Mulberry Phosphates, Inc. - Executive Summary |
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The following is the Corporation's Safety and Health Policy Statement as acknowledged by the General Manager of Chemical Operations on April 20, 1999. Mulberry Phosphates, Inc. recognizes the importance of safety and health in voluntary compliance with all federal, state and local regulations, including the Occupational Safety & Health Administration (OSHA). We will manage company operations to prevent injury to employees, the residents of our community, and all visitors to our facility. To that end, we pledge to provide each employee a place of employment free from recognized hazards that are likely to cause physical harm. While zero accidents/illnesses/injuries is our goal, this policy also establishes post-injury or disability management procedures to help injured or ill employees rapidly return to work. Safety and health are an integral part of our daily business functions. Management and supervision are responsible for ensuring employees are trained to perform work safely, t o abate safety hazards, and to report and investigate mishaps and potential hazards in the workplace. Employees are expected to participate in all phases of our Safety & Health Plan and to conduct their daily tasks in a manner consistent with its objectives and regulations. Safety and health are a responsibility that must be shared equally and without exception by each individual within the organization. Corporate Commitment to Safety: The following is the Corporation's policy statement on process safety management as acknowledged by the corporate Senior Vice President of Operations and Administration. To protect the employees at our facilities as well as the communities we live in, Mulberry Phosphates, Inc., has established many important safety and environmental programs. However, because of the recently published OSHA regulations on process safety management (PSM), we will be reemphasizing and documenting many of our programs that help to reduce the likelihood of catastrophic incidents which could potentially threaten our employees, facilities, and neighbors. As part of that effort, I am requesting each department head to involve our employees, both hourly and salaried, in the development and implementation of PSM systems and procedures at our facilities. These PSM activities should address at least the following: 1. Development of PSM information program; e.g., determine where information such as MSDS's should be kept. 2. Development of a process hazard analysis (PHA) program (decide how to select employees to participate in PHA). 3. Conduct specific process hazard analyses (experienced operators should be included). 4. Develop and update operating and maintenance procedures. 5. Develop training programs and appropriate refresher training. 6. Monitor contractor's performance to ensure that contractor employees follow the safe work practices established for our facilities. 7. Identify pre-startup activities which need to be included in ou r pre-startup safety reviews before startup of new or modified equipment and processes. 8. Develop and implement a mechanical integrity program which satisfies OSHA's PSM regulation. 9. Develop and update safe work practices. 10. Generate and implement a Management of Change program. 11. Perform incident investigations. 12. Prepare an emergency response plan and participate in emergency response training and drills. 13. Participate in compliance audits and correct deficiencies identified by those audits. In addition to addressing the items above, plans should be developed for communicating PSM information to all employees involved with process systems and those who may be affected by their failure. The Facility: Mulberry Phosphates, Inc. (MPI) is a granular fertilizer facility located at 4000 State Road 60 East approximately one mile east of the City of Mulberry. The facility consists of three separate manufacturing plants, a phosphogypsum stack system, warehouses, rep air shops, offices, and other ancillary structures. The three manufacturing plants are the sulfuric acid plant (SAP), the phosphoric acid plant (PAP), and the granular fertilizer plant (fertilizer plant). Each of the plant's process descriptions has been provided below. Sulfuric acid is produced from elemental sulfur. Sulfur is burned in a furnace to produce sulfur dioxide gas. Then by use of a catalyst, sulfur dioxide is converted to sulfur trioxide, which is also a gas. Sulfur trioxide gas is absorbed into a stream of recirculating sulfuric acid thereby increasing the acid strength. Water is added to the strengthened acid causing a decrease of strength and increase in volume. The extra volume is removed as product from the recirculation circuit. Heat from the burning of elemental sulfur and from the conversion of sulfur dioxide to sulfur trioxide is captured. The captured heat is used to produce steam that is utilized in two fashions. Electricity is generated from the maj ority of the steam at a on-site turbine driven generator. The remaining steam is utilized in tube and shell evaporators located in the PAP. Sulfuric acid produced on-site or from external sources is then pumped from storage tanks to the PAP and reacted with mined phosphate rock producing a slurry containing a diluted form of phosphoric acid (28-30% P2O5) and a solid by-product, phosphogypsum. The phosphogypsum is filtered from the phosphoric acid and conveyed to an adjacent aboveground storage site. The phosphoric acid is concentrated through evaporation to increase its strength to 40-42% P2O5, stored, and then utilized in the fertilizer plant. At the fertilizer plant, phosphoric acid is neutralized with another raw material, anhydrous ammonia (ammonia), to form a slurry that is granulated and dried to form the facility's primary product, diammonium phosphate fertilizer (DAP). The DAP is conveyed to an on-site warehouse for storage prior to shipment. The DAP is transported, v ia truck or rail, to the Port of Tampa or Port Manatee for export. Production of DAP utilizes anhydrous ammonia, a chemical subject to the regulations found in 40 CFR part 68 (as approved in Section 112r of the Clean Air Act). The ammonia is received at the facility via pipeline and is stored on-site as a liquid at ambient temperatures. Up to 250 tons of ammonia may be stored at the facility. Offsite Consequence Analysis: 40 CFR part 68 Subpart B requires facilities that store over 10,000 pounds of ammonia to prepare an Off-site Consequence Analysis (OCA). The OCA includes both a "Worst Case Scenario" analysis and an "Alternative Release Scenario" analysis utilizing physical parameters determined by the U.S. Environmental Protection Agency (EPA). The OCA for the MPI facility was determined using the HGSYSTEM model and was prepared by an independent consulting firm. The HGSYSTEM model estimates a distance to a toxic endpoint of 0.14 mg/l (200 ppm) for ammonia. The toxic endpoi nt concentration of 200 ppm has been set by EPA in regulations found at 40 CFR 68 Appendix A. The data to support the toxic endpoint of 200 ppm is provided by reference by EPA. The worst case scenario was determined by assuming 500,000 pounds of ammonia is