PCS Phosphate Co., Inc. - Executive Summary
RISK MANAGEMENT PROGRAM
Risk Management Program (RMP) PCS Phosphate
40 CFR 68 Aurora Division
Highway 306 North
Aurora, NC 27806
This Executive Summary for the Risk Management Program conforms to Sections 68.155 through 68.185. Referenced documents, such as the Comprehensive Emergency Management Plan, Process Safety Management Plan, Spill Prevention, Containment and Countermeasures (SPCC) and Oil Pollution Act of 1990 (OPA 90) plans are maintained at the facility and are available for inspection by authorized individuals.
Prevention and Emergency Response Policies
It is the PCS Phosphate policy to provide a safe environment for all employees, contractors, visitors and neighbors. Operations of the facility are designed so as not to adversely affect the environment of the surrounding area during emergency situations or normal operating periods.
It is the emergency response policy o
f the PCS Phosphate Aurora facility to immediately notify Beaufort County Dispatch of an accidental release of anhydrous ammonia in excess of 100 pounds, so that the public can be notified in a timely manner. PCS Phosphate employees will mitigate or contain the release, and provide emergency medical treatment for any injured personnel.
It is the policy of PCS Phosphate to prevent accidental release 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 them until rectified.
Description of the Facility
The PCS Phosphate facility in Aurora, NC covers 35,000 acres and sits along the Pamlico River. The Pamlico River empties into the Pamlico Sound, ten miles downstream of the facility. The only concentrations of population within 6 miles of the facility are the Town of Aurora
which lies south of the facility and has a population of approximately 1,000, and the communities of Pamlico Beach and Bayview (north of the site) with approximate populations of 500.
PCS Phosphate Aurora facility employees approximately 1,200 people and because of its isolated location the facility has its own medical clinic, fire response team, hazardous materials response team, rescue team and medical response team.
PCS Phosphate Aurora manufactures granular and liquid phosphate fertilizers, fertilizer grade phosphoric acid, technical and food grade phosphoric acid, superphosphoric acid, and phosphate rock products. The principal raw materials used at the Aurora site are phosphate rock, sulfur and ammonia. Phosphate ore is mined in adjacent open-pit mines and transported in a water slurry in enclosed pipes to the mineral processing area. Elemental sulfur is transported in railcars and barges to the plant where it is used to produce sulfuric acid, which in turn is used to prod
uce phosphoric acid. The phosphoric acid is used as the feedstock to produce solid or liquid fertilizers and animal feed supplements. Ammonia, in anhydrous form, is transported to the plant in railcars where it is used to make solid and liquid fertilizers by reacting with phosphoric acid. The fertilizer and phosphoric acid products are stored in warehouses and tanks until they are shipped to customers by barge, railcar or truck. Anhydrous ammonia is delivered to the Aurora facility by railcar and stored in 10 bullets with a maximum capacity of 244 tons. Each bullet is administratively limited to storing 195 tons of anhydrous ammonia. The anhydrous ammonia is transferred from the railcars to the storage bullets in a specially designed and built facility that incorporates essential safety features.
Four of the five cooling towers in the Sulfuric Acid area are used to reduce the heat in cooling water used to cool hot sulfuric acid from individual sulfuric plants. The fifth tower i
s used to condense steam from the turbo-generator condenser. Cool water (75oF-85oF) from each basin is pumped through one or more heat exchangers where it is heated (95oF-105oF) and returned to the top of the cooling tower. The tower releases heat to the atmosphere. Because the water temperature remains consistently warm throughout the year, it is an ideal location for biological growth. Biological growth will restrict the flow and heat exchange properties of the system, and can cause corrosion if it is left untreated. PCS Phosphate has several one ton chlorine cylinders on site. Chlorine gas is added to the basin water to kill biological growth. Work with chlorine cylinders is done by trained, qualified operators and maintenance personnel. In case of a chlorine release, PCS Phosphate has an internal hazardous materials response team and additional assistance can be requested from the North Carolina Regional Response Team.
