PCS Joint Venture dba Farmers Favorite Fertilizer - 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 It is the policy of Farmers Favorite Fertilizer (FFF) to prevent accidental releases through the use of 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. The FFF policy is to provide a safe work environment for all employees, contractors, visitors and neighbors. This extends to the design, training, and implementation of a program that will result in saving lives and reducing property damage during an emergency. It is FFF policy to operate in an e nvironmentally responsible manner consistent with environmental knowledge, policies, and regulations. 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. FFF attempts 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. Preserving life is the prime consideration. 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 FFF to immediately notify the City of Moultrie Fire and Police Departments of a release of anhydrous ammonia that exceeds the reportable quantity. FFF employees will mitigate or contain the release. Descr iption of the Facility The Farmers Favorite Fertilizer facility has 25 full-time employees. FFF manufactures normal superphosphate and complete grades of NPK fertilizers. Ammonia is used in the process as a form of nitrogen for the NPK fertilizers. Anhydrous ammonia is delivered to the FFF facility by railcar. It is stored in a tank. The tank is capable of storing 100 tons of anhydrous ammonia. The anhydrous ammonia is transferred from railcars to the storage area using specially designed hoses, piping, and pumps. Safety features of this system include a fail-close valve system in case power is lost and excess flow valves in case of line failure. 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 expe rts 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 100 tons of anhydrous ammonia over a ten-minute period from the storage tank. This release is expected to impact offsite areas. The alternate case scenario is assumed to be a release of 20 pounds of anhydrous ammonia over a period of one minute. This release is expected to impact offsite areas. General Accidental Release Prevention Program The FFF facility is in full compliance with the OSHA Process Safety Management rule. Additionally, the use of Safety and Operating Procedures provide a system to prevent accidental releases by focusing on specific components of each shipment. 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 durin g 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 that have affected offsite receptors during the last five years. The Emergency Response Program The FFF facility has developed an Emergency Management 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 OSHA's Process Safety Management Program aid in managing potential emergency situations. The Process Safety Management program is integral to the RMP. It consists of procedures for Process Hazard Analysis, Operating Procedures, Mechanical Integrity, Employee Involvement, and Management of Change. Emergency response is coordinated with the local fire and police departments. Emergency response personnel are trained annually. Planned Changes to Improve Safety FFF's ongoing training program helps insure that all personnel are prepared in the event of an emergency. Through the Process Hazards Analysis and Process Safety Management programs, we are always reviewing changes to make our operation as safe as possible. G:\SPCC\RMPMoul/cbp/599 |