WSA, Inc. dba PCS Phosphate - White Springs - Executive Summary

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This Executive Summary for the Risk Management Program conforms to 40CFR68.155 through 68.185. Referenced documents, such as the Comprehensive Emergency Management Plan, Process Safety Management Plan, and SPCC plans are maintained at the facility and are available for inspection. 
Prevention and Emergency Response Policies 
The PCS Phosphate - White Springs policy is to provide a safe work environment for all employees, contractors, visitors and neighbors. This policy includes prevention of accidental releases through the use of initial design to recognized standards, preventive maintenance programs, testing, calibrations, routine maintenance, inspections, replacement of equipment as necessary, and training of personnel. A work order system is in place for employees to formally report deficiencies and track progress until completed. 
It is PCS Phosphate - White Springs' policy to operate in an environmentally responsible manner consistent with environmental knowledge, policies, and re 
gulations. Operations of the facility are designed so as not to adversely affect the environment of the surrounding area during normal operating periods or emergency situations. 
The goal of PCS Phosphate - White Springs is to prevent emergencies from ever occurring. However, should an event occur, the immediate goal is to keep the emergency and its effects within facility boundaries and not allow it to present a threat to the health and safety of the general public. All procedures will be carried out in a manner to minimize risk to employees and emergency response personnel. Rescue and medical activities have priority over all other actions. 
It is the emergency response policy of PCS Phosphate - White Springs to immediately notify Hamilton County authorities, the LEPC, the State Emergency Response Commission, and the National Response Center of a release of anhydrous ammonia that exceeds the reportable quantity. PCS Phosphate - White Springs employees will mitigate or contain the rel 
ease and assist in the provision of emergency medical treatment for any injured personnel. 
Description of the Facility 
The White Springs facility employs about 1200 people. Phosphate rock mining takes places within a project area of over 100,000 acres or about 160 square miles. The Hamilton County Mine, located just off US 41 approximately eight miles north of White Springs, produces nearly four million tons of phosphate rock each year. This rock is used at the two chemical plants to produce various phosphate products. The Swift Creek Chemical Plant is located on US 41 adjacent to the Hamilton County Mine. The Suwannee River Chemical Plant is located on County Road 137, approximately six miles north of White Springs. 
Both chemical plants produce sulfuric acid. The sulfuric acid is produced by burning sulfur in special furnaces. The sulfur is delivered in railroad tank cars. Sulfur may also be delivered by truck. The sulfuric acid is reacted with the phosphate rock to produce phospho 
ric acid. A byproduct of this reaction is gypsum. 
The two chemical plants produce a variety of products. These include sulfuric acid, concentrated phosphoric acids, diammonium phosphate (DAP), Monocalcium Phosphate (Monocal), Dicalcium Phosphate (Dical), and Defluorinated Phosphate (DFP). DAP is used as an ingredient in fertilizer. Monocal, Dical, and DFP are used as animal feed supplements. The sulfuric acid and the phosphoric acid are used as ingredients in producing these other products. 
Anhydrous ammonia is delivered to the White Springs facility by railcar. It is stored in spheres or "bullets" (tanks). The two spheres are each capable of storing 2,300 tons of anhydrous ammonia. Inventory in the two spheres is maintained, through administrative controls, at 1150 tons each. Maintaining the storage at fifty percent of capacity allows for movement of ammonia from one tank to another in an emergency. It also limits the amount of ammonia stored to the minimum amount necessary for our  
operation. The two bullets are each capable of storing 170 tons of anhydrous ammonia. Safety features in the storage area include relief valves and excess flow valves on the spheres and tanks, ammonia sensors and alarms, and a shut-off valve system to stop transfers of ammonia if preset conditions are exceeded. These valves will fail-closed in the event of a power failure. The anhydrous ammonia is transferred from railcars to the storage area using specially designed piping, and pumps. Safety features in the railcar unloading area include: 
An emergency shut-off valve system (which fails closed in case power is lost) activated by any of six switches located strategically throughout the area, 
Excess flow valves in case of line failure, 
Area ammonia sensors and alarms, 
Video monitoring systems, and 
Railcar derailers to protect cars connected for unloading. 
