CF Industries, Inc. Plant City Phosphate Complex - Executive Summary |
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About CF Industries, Inc. CF Industries, Inc. is one of North America's largest interregional agricultural cooperatives and is owned by and serves 9 regional farm cooperatives. Through its members, the company's nitrogen, phosphate and potash fertilizer products reach over a million farmers and ranchers in 48 states and two Canadian provinces. CF's Plant City Phosphate Complex, located north of Plant City, Florida, produces more than 2 million tons of phosphate fertilizers annually for use by its member owners. Accidental Release Prevention and Emergency Response Policies CF's Plant City Phosphate Complex handles anhydrous ammonia, a commercial chemical that is defined by the EPA as "a regulated substance" for the purposes of the RMP. Its most extensive use (about 80%) is in soil fertilization as a source of nitrogen, which is essential for plant growth. The Plant City Phosphate Complex has an extensive safety program that assures compliance with all applicable local, state and federal rules and regulations. The facility operates under a Corporate Environmental Health and Safety Policy that endorses going beyond regulatory requirements when necessary to protect the health and safety of its employees and the public. The design, maintenance, and operation of this facility are carried out in conformance with this policy to provide a safe operation and to prevent exposure of our employees and nearby neighbors to ammonia. The facility's Emergency Response Plan is based on OSHA's emergency response standard, 29 CFR 1910.120(q). The plan includes procedures for the notification of local fire and emergency response authorities and notification of any potentially affected neighbors. In addition, emergency preparedness is assured by: Hazardous Materials (HAZMAT) trained operating and supervisory personnel; emergency response drills with local emergency responders; ammonia sensors located at critical locations in the process area and along the facility perimete r; continuous computer monitoring of ammonia sensor readings and weather conditions; and water curtain capability for ammonia vapor suppression. Stationary Source and Regulated Substance * The Plant City Phosphate Complex receives shipments of anhydrous ammonia by rail. The ammonia is transferred from the pressurized railcars to pressurized ammonia tanks. The ammonia is pumped from the tanks directly to four granulation plants, where it is combined with phosphoric acid to produce ammonium phosphate fertilizers. Access to the site is restricted to authorized personnel. * The only substance subject to EPA's RMP requirements at this facility is ammonia. Worst-Case Release Scenario(s) and the Alternative Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario. Worst Case and Alternate Release Scenarios are based on the modeling guidelines set forth in 40 CFR Part 68, which specifies the time duration for the release to occur, weather conditions, and other assumptions to be used in the worst case and alternative case analyses. * Worst-Case Scenario: Failure of the largest storage tank when filled to the greatest amount allowed would release the total contents of the tank in accordance with mandated assumptions. Administrative controls, fill-level alarms, and automatic shut-off valves prevent the tank from being filled to capacity. The Worst-Case Scenario is highly unlikely due primarily to the extensive and detailed safety program that guides the design, maintenance and operation of the facility and includes numerous layers of protection to prevent storage tank rupture and minimize the potential for any release (e.g. written operating procedures, five-year inspection program, relief valves, excess flow valves, and exterior guardrails and traffic protection). Although highly unlikely, if a worst case release did occur, the release is predicted to go off-site. * Alternative Rel ease Scenario: A two-inch hole opened in an ammonia tank car during an accident would release anhydrous ammonia to the atmosphere. In this analysis, the contents are released as a vapor/aerosol mix and the aerosol vaporizes as the release mixes with the air. The alternative release scenario is highly unlikely due primarily to the extensive and detailed safety program that guides the design, maintenance and operation of the facility and includes several layers of protection to prevent a railcar rupture (e.g. railcar construction, rail preventative maintenance program, and traffic protection). Although highly unlikely, if an alternative release scenario did occur, the release is predicted to go off-site. Accidental Release Prevention Program and Specific Prevention Steps The Plant City Phosphate Complex is subject to the U.S. Occupation Safety and Health Administration's Process Safety Management (PSM) Standard, 29 CFR 1910.119. As required by EPA, the PSM standard forms the basis for the Agency's RMP prevention program component. The primary purpose of this facility's PSM Program is to safeguard our employees and nearby neighbors from exposure to ammonia by providing assistance in evaluating and updating the facility's process and mechanical safety procedures and programs. The objectives of the PSM Program are: 1. To periodically review and update the facility's process/mechanical safety procedures and programs; 2. To provide for regular and periodic review of the facility's procedures to maintain compliance with OSHA's PSM regulations; 3. To perform Process Hazard Analyses on new and existing processes; and 4. To assure follow-up on the action items generated by the Process Hazard Analyses until completion. Key mechanisms are listed below. 1. A comprehensive tank inspection program requires every tank be emptied and inspected at five-year intervals; 2. Automated emergency shutdown systems are provided and maintained; 3. Continuous monitoring and surveillance are conducted by operating personnel using remote cameras and on-site inspection; 4. Ammonia sensors located at critical areas in the plant are continuously monitored by plant personnel; 5. System design incorporates multiple layers of protection including: back up power sources on automatic shutdown valves, pressure relief valves, leak detectors, excess flow valves, temperature shutdowns on compressors, and ammonia suppression equipment; 6. Plant personnel receive annual Process Safety Management training; 7. Barrier posts are installed surrounding the ammonia tanks; 8. Traffic is strictly controlled around the ammonia tanks and railcars; and 9. Site access is strictly controlled and monitored. Five Year Accident History In the past five years there have been no ammonia releases that caused injury or property damage either on-site or off-site. Emergency Response Program HAZMAT training is performed in accordance with OSHA regulation 29 CFR 1910.120 (q) and pre -emergency planning and drills are conducted with local emergency responders. The emergency response program complies with the OSHA PSM Program as outlined in 29 CFR 1910.119. The HAZMAT team conducts joint training and drills with the local fire department. Facility personnel conduct meetings informing the public of the facility's Emergency Response Program. The facility uses the Incident Command System that was developed by the National Fire Academy. Planned Changes to Improve Safety The facility plans to install alarms and a telephone notification system for the community during 1999. CF will continue to provide support to and work with the Local Emergency Planning Committee and emergency responders to plan for the appropriate emergency response and to prepare for responding to an emergency through practice and drills. CF Industries, Inc. Plant City Phosphate Complex Risk Management Program (RMP) Executive Summary |