released in vaporous form from two interconnected tanks over a 10 minute period. (It should be noted that according to EPA-454/R-93-002, Guidance on the Application Refined Dispersion Models for Hazardous/Toxic Air Releases, Appendix B, p. 4, it would take approximately 5 hours to completely vaporize 500,000 pounds of ammonia). The modeling presumes there is no passive mitigation systems in place. Using the parameters mandated by the EPA, the distance to the toxic endpoint concentration of 200 ppm is 1.9 miles from the Mulberry facility. However, there are passive mitigation systems in place at MPI to minimize the vaporization of ammonia in the event of a release. The ammonia tanks are located in a concrete containment are a which includes a gravity fed drain that immediately discharges into a process water ditch. During a release the ammonia will pool in the containment area and then flow immediately through the gravity fed drain into the ditch. The function of the containment is two-fold: First, it will minimize the exposed surface area available for vaporization, decreasing the release rate; and secondly, it will direct the liquid ammonia into the process water ditch where it will solubilize in the water. The containment also is equipped with a deluge system that upon activation will spray water down over the containment area. This will scrub most of the vaporous ammonia from the air and will also promote pooling of the ammonia in the containment area. The deluge water will also aid in flushing the pooled ammonia from the containment area into the process water ditch. The ammonia storage and distribution system is also equipped with self-closing excess flow valves. These excess flow valves a re designed to limit or halt ammonia flow should a failure occur in the unloading or distribution systems. These mitigation systems will significantly reduce the distance to the toxic endpoint and hence, make the worst-case scenario very unlikely. The alternative release scenario was determined by assuming a transfer line is severed causing the release of 12,600 pounds of anhydrous ammonia over a 10 minute period. The modeling presumes there is no passive mitigation systems in place. Under this scenario the release would be terminated by manually closing an emergency valve. Using a wind speed of two meters per second, the distance to the endpoint concentration was determined to be 0.43 miles from the Mulberry facility. At this distance the endpoint would be contained onsite in all directions except to the north where it would reach just beyond State Road 60 East. Once again both the passive and active mitigation systems that have been described above will significantly reduce the distance to the toxic endpoint and completely contain it on-site. Accidental Release Prevention Program: MPI complies with all OSHA safety and health standards listed in 29 CFR part 1910, as well as all other federal, state and county regulations that are applicable to the fertilizer industry. Both operations and maintenance departments have detailed written operational, maintenance, and inspection programs in keeping with OSHA requirements. These programs provide employees with guidance to help prevent unsafe practices or conditions from existing in the facility that could contribute to an accidental release. These programs have guidelines or defined practices that identify how to safely operate the various plants in such a manner to minimize accidental releases or unsafe conditions. Maintenance and inspection procedures are similarly defined, so that maintenance personnel can safely maintain equipment such as the ammonia storage and distribution systems. Inspection programs p rovide criteria to be checked, frequency of needed maintenance, and key indicators of suitability for use. Company employees are trained and tested in their knowledge of safety procedures such as, but not limited to, lockout/tagout, confined space entry, line breaking, hot work, respirator protection, fall protection, permitting requirements, hazard communications, hazardous operator requirements, and MSDS (material safety data sheet) usage and locations. Facility emergency responders have been trained in the use of emergency equipment and have participated in staged exercises. MPI has built-in layers of protection for the equipment used in the handling and processing of those chemicals that are regulated by OSHA, EPA, and other governmental agencies. Those layers of protection include meeting design standards, continuous training of employees, inspections of equipment, automatic safety devices, redundant manual devices, and water spray systems. Facility 5-Year Accident His tory: There has been no accidental releases of ammonia at the Mulberry Phosphates, Inc. facility in the last five years. Emergency Response Program: MPI has trained key employees to respond to chemical releases at the facility under OSHA's Hazardous Waste Operator requirements to the technician level. These employees have been trained to use emergency responder equipment, level A, B, & C protective equipment including encapsulated suits, and S.C.B.A. equipment in staged release drills. All shift supervisors, day supervisors, superintendents and electrical employees have completed an 8 hour class on basic first aid & CPR. MPI has hazardous material trained personnel onsite during every shift to respond to chemical releases. All employees are trained in an overview of the process and operating procedures with an emphasis on specific safety and health hazards and emergency operations. Contractors working at the MPI facility complete a 16 hour safety class for fertilizer industry facilities conducted by Polk Community College and attend a facility site specific safety class presented by the facility safety supervisor. Site specific training includes briefing on the facility emergency response program. MPI has an Emergency Response Plan which contains those elements required under 29 CFR part 1910.119 & 40 CFR part 68.95. The emergency response plan acts as a guideline to direct internal response and reporting activities at the direction of specific on-site personnel, in the event of a release emergency. The plan includes federal, state and county agencies to be contacted in an emergency in addition to company managers that must be notified in the event of a release emergency. In the plan is specific information such as material safety data sheets of certain hazardous chemicals, notification instructions, location of emergency response equipment, evacuation directions, documentation on emergency medical treatment, and other resources. Emergency responde r team training has been developed in conjunction with outside agencies (LEPC, local fire department, EMS, local law enforcement). Planned Changes to Improve Safety: Safety issues and operating procedures are regularly reviewed by a safety committee once a month. The committee is assigned the task of addressing all safety issues with the goal of correcting any deficiencies to improve the overall safety at the facility. Operating procedures are evaluated by means of a hazard analysis. The committee will then implement measures to correct or improve any deficiencies resulting from the hazard analysis. |