COLUMBUS - Executive Summary |
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Executive Summary Royster-Clark Agribusiness Columbus, Ohio A. Introduction Royster-Clark Agribusiness, Columbus Granulation Plant, is a facility wholly owned and operated by Royster-Clark Agribusiness of Collinsville, Illinois. The plant manufactures granular fertilizers for use by farmers throughout Ohio, Indiana, Illinois, Michigan, Kentucky, West Virginia, and New York. The process combines various amounts of nutrient containing dry and liquid materials into homogenous granules. It is a physical and chemical process developed in the 1950's and used in over 20 plants in the US and numerous others throughout the world. One of the materials necessary for this method is anhydrous ammonia. It is stored under pressure in two 30,000-gallon tanks which are filled from tankcars or trucks. Due to the quantity of this material maintained on site, Royster-Clark Agribusiness falls under both the EPA's Risk Management Program (RMP) and OSHA's Process Safety Management (PSM) standard. Royster-Clark Agribusiness believes safety and concern for the environment must be a priority to all personnel and handles anhydrous ammonia with these fundamentals in mind. B. Accidental Release Prevention Policies and Program This facility is in compliance with OSHA PSM standards. The standards were developed specifically by OSHA to prevent the type of catastrophic failures which could lead to a release. The program is very thorough and the main elements are listed below: * Employee Involvement * Process Safety Information * Process Hazard Analysis * Operating and Maintenance Procedures * Safe Work Practices * Employee Training * Contractor Training * Pre-Startup Safety Reviews * Mechanical Integrity * Hot Work Permitting * Management of Change * Accident Investigation * Internal Audits & Recordkeeping The OSHA PSM standard plays an integral part in the safety efforts of this facility, but is not the only means of prevention. Our employees receive training on a multitude of i ssues in our monthly safety meetings. This knowledge is reinforced with the use of computer based training modules. Royster-Clark Agribusiness believes safety and concern for the environment must be second nature to all employees. The Ohio Department of Agriculture also performs annual inspections on our anhydrous ammonia system. Their intention is to ensure no conditions exist which could pose any threat of accidental release. Our company's Environmental, Health and Safety department also performs annual inspections of our entire facility and takes special care to ensure the integrity of our anhydrous ammonia system. C. Worst Case Scenario The worst case scenario is considered by the EPA to be a catastrophic rupture of a tank causing the complete loss of the contents over a 10-minute period. In addition, this event must be modeled under the worst possible atmospheric conditions. The EPA makes the following statement about the worst case scenario: "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) The worst case modeling for this facility used The Fertilizer Institute (TFI), Degadis Model, which is recognized, accepted, and approved by EPA. It involves the loss of all the contents from one 30,000-gallon tank. Because of past operating experience, inspections performed on the tanks and the PSM program, Royster-Clark Agribusiness believes the chances for a catastrophic rupture is extremely unlikely. D. Alternative Release Scenario The Risk Management Plan also requests each facility to evaluate a more likely release scenario. The most likely release scenario at this facility would be a rupture of a transfer hose during the unloading process. Railcars are unloaded on a frequency of approximately one to two per week. Although excess flow valves are in place to prevent the release from continuing more than a few seconds, a two-minute scenario was chosen. Charts created by TFI which are recognized, accepted and approved by the EPA were used to model such a release. E. Emergency Response In the unlikely event of any type of release, the facility has an Emergency Action Plan which gives detailed guidelines on how to handle such an event. This plan is reviewed annually with all employees so each person understands what to do if an eve nt occurs. The local emergency planning commission (CEPAC) and fire department have copies of this manual and are familiar with our site. The fire department conducts annual walk-through inspections and their special Hazardous Materials teams have visited the facility in order to familiarize them with our operation. Royster-Clark Agribusiness promotes open communication with these agencies and is confident these highly trained groups are prepared in the unlikely event of a release. F. Five Year Accident History Royster-Clark Agribusiness 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. Extensive programs and procedures are in place to maintain that record. G. Summary The employees of Royster-Clark Agribusiness are extremely proud of its safety record and the continuous improvements in both safety and environmental responsibility. We believe that with the programs and policies in place, and the continued efforts of our personnel, we will be able to maintain a safe workplace and community for all in the years to come. Royster-Clark Agribusiness is committed to maintaining this facility responsibly and will use all means necessary to ensure its safety. |