Mississippi Phosphates Corporation - Executive Summary |
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Mississippi Phosphates Corporation (MPC) is a manufacturer of fertilizers. A main ingredient in our product is ammonia that is used in the final process of manufacturing diammonium phosphate fertilizers. It is fertilizers such as this that in turn feed and clothe the rest of the world. Among the many other things that Mississippi Phosphates brings to its community is a commitment to operate safely. The company recognizes the health concerns of its neighboring community and is committed to responding to those concerns. A safe workplace is a top priority for company management and personnel, and Mississippi Phosphate employees continuously look for innovative ways to operate and maintain the production facilities. Mississippi Phosphate participates in routine safety training programs and drills. In addition, continuous monitoring and assessment of the plant facilities ensures that all operations are running smoothly and efficiently. Mississippi Phosphates has a close working rela tionship with local emergency responders, and together they are prepared to respond to chemical emergencies. To ensure proper emergency preparedness Mississippi Phosphates has a team of employees trained in confined space rescue, hazardous waste operations and other specialties. MPC's worst -case release scenario is the failure of a 25,000-ton ammonia storage tank. The selection of the ammonia storage tank for the worst-case release is strictly taken from the regulatory definition of the worst-case release; the entire 25,000 tons of ammonia is released in 10 minutes. This produces a scenario with a 4.40-mile distance to the endpoint. This was determined by the use of a computer air modeling program called DEGADIS. MPC's alternative scenario is the release of 1,300 pounds of ammonia. The selection of the alternative scenarios was based on researching information sources for release data. The Environmental Protection Agency (EPA) Emergency Response Notification System (ERNS) data base and publications from the AIChE Ammonia Safety Symposia were reviewed. Informal interviews with diammonium phosphate plant operators, supervisors, engineers and managers were also conducted with other plants. MPC transfers ammonia in a pipeline from its atmospheric storage tank to its fertilizer plant continuously. A rupture of this pipeline would result in a release of 1,300 pounds of ammonia in an 8-minute period. Under the regulatory defined parameters produces a scenario with a 0.40-mile distance to the endpoint. The distances to the endpoint for the alternate scenarios were also determined by the use of a computer air modeling program called DEGADIS. MPC's safety and environmental record reflects this commitment. We have multiple layers of safety and environmental protection in place at our plants to protect our employees and the community. The following covers some of these layers of protection: 7 Managing risks is something we do on a daily basis. 7 We have work ed for many years to reduce risks at our site and to be prepared for emergencies. 7 Our employees are highly skilled and well trained. 7 Our equipment is routinely inspected and tested to make sure it is safe. 7 We have controls in the process throughout our plants to detect potential leaks or releases before they occur. 7 Hazard reviews add another layer of protection. They involve "what if" scenarios where employee teams investigate every possible scenario of a new project and resolve it as part of the design phase of the project. 7 Emergency response, including employee responders as well as off-site responders add another layer of protection to the community. 7 We work closely with the police and fire departments, and we conduct routine drills. 7 In the event of an emergency, we are prepared to respond. MPC has taken all the necessary steps to comply with the accidental release prevention requirements set forth under 40 CFR part 68 of the EPA. The following summar izes the elements of the release prevention program that are in place at our Pascagoula facility. Process Safety Information: Workplace health and safety are of paramount concern. MPC maintains a file and makes it employees aware of process safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis: MPC conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is known as the Hazard and Operability (HAZOP) study. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated every five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures: For the purposes of safely conducting activities within our covered processes, MPC maintains written operating p rocedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training: MPC has a training program in place to inform and educate employees and to ensure they are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity: MPC carries out documented maintenance checks on covered process equipment during each operational turn-around to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified personnel carry out maintenance operations with t raining in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change: Written procedures are in place at MPC to manage changes in covered process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews: Pre-startup safety reviews of new processes and to significant modifications in existing processes are conducted as a regular practice at MPC. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits: MPC conducts audits on a regular basis to monitor and susta in this process and ensure that MPC management is kept informed of all safety, health, and environmental matters. Formal audits will carried out at least every 3 years and any corrective actions required as a result of the audits will be undertaken in a safe and prompt manner. Incident Investigation: MPC promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation: MPC truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility 's implementation of the EPA Risk Management Program rule, including information resulting from process hazard analyses in particular. Hot Work Permits: MPC recognizes the inherent danger associated with hot work and requires the issuance of a work permit for all such activities at the facility. The permit documents that all appropriate fire prevention requirements have been considered and implemented prior to beginning the hot work operations. The permit is kept at the site of the work until completion of the hot work operation. Contractors: MPC hires outside contractors to conduct some specialized maintenance and construction projects. All contractors working in the facility or visitors to the facility are expected to be aware of and adhere to all MPC health, safety, and environmental policies and procedures. MPC will conduct or require proof of appropriate training. MPC has a set policy for informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. MPC has not had any accidental releases, as defined by the Risk Management Program regulations, for the last 5 years. The releases that MPC has had in the past 5 years are typically a small release to the air and do not meet the criteria that is set forth in the regulations. MPC has an extensive emergency response program. Within the facility there is a written Emergency Response Plan (ERP). The ERP is designed as a guide to help in determining the magnitude of an incident, the steps needed to bring the incident under control and the requirements to ensure that all the federal, state, and local laws are complied with. The ERP is a definitive plan that assigns responsibilities defines several different methods of communication, assigns control centers and safe havens, designates evacuation procedures, and coordinates with outside assistance. The plan has detailed action plans that specifically address incidents concerning chemical spills, fire, acts of nature, personnel injury or fatality, and equipment failures. The plan also designates the type and frequency of training that each person is required to have depending on their responsibilities. Furthermore, the plan commits the management team to devote the necessary resources to prepare, implement and audit the ERP. MPC is striving on a daily basis make the facility as safe as possible for the employees, contractors and the community. MPC literally has safety and/or environmental training going on almost daily. Every employee and contractor will attend numerous safety and/or environmental training meetings annually. MPC and its employees have an enduring commitment to protecting health, safety and the environment and our success is accomplished by research, innovation and the use of good common sense. |