U.S. Vanadium Corp. - Executive Summary |
|
A. Accidental Release Prevention and Emergency Response Policies The use of Chlorine (Cl2) and Titanium tetrachloride (TiCl4) in our halides manufacturing facility is operated and maintained in a safe and responsible manner. We have implemented release prevention programs and emergency response policies in order to preserve and protect the health of employees. These programs and policies also serve as protection of human health and the environment of the communities surrounding U.S. Vanadium. B. Stationary