HARTSVILLE - Executive Summary

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Executive Summary 
Royster-Clark Agribusiness 
Hartsville, SC 
A.    Introduction 
The Royster-Clark Hartsville plant is an ammoniated fertilizer production facility that either unloads 44.8% nitrogen solution (25% aqua ammonia) railcars into storage tanks or uses it directly from the railcar.  The nitrogen solution is then used in the production of granular ammoniated fertilizers.  The facility has been in operation since the 1920's and started as a pulverized fertilizer plant.  The original plant, built by Hartsville Fertilizer Company, was purchased by International Agricultural Corporation (IAC) in 1931.  In 1944 a fire destroyed the plant.  The plant was rebuilt and started production in 1946. In the same year the IAC Company name was changed to International Minerals and Chemical Corporation (IMC Corp.).  In 1965 the granulation unit was built and put into production.  On July 1, 1987, the facility was deeded to IMC Fertilizer, Inc., which became IMC AgriBusiness on March 7, 1996.   
Finally, IMC AgriBusiness was purchased by Royster-Clark, Inc. on April 1, 1999.  The plant has manufactured ROP superphosphate since its inception and still does so today.     
The plant site consists of 38  acres of land.  The plant currently employs 50 people and maintains three shifts, which work five to seven days per week, depending on production demands.  
Royster-Clark Hartsville 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 working toward compliance of the RMP standard and will be in full compliance by the June 21, 1999 deadline.  Information for P&ID drawings, operations procedures, Management of Change (MOC) documents, and other pertinent documents are on file at the plant office.   Th 
e Hartsville, SC EHS administrator furnishes technical assistance and performs safety and environmental audits and training on a regular basis. 
The solution 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 safety training courses. All supervisory positions 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 Hartsville granulation facility employees are trained t 
o 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 the Hartsville Fire Department personnel are furnished a copy of the Emergency Response Plan and invited to tour the facility and participate in response drills on a regular basis. 
The facility Emergency Response Plan covers such things as accidental releases of plant chemica 
ls, natural disasters, and emergency response practices and procedures.  The plan is reviewed annually with all employees as well as with the local fire department.  
The Hartsville facility maintains a Hazardous Materials Response Team whose duty is to respond to chemical emergencies at the plant.  The team members 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 two 448 ammonia solution storage tanks on site. The tanks are within a containment area capable of containing 110% of the largest storage tank.  
The EPA requires a very conservative worst case scenario to be a catastrophic rupture of that tank with a complete loss of product.  
It should be noted that the EPA d 
escribes 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 Hartsville used the results of the RMP Comp model, which is recognized, accepted, and approved by EPA. 
Because of past operating experience, visual inspections performed on the tanks and oper 
ations training, Royster-Clark believes the chances for a catastrophic rupture is extremely unlikely. 
F.    Alternative-case Scenario 44.8% nitrogen solution: 
The 44.8% nitrogen solution tanks are filled via railcars.   The most likely release scenario would be a rupture of a transfer hose.  Railcars are unloaded on a frequency of approximately 2 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, Hartsville, 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. Extensive programs and procedures are in place to maintain that record. 
H.    Planned Changes to Improve Safety: 
The Hartsville plant continuously looks for ways to enhance the safety 
of the plant.  Plant personnel inspect the plant monthly, and the environmental, health and safety department conducts an annual Royster-Clark review. 
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 concerned in the years ahead.
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