SF Phosphates Limited Company - Executive Summary |
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EXECUTIVE SUMMARY 40 CFR 68.155 states that the owner or operator of a regulated source shall provide an executive summary in their Risk Management Plan (RMP) that includes a brief description of the Risk Management Program elements established under the rule. This Executive Summary is intended to satisfy those requirements. INTRODUCTION SF Phosphates Limited Company (SFP's) Rock Springs Fertilizer manufacturing complex is located approximately 4.5 miles southeast of Rock Springs, WY on Highway 430 in Sweetwater, County. With the exception of a small residential subdivision to the southwest of the plant, the area is undeveloped. This facility manufactures phosphate fertilizer used primarily for agricultural food crops. The facility employs 200 full time staff and operates 24 hours per day, 7 days per week. SFP is a solid and responsible member of the local community. The Company and its employees strive to contribute and improve the community they work and live in through thei r involvement, volunteerism and support of local programs. SFP is committed to protecting the environment and preserving natural resources through the elimination or reduction of toxic substance use, pollution prevention at the source and responsible recycling, treatment and disposal of waste materials. Accidental Release Prevention and Emergency Response Policies: SF Phosphates Limited Company (SFP), Rock Springs Fertilizer Complex, Rock Springs, Wyoming, is committed to being a responsible community partner. Emergency response planning and training of all employees is current and on going. The company fully supports an emergency response team, whose members receive more advanced training. Every reasonable effort is made to prevent a "significant accidental release" to the air from the facility. Local fire departments and local emergency management agencies receive annual Sara Title III reports that give information about materials that are manufactured, stored, and used at the facility. It is SFP's policy to fully cooperate with all inspections and requests for information from all regulatory agencies. Regulated Substances Processed, Stored, or Used: SFP's Rock Springs Fertilizer Complex manufactures phosphate fertilizer products and industrial chemicals. These processes require the use of two substances currently listed in the RMP rule. These substances are anhydrous ammonia used to manufacture fertilizers and chlorine used strictly for water treatment. The Rock Springs complex transfers, stores, and processes anhydrous ammonia and stores chlorine in quantities exceeding the rule applicability threshold limits, therefore requiring the facility to develop a Risk Management Program and submit an RMP. Because these processes and substances are also subject to the OSHA-PSM standard and are not eligible for Program 1, the processes that contain these substances will be regulated as Program 3 processes under the RMP rule. Both of these substances a re regulated as toxic substances. There are no regulated flammable substances above their respective threshold quantity at this facility. Worst-Case and Alternative Release Scenarios: The RMP rule requires facilities containing Program 3 processes to provide a hazard assessment of the potential worst-case and alternative release scenarios involving the regulated substances. The rule requires that a worst-case scenario representative of all toxic substances and an alternative release scenario for each toxic substance be evaluated and reported in the RMP. SFP has evaluated worst-case scenarios involving the largest vessels of anhydrous ammonia and chlorine and has determined that the worst-case scenario is dictated by the catastrophic failure of one of its pressurized storage tanks. This hypothetical release dictated by the rule involves the sudden failure and subsequent release of the contents of one tank, administratively controlled to 161.5 tons, in 10 minutes. This releas e is assumed to occur during worst-case release conditions of low wind speed, stable atmospheric conditions and maximum ambient temperature. Assuming these conditions, the release was evaluated with the publicly available model DEGADIS, which has been demonstrated to provide reasonable estimates of concentrations and distances associated with that type of release. The modeled results indicate that the impact from this hypothetical release will extend offsite, and under certain wind directions, can encompass public receptors. In addition to the extremely unlikely probability of such a hypothetical scenario occurring, SFP has numerous prevention and safety features including elevation of the storage tanks, concrete barriers around all storage tanks, a comprehensive inspection program, pressure relief and emergency shutoff valves and water fog nozzles in place in order to reduce the potential for this scenario. Alternative release scenarios should be modeled and be representative of scenarios that may have occurred or are more likely to occur. The SFP processes regulated under this rule have not had any previous accidental releases, therefore the alternative release scenarios are also based on a hypothetical, although more likely potential release scenarios. The hypothetical anhydrous ammonia alternative release scenario consists of an accidental rupture of an 8-inch diameter overhead transfer pipe due to an impact from a mobile crane. The scenario assumes that the pipe is completely severed, releasing anhydrous ammonia liquefied by pressure for approximately two minutes before the automatic shutoff valves cut off the flow. The contents of the unblocked pipe lengths is assumed to subsequently drain out, prolonging the release slightly. A total quantity of over 45,000 pounds of anhydrous ammonia is estimated to be released. This scenario was also modeled using the DEGADIS model assuming typical meteorological conditions as recorded at the Rock Springs Airport and, conservatively, as a ground level release. The impact of this scenario is predicted to extend offsite and under certain wind conditions, could potentially impact public receptors. This release is highly unlikely to occur due to the general facility accident prevention program requiring all employees to be aware of potential dangers and other prevention steps in-place, such as signs and markings clearly indicating the location of the pipes and warning crane operators of potential danger. The hypothetical alternative release scenario for chlorine is based on the assumption that a 3/4 inch diameter fuse plug on the bottom of a one-ton cylinder fails and the contents of the tank are released, unmitigated. It is estimated that the release would persist approximately 13 minutes. The impact of this scenario, as modeled with the DEGADIS model, is predicted to extend beyond the plant boundary, however, no public receptors would be within the endpoint concentration. This scenario h as never happened at this facility and is also highly unlikely to occur in the future due to SFP's operator training in the use of chlorine cylinder repair kits and safe