Worst-Case and Alternate Case Scenarios
Both case scena
rios were developed using the DEGADIS model. The DEGADIS model is listed in 40 CRF Part 51, Appendix W as an acceptable EPA Guideline Model.
Chlorine and anhydrous ammonia are stored in pressurized storage cylinders and bullets respectively. The worst-case scenario for the facility was assumed to be the release of 195 tons of anhydrous ammonia over a ten-minute period from the storage bullet. The worst-case scenario of chlorine for the facility was assumed to be a complete release of 1 ton over a ten-minute period. These worst case scenarios have off site impacts.
Alternative Case Scenarios
The alternate case scenario for anhydrous ammonia is postulated to be a 6 ton release due to a ruptured pipeline from a railcar to a storage bullet. The amount released is based on the volume contained within the pipeline between the railcar and the storage bullet. This assumes active mitigation with an excess flow valve on the railcar and a check valve on the storage
bullet. This alternative release scenario has off site impacts.
The alternative release scenario for chlorine assumed the loading valve being broken off leaving a 3/4 inch hole. Due to the pressure of the tank the entire contents would be released before active mitigation could be implemented. This alternative release scenario has off site impacts.
General Accidental Release Prevention Program
The PCS Phosphate Aurora facility is in full compliance with the OSHA PSM rule. Additionally, the use of Safety and Operating Procedures provide a system to avert accidental releases by focusing on specific components of each shipment. The safety and operating procedures manual consists of safety and operating procedures, uniquely designed for specific job tasks associated with unloading, storage, and use of anhydrous ammonia chlorine. The manual is reviewed annually and revised as necessary to address any changes. Every inbound anhydrous ammonia shipment receives a detailed pre-unloadin
g inspection, inspection during unloading, and a post unloading inspection by the loading technician. A final quality assurance inspection is performed by a tank car inspector. Employees and contractors are trained regularly to insure proficiency in all phases of the operation.
Five Year Accident History
No accidental releases of anhydrous ammonia greater than 100 pounds have occurred in the last 5 years from an RMP or OSHA PSM covered process at the PCS Phosphate Aurora facility.
The Emergency Response Program
PCS Phosphate Aurora facility has developed a Comprehensive Emergency Management Plan (CEMP) designed to address prevention, preparation, response and recovery from a wide variety of potential emergencies to include 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, se
vere weather, and man-made hazards. The CEMP, in conjunction with the Risk Management Program and OSHA's Process Safety Management for Highly Hazardous Chemicals Program (PSM) aid in managing potential emergency situations. PSM is more closely aligned to prevention through the use of Process Hazard Analysis, Operating Procedures, Mechanical Integrity, Employee and Contractor Involvement, and Management of Change procedures.
The facility maintains an aggressive training program for all members of its four emergency response teams (medical, hazardous materials, technical rescue and fire), its emergency management group, and employees and contractors. In addition to the initial training programs for all emergency response team members, annual refresher training is provided along with quarterly drills and exercises. Emergency response equipment is maintained in prime condition and includes a fully equipped ambulance, hazardous materials response vehicle, two fire trucks and sophistic
ated rescue apparatus.
The emergency response teams operate under the Incident Command System and the primary Incident Commander is the Manager, Health & Safety. All positions in each response team have at least two alternates and all members of the Emergency Management Group have designated and trained alternates.
The PCS Phosphate Aurora facility coordinates training programs with the local fire and rescue teams. This training includes joint exercises on an annual basis. The public is notified by using the county communications system.
Planned Changes to Improve Safety
PCS Phosphate Aurora facility is implementing facility wide the "STOP" safety program. This is a follow-on to the successful "Take Twofor Safety" program which has been in place for several years. Shelter in place options were presented to all employees and interested parties and will be made a part of the safety orientation program for all contractors.