ORANGEBURG - Executive Summary |
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Executive Summary Royster-Clark Agribusiness ORANGEBURG, SC A. Introduction The Royster-Clark Agribusiness, Orangeburg plant is an ammonium polyphosphate liquid fertilizer production facility. The facility unloads ammonia railcars and trucks into storage tanks. The ammonia is then used in the production of ammonium polyphosphate liquid fertilizer. Royster-Clark Agribusiness, Orangeburg Plant has an excellent safety record with no deaths or serious injuries to plant personnel or contractors due to RMP covered process. The facility's safety record is a direct result of much emphasis on safety in the plant on the part of management and employees. B. Accidental Release Prevention Policies and Program: The facility is in compliance with OSHA PSM Standards. Information including piping and instrumentation diagrams (P&ID's), operating procedures, management of change (MOC) documentation, and other pertinent documents are on file in the plant office. The Royster-Clark Agr ibusiness Technical Services staff furnishes assistance and performs safety and environmental audits. Additionally, the Royster-Clark Agribusiness Safety Coordinator performs safety training on a regular basis. The ammonia tanks and associated equipment is covered by a mechanical integrity inspection and testing schedule and is constantly monitored. Safety meetings for all employees are held at least every month at this facility. In addition to safety training classes, each employee has taken numerous computer based training courses; several employees are certified in First Aid and CPR. Royster-Clark Agribusiness believes safety and concerns for the environment must be second nature to all employees and contractor personnel. C. Emergency Response Policies and Program: Each Royster-Clark Agribusiness facility employee is trained to be familiar with the Emergency Response policies and procedures through safety reviews and other plant safety meetings. The Emergency Action Pl an is reviewed on an annual basis as part of the employee meeting to provide refresher training. Safety policies and procedures are also reviewed on an annual basis. The local LEPC and Fire Department personnel are furnished a copy of the Emergency Action Plan and invited to tour the facility on a regular basis. The facility Emergency Action Plan covers such things as accidental releases of plant chemicals, natural disasters, emergency response practices and procedures, and process safety topics. The plan is reviewed each year with all employees and reviewed with the local fire department on a regular basis. D. Worst Case Scenario: The facility has four anhydrous ammonia storage tanks on site. All tanks are equipped with safety relief valves, and excess flow valves. The EPA requires a very conservative worst case scenario to be a catastrophic rupture of the largest tank with a complete loss of product over 10 minutes. It should be noted that the EPA describes the worst-ca se scenario as: "Because the assumptions required for the worst-case analysis are very conservative, the results likely will be very conservative...These endpoints are concentrations below which it is believed nearly all individuals could be exposed for one half hour to one hour without any serious health effects. In addition, the worst case analysis is carried out using very conservative assumptions about weather and release conditions. The distance to the endpoint estimated under worst-case conditions should not be considered a zone in which the public would likely be in danger; instead, it is intended to provide an estimate of the maximum possible area that might be affected in the unlikely event of catastrophic conditions." (EPA550-B-98-003, Section4.2) Royster-Clark Agribusiness believes the chances for a catastrophic rupture are extremely unlikely because of the routine testing, in-plant safety systems, periodic inspections, and constant monitoring. E. Alternative- case Scenario: The ammonia tanks are filled via railcars and trucks. The most likely release scenario would be a rupture of a hose connecting the railcar or truck and ammonia unloading system. Railcars are unloaded on a frequency of three per month. Trucks are unloaded on a frequency of approximately fifteen per year. The conditions picked for this scenario are those which would create a maximum loss of anhydrous ammonia. F. Five Year Accident History: Royster-Clark Agribusiness, Orangeburg, has an excellent safety record with no deaths or serious injuries to any of its personnel or contractors as a result of the RMP covered process. In addition, there have been no accidents resulting in releases of ammonia with off site consequences during the entire operations period. G. Planned Changes to Improve Safety: The Orangeburg plant continuously looks for ways to enhance the safety of the plant. Monthly safety inspections are conducted which result in corrective action s; Process Safety Management audits are conducted every three years; and corporate-sponsored environmental, health, and safety audits are conducted annually. H. Summary: The employees of Royster-Clark are extremely proud of our safety record and vast improvements made in both environmental stewardship and safety over the last twenty years. We believe, with our programs and policies in place and with the continued efforts of our personnel, we will maintain our safety record and our safe plant environment for the public, our customers, and our employees for years to come. |