PCS Phosphate - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: 
PCS Phosphate has published policies that address the company's position on protecting the environment. Our Environmenal Policy states -  PCS is committed to excellence in employee safety, environmental protection, and operations.  We believe safety, envirionmental protection, and product stewardship go hand-in-hand. 
PCS Phosphate Savannah Ammonia Terminal bears a special responsibility for the stewardship of its environment and natural resources.  It requires that we prevent any possible negative impact to the greatest extent possible.  Each employee shares in the responsibility of environmental protection.  It is considered an integral part of every task we perform. 
 
STATIONARY SOURCE: 
49,000 short ton refrigerated storage tank. 
 
WORST CASE SCENARIO: 
Failure of refrigerated ammonia storage tank resulting in loss of 98,000,000 pounds of ammonia. 
 
ALTERNATIVE CASE SCENARIO: 
Failure of loading valve on tank car resultuing in 
loss of 60,000 pounds of ammonia. 
 
GENERAL ACCIDENTAL RELEASE PREVENTION PEOGRAM: 
The Savannah ammonia terminal is subject to OSHA's PSM regulation.  Established safety and operating procedures provide a system to reduce the potential for accidental releases. Pre and Post loading inspections are conducted on each unit prior to shipment.  Weekly, monthly, quarterly, and annual inspections provide a system to locate potential problem areas.  A work order system is in place to formally notify maintenance of any problems.  Any noted condition is tracked until completion. 
 
FIVE-YEAR ACCIDENT HISTORY: 
No accidental releases have occured in excess of the 100 pound Reportable Quantity in the last five years from a covered process at the terminal. 
 
EMERGENCY RESPONSE PROGRAM: 
PCS Phosphate has in place a Comprehensive Emergency Management Plan (CEMP) designed to address prevention, preparation, response, and recovery from an accidental release of a regulated substance at the terminal.  The ter 
minal, its employees, and business 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 standard aid in the prevention and management of potential emergency situations.  PSM is more closely alligned to prevention through the use of process Hazard Analysis, Operating Procedures, Mechanical Integrity, Employee Involvement, and Management of Change Procedures. 
The CEMP has six basic elements; Basic Plan, Prevention, Preparedness, Response, Hazard Specific  Procedures, and Recovery. 
The use of Safety and Operating Procedures provide a system to reduce the potential for accidental releases by focusing on specific components of each shipment and process.  The safety and operating procedures manual consists of 16  safety procedures and 39 operating procedures uniquely designed for specific job tasks.  The manual is reviewed annually and revised as necessar 
y to address any needed changes or recommendations.  Each and every ourbound shipment receives a pre-loading and  post loading inspection by the loading technician.   
 
PLANNED CHANGES TO IMPROVE SAFETY: 
PCS has investigated reducing the containment size of the storage tank to lessen the potential impact of an accidental release.
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