Because of its isolated location the facility has its own medical clinic, fire response team, hazardous materials response team, res 
cue team and medical response team. 
Worst Case and Alternate Case Scenarios 
Both scenarios were developed using the DEGADIS model. The DEGADIS model is listed in 40 CFR Part 51, Appendix W as an EPA Guideline Model. It will calculate a release rate given storage conditions and specific leak parameters. It incorporates detailed thermodynamic factors for the release. Many experts consider this to be the most accurate or realistic model used for similar RMP applications. 
The worst case scenario is assumed to be the release of 1150 tons of anhydrous ammonia over a ten-minute period from the storage sphere. This release is expected to impact offsite areas. 
The alternate case scenario is assumed to be a release of five tons of anhydrous ammonia over a period of approximately eight minutes. This release is not expected to impact any offsite areas. 
General Accidental Release Prevention Program 
The PCS Phosphate - White Springs ammonia handling and processing area is governed by the OSHA 
Process Safety Management rule. Additionally, the use of Safety and Operating Procedures provides a system to prevent accidental releases by focusing on specific components of each job task. The safety and operating procedures manuals contain detailed job descriptions related to each task. The manuals are reviewed annually and revised as necessary to address any changes. Each shipment receives a detailed pre-unloading inspection, inspection during unloading, and a post unloading inspection by the operator. Employees and contractors are trained regularly to insure proficiency in all phases of the operation. 
Five Year Accident History 
There have been no reportable releases of ammonia that have affected offsite receptors during the last five years.  In fact, there have been no releases of ammonia that have affected offsite receptors in the 34-year operating history of the facility. 
The Emergency Response Program 
The PCS Phosphate - White Springs facility has developed an Emergency Ma 
nagement Plan designed to address prevention, preparation, response and recovery from a wide variety of potential emergencies. This includes an accidental release of a regulated substance at the facility. The facility, its employees and business operations are susceptible to emergencies such as natural disasters, severe weather, and man-made hazards. The Emergency Management Plan, in conjunction with the Risk Management Program and the OSHA Process Safety Management Program combine for management of potential emergency situations. The Process Safety Management program is integral to the RMP and includes, among other materials, procedures for Process Hazard Analysis, Operating Procedures, Mechanical Integrity, Employee Involvement, and Management of Change. 
This facility maintains an aggressive training program for all members of its four emergency response teams (medical, hazardous materials, rescue and fire), its emergency management group, and general employees. In addition to the i 
nitial training programs for all emergency response team members, quarterly refresher training is provided along with frequent drills and exercises. Emergency response equipment is maintained in prime condition and includes two fully equipped ambulances, a hazardous materials response vehicle, two fire engines, a water tanker with a monitor nozzle,and sophisticated rescue apparatus. 
The emergency response teams operate under the Incident Command System and the primary Incident Commander is a member of the Safety Department. All positions in each response team have at least two alternates and all members of the Emergency Management Group have designated and trained alternates. 
Because of the isolated nature of the location, PCS Phosphate - White Springs facility coordinates training programs with the local fire and rescue teams. This training includes joint exercises on an annual basis. 
Planned Changes to Improve Safety 
A Safety Plan is developed each year by the Safety Manager and  
staff, and followed to completion. The 1999 Safety Plan contains 25 key points and is a comprehensive program outlining activities for the year to ensure continuous safety improvement. Additional improvements will include the implementation of the Action Items identified by the 1999 Process Hazard Analysis and evaluation of diking for the ammonia storage area and emergency power for the ammonia compressors. A joint project is underway with PCS Phosphate, Hamilton County and Alltel to install a telephone ring-down system designed for notifications in the event of an emergency anywhere in the county. 
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