Monsanto Augusta Site - Executive Summary |
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Monsanto's Augusta site consists of two operating plants and one plant under construction. The site is located at 1750 Lovers Lane, Augusta, Georgia 30903. The site consists of approximately 700 full time employees including Monsanto personnel and resident contractors. The site produces pharmacuticals at it's G. D. Searle plant and aspartame at its NutraSweet plant. There are two EPA RMP regulated toxic chemicals at the site; Ammonia and Chlorine, located in the NutraSweet plant. There are no RMP regulated flammables at this site. The site operates under six different air permits, NutraSweet's number was selected due to the location of the regulated substances. Monsanto, Augusta (NutraSweet), along with nine other local industrial plants, EMA and local emergency response units, conducted a Risk Communication forum for the public in October of 1997 to explain the hazards, mitigation, and prevention of releases of the RMP toxic substances, ammonia and chlorine. This forum was hi ghly publicized locally and nationally. Attendees included local residents, industries, news media along with national news coverage and interested persons from other industries. The site has a documented Emergency Response plan which includes defined responsibilities and actions to be implemented for many events including toxic chemical releases, fires, and weather conditions. In addition, the site Emergency Response Team (ERT) has developed specific procedures for each piece of emergency equipment and the personnel to operate it. All ERT members receive formal training in fire fighting, HAZMAT, and Emergency Medical Technician (EMT) First Responder. The team receives a minimum of annual refresher training in all three areas of response. Approximately twenty of the ERT members are on site 24 hours per day, 365 days per year. In general, the Emergency Response Plan describes actions which will allow safe response for all site employees and prompt notification of community organi zations. The plan has been integrated with the Augusta-Richmond County Local Emergency Response Committee (LEPC) and Emergency Response Authority (EMA). The LEPC and several local facilities have conducted coordinated drills that employ ERT's, the local fire department, and various EMA agencies. These drills enhance the prepardness of the community. In addition, the Monsanto, Augusta site ERT conducts regular on and off site training in all emergency prepardeness including toxic releases, fires, and personnel injury EMT. In the event that an incident occurs which would jeopardize the safety and health of personnel or the environment of the site and surrounding area, the following responses would occur: 1. The site ERTwould be notified by plant alarm and verbal communication to respond to the area of the incident. 2. The Augusta-Richmond County emergency facilities would be notified through notification to 911. 3. The Augusta-Richmond County Emergency Management Authori ty (EMA) would assist the local fire department incident commander in ensuring that all community personnel are notified of the incident and the appropriate response necessary; shelter in place or evacuation for the area affected. There have been no incidents from this site in the last five years that would have jeopardized the health and well being of the community. In fact, there have been no offsite incidents that would have affected the community in the history of the Monsanto, Augusta site, some 15 years. The Monsanto, Augusta site maintains a comprehensive system for each of the RMP regulated chemicals, ammonia and chlorine, to ensure safe operations; RMP requirements are very similiar to the OSHA PSM requirements. OSHA audited all the PSM regulated processes at this site, including the chemicals governed by RMP, for admission into the Voluntary Protection Plan (VPP) program. The agency has awarded "Star" status, the highest rating, to the entire Augusta Site and the " Best Practice in OSHA" status to the PSM program. These awards, our ongoing programs, and our certification letter stating full compliance with RMP regulations, demonstrates our commitment to the safety and health of our employees and the community. As stated the Monsanto, Augusta site utilizes two toxic chemicals, ammonia and chlorine, that are regulated by RMP. The site does not have any chemicals that are in sufficient quantity on the list of 63 regulated RMP flammables. An Offsite Consequence Analysis (OCA) has been conducted for the worst case scenario for the largest maximum inventory toxic, ammonia, and an alternative case scenario for ammonia and chlorine. The worst case considers that the entire volume of the vessel, V-103, is filled with anhydrous ammonia, liquified under pressure and is spilled and vaporized within a ten minute time frame. No mitigation is considered in this scenario. This situation is considered only to meet RMP requirements; it is not considered a credible scenario in reality. The regulation also requires an alternative scenario be considered for each toxic meeting RMP requirements. The ammonia scenario considers that a flange leak occurs within the system at a frequently utilized connection and has a duration of one minute before mitigation controls shut the system down; the remaining nine munutes of the release is the time required for the piping in question, between automatic shut off valves,to be emptied of the material. ERT personnel respond to each of the ammonia releases, however additional mitigation of the quantity released is not possible. The quantity released and the nature of the release for the worst case scenario eliminates ERT mitigation. The ERT also responds to the alternative case scenario for ammonia, however the automatic shutoff system responds and stops the release before personnel can further mitigate the release. The toxic end point for the worst case scenario is 4.4 miles while the alternative case scenario only 0.1 mile, reaching the boundaries of the site but having no off-site impact for the population or environment. The chlorine scenario assumes that a 3/16" hole developes in the feed tubing from the chlorine cylinder to the distribution manifold. The area chlorine monitors detect the release and alarm at 0.3 ppm. The leak continues until the area operators don the proper PPE and manually shuts off the valve on the chlorine cylinder. Total duration of the leak is 15 minutes. Atmospheric conditions are stability class D at 77 F. The toxic end-point extends to 0.2 miles in a radiating circle from the point source. Off-site impact is minimal having no population affected and no environmental receptors. Monsanto, Augusta utilizes many safety tools and practices to maintain and improve site equipment and operations. Some examples of these systems are: 1. Employee participation in the development and implementation of all elements of the PSM program 2. Process Hazards Analysis (PHA) conducted every 5 years, or sooner for all PSM covered processes using the HAZOP methodology for all studies. 3. A Mechanical Integrity (MI) system that requires regular inspection and testing of critical equipment, relief devices and other systems utilized to maintain safe operations. 4. Operating Instructions (OI) and Training on the OI's that is maintained current by annual review and updating. Verification of understanding is utilized and maintained on each employee. 5. A Management of Change (MOC) is utilized for every non replacement in kind change to the PSM and RMP covered processes. Pre Startup Safety Reviews (PSSR) are conducted on all MOC's in covered process areas. This summary provides information into the operation and maintenance of the Monsanto, Augusta site to provide a safe environment for site personnel and the community at large. For additional information concerning RMP or PSM, please contact our ESH department at (706) 303-5000.- |