PCS Phosphate Co., Inc. - Executive Summary |
RISK MANAGEMENT PROGRAM FOR PCS PHOSPHATE KINSTON FEED PLANT EXECUTIVE SUMMARY June 1999 Risk Management Program (RMP) PCS Phosphate 40 CFR 68 Kinston Feed Plant Highway 11 North Kinston, NC 28501 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 and Process Safety Management Plan, are maintained at the facility are available for inspection by authorized individuals. Prevention and Emergency Response Policies 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 until rectified. The overall PCS Phosphate policy is to provide a s afe work environment for all employees, contractors, visitors and neighbors. This extends to the design, training, and implementation of a program which will result in saving lives and reducing property damage during an emergency. It is also PCS Phosphate's policy to operate in an environmentally responsible manner consistent with environmental knowledge, policies, and regulations that best serve the needs of employees, the community, and the company. Operations of the Plant are designed so as not to adversely affect the environment of the surrounding area during emergency situations or normal operating periods. PCS Phosphate attempts to prevent all emergencies from ever occurring. However, should an event occur, the immediate goal is to keep the emergency and its effects within Plant boundaries and not allow it to present a threat to the health and safety of the general public. Preserving life is the prime consideration, so all procedures will be carried out in a manner to minim ize risk to employees and emergency response personnel. Rescue and medical activities have priority over all other actions. It is the emergency response policy of the Kinston, NC PCS Phosphate facility to immediate notify the Lenior County Central Dispatch of a accidental release of anhydrous ammonia. Description of the Facility The PCS Phosphate Feed Products operation is located on Highway 11 approximately three miles north of Kinston, North Carolina. At this facility, PCS Phosphate processes phosphoric acid and limestone to produce monocalcium and dicalcium phosphate which are used by the animal feed industry. PCS Phosphate also processes anhydrous ammonia, phosphoric acid and sulfuric acid to produce monoammonium phosphate which is also used by the animal feed industry. Normal hours of operation are Sunday to Friday with a security service on weekends during the off hours. Anhydrous ammonia is received by railcar and is transferred from the railcar to a storage vessel for the short period of time that anhydrous ammonia is used in the production of the animal feed additive. Only 15% of the time is there any anhydrous ammonia present at the Kinston facility. The maximum capacity for a railcar is 75 tons of anhydrous ammonia. Ammonia is unloaded from the railcar by using an ammonia compressor to develop a pressure differential between the railcar and ammonia storage vessel. Ammonia vapor is pumped from the storage vessel to the railcar through the vapor line. Liquid ammonia is pressured through the liquid line into the bottom of the storage vessel. The storage vessel will hold approximately 40 tons of liquid anhydrous ammonia. The standard instructions for our operation is to fill the storage vessel to only 65% full. This gives a better operating safety factor. The 18,000 gallon capacity vessel should never be filled over the 85% level, as specified for all operating anhydrous ammonia pressure vessels. It is equipped with pressure relief valves, level gages, pressure gages and excess flow valves. Additionally, shut off valves are connected with the railcar unloading hoses. These can be closed from two remote locations. An ammonia pump is located at the ammonia storage vessel and used to transfer liquid ammonia into the plant through a steel process line. Worse Case and Alternate Case Scenarios Both case scenarios were developed using the Degadis model. The Degadis model is listed in 40 CFR Part 51, Appendix W as an EPA Guideline Model. The worse case scenario is assumed to be a complete release of anhydrous ammonia over a ten-minute period from the storage tank. The worst case scenario has off site impacts. The alternate case scenario is postulated to be a 0.09 ton anhydrous ammonia 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 vessel. This assumes active mitigation with an excess fl ow valve on the railcar and a check valve on the storage vessel. The alternate case scenario has off site impacts. General Accidental Release Prevention Program The PCS Phosphate Kinston Feed Plant is in compliance with the OSHA PSM rule. The use of Safety and Operating Procedures provide a system to avert accidental releases by focusing on material receiving, storage and processing. Additionally, safety and operating programs consists of manuals and numerous operating procedures, uniquely designed for specific job tasks. These manuals and programs are reviewed annually and revised as necessary to address any changes. Five Year Accident History 1994 1995 1996 1997 1998 None None None None None No accidental releases have occurred in the last 5 years from a covered process at the PCS Phosphate Kinston Feed Plant. The Emergency Response Program PCS Phosphate Kinston Feed Plant has developed a Comprehensive Emergency Management Plan (CEMP) designed to addre ss 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, severe weather, and man-made hazards. The CEMP, in conjunction with the Risk Management Program and OSHA's Process Safety Management 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 Involvement, and Management of Change procedures. The Kinston Feed Plant maintains an open and cooperative working relationship with the Lenior County Emergency Management Agency, the Hugo District Fire Department and the Sand Hill District Fire Department. Both fire departments conduct orientation visits to the facility on an annual basis and participate in joint exercises with the facility on a bi-annual basis. At least one drill per year is conducted at the facility for all employees and tabletop exercises are used to review plans and procedures on an annual basis. All employees receive annual refresher training on the emergency response procedures. Public notification is provided by the Lenior County Central Dispatch following an immediate notification from the facility to the county of an emergency condition. Planned Changes to Improve Safety The PCS Phosphate Kinston Feed Plant is examining options for providing additional active and passive mitigation systems around the railcar unloading area and the storage vessel. |