as accidental releases of plant chemicals, natural disasters, emergency response practices and procedures, and process safety topics. The plan is reviewed each year with all employees and reviewed with the local fire department on a regular basis. The Royster-Clark Agribusiness Cook Station facility maintains a Hazardous Materials Response Team member whose duty is to respond to emergencies at the plant. The response team member has undergone extensive training in Hazardous Materials Response and can respond quickly to the faci lity. D. Worst Case Scenario: The facility has three anhydrous ammonia storage tanks on site. Two tanks are equipped with four safety relief valves, and one with five safety relief valves. The EPA requires a very conservative worst case scenario to be a catastrophic rupture of the largest 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; in stead, 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 Agribusiness believes the chances for a catastrophic rupture are extremely unlikely because of the routine testing, in-plant safety systems, daily inspections, and constant monitoring. E. Alternative-case Scenario: The ammonia tanks are filled via railcars and trucks. The most likely release scenario would be a rupture of a hose connecting the railcar or truck and ammonia unloading system. Railcars are unloaded on a frequency of three per month. Trucks are unloaded on a frequency of approximately fifteen per year. The conditions picked for this scenario are those which would create a maximum loss of anhydrous ammonia. F. Five Year Accident History: Royster-Clark Agribusiness, Mt. Sterling, has an excellent safety record with no deaths or serious injuries to any of its 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 during the entire operations period. The Mt. Sterling Manufacturing Plant was presented with a Safety Award for 1998 for No OSHA Recordable Incidents. Extensive programs and procedures are in place to maintain that record. G. Recent Changes and Improvements: In years past, the Mt. Sterling Manufacturing Plant has received nuisance odor complaints. In 1996, Royster-Clark Agribusiness voluntarily redesigned the Mt. Sterling Plant to eliminate this problem. A totally new design was adopted; new equipment was installed; and subsequent environmental control was assured with the performance of a stack test. As of this date, no more nuisance odor complaints have been made. As a result, our relationship with neighbors and community has improved greatly. H. Planned Changes to Improve Safety: The Mt. Sterling plant contin uously 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; and corporate-sponsored environmental, health, and safety audits are conducted annually. I. Summary: The employees of Royster-Clark are extremely proud of our safety record and vast improvements made in both environmental stewardship and safety over the last twenty years. We believe, with our programs and policies in place and with the continued efforts of our personnel, we will maintain our safety record and our safe plant environment for the public, our customers, and our employees for years to come |