cylinder handling practices. SFP is also currently evaluating possible replacement chemicals for chlorine, which could be safer to store and use. Although these release scenarios are hypothetical and unlikely to occur, SFP is prepared to respond to any release at the facility through the implementation of its Emergency Response Plan and deployment of the emergency response team, thus minimizing the impact of any release. Accidental Release Prevention Program and Chemical-specific Prevention Steps: The processes and substances regulated by the RMP rule have also been subject to the OSHA-Process Safety Management (PSM) standard for many years. Under the OSHA Program, the facility is required to develop a prevention program, which is equivalent to that required by the Risk Management Program rule. SFP developed and i mplemented the prevention program in accordance with the OSHA-PSM requirements well before the RMP required them to do so. The prevention programs for the covered processes establish a multi-element program and management policies and procedures which when implemented will facilitate the prevention of accidental releases and will minimize any potential release. SFP staff assigned to work on these processes are highly trained in the safe handling of all hazardous materials present at the facility, especially those in the covered processes. Each employee receives initial training and annual refreshers appropriate to the job when hired or when re-assigned. In addition to Training, the following prevention program elements inherent in the Process Safety Management (PSM) program have been implemented in all areas where anhydrous ammonia and chlorine are present. The following elements of PSM decrease the likelihood of a release: (1) Mechanical Integrity is a preventative maintenance pr ogram that assures the structural integrity of process vessels and piping. (2) Hot Work Permits are required to prevent fires in areas where ammonia would be effected. (3) Process Hazard Analyses are performed on all new processes and periodically on existing process that contain ammonia or chlorine. (4) Management of Change procedures are followed in order to help prevent failure due to improper engineering or modifications. (5) Operating Procedures are in place and operators are trained on these procedures. (6) Incident Investigations are done on any accident or near miss to find possible changes that can be made to prevent future incidents. (7) Emergency Response and Planning helps to prepare facility employees to respond to a release of a hazardous material if such an event were to actually occur. (8) Pre-Startup Safety Reviews are done on all new or modified processes. (9) Compliance Audits. An independent contractor will be hired to audit all PSM / RMP programs and sugges t improvements as necessary. This compliance audit will take place by November of 1999. The SFP management and employees are committed to the continued evaluation and improvement of the prevention programs for the processes and strive to operate these processes in the safest manner possible. Five-year Accident History: The RMP rule requires that accidental releases of regulated substances from covered processes which resulted in prescribed onsite or offsite impacts be reported in the Risk Management Plan. The Rock Springs Fertilizer Complex has not had significant accidental releases of ammonia or chlorine with onsite or offsite consequences within the last five years. This is a tribute to the effectiveness of the prevention programs implemented and the operator's dedication to proper process control and adherence to the prevention program. Emergency Response Program: The SFP facility has established an Emergency Response Program, which includes a written Emergency Response Plan in compliance with the RMP rule requirements, and other applicable emergency response programs. At the core of the emergency response program is the Emergency Response Team (ERT) which has been established to respond to facility emergencies. The SFP Emergency Response Team (ERT) is a response team comprised of trained employees. These employees are trained to respond to fires (in their incipient stages), chemical, medical and evacuation/rescue emergencies at the fertilizer complex. Team participants are kept informed and trained as appropriate. The facility's PSM Emergency Response Plan, which has been in effect for years, was modified to incorporate additional information as specified under 40CFR68.95. This single plan includes emergency response telephone numbers as well as instructions to employees on emergency alarm activation, emergency response communication procedures, responsibilities of themselves and emergency response team members, evacuation procedures, on an d off site notification procedures and other relevant information regarding potential releases and emergencies at the facility. The notification procedures themselves were not changed; thus employee training is current. The SFP Emergency Response Plan has been coordinated with local emergency responders and copies of the plan are provided to interested parties. In addition to the facility emergency response capabilities, other emergency responders are available and in the unlikely event of an emergency, their response will be solicited and coordinated as necessary. The Rock Springs Fertilizer Complex is located in Sweetwater County, therefore the following emergency responders have been identified and communication has been established. The Fire District Number One and / or the City of Rock Springs Fire Departments will respond to a fire emergency at the facility. The Sweetwater County emergency management agency and / or the Sweetwater County Sheriff's Department will respond to the site to assist with logistical support as needed in the event of a fire or Hazmat emergency. A local ambulance service will be notified in all cases where advanced medical support is needed on or off site. The SFP staff and process operators' primary objective is to prevent accidental releases of any substance from the facility. However, the facility has expended much effort to assure that in the unlikely and unforeseeable circumstance of a release the proper emergency response mechanisms are in place to act quickly to minimize any release and potential consequences to plant staff, the public and the environment. Continuous Safety Improvement: SF means "SAFETY FIRST" at the Rock Springs Fertilizer Complex. Achieving a "ZERO-INJURY" workplace and protection of our neighbors and the environment are goals of SF Phosphates Limited Company. Safety training is an on-going process. The training consists of new employee orientation, safety/environmental/health training and fund amental skills and process/job specific training. A skill assessment is given to each employee in order to document a level of understanding. Simulated emergency evacuation drills are conducted by the facility's ERT to maintain skills and update the level of knowledge as necessary. The process prevention programs are systematically evaluated and improvements made continuously to enhance the reliability and safety of the process. 1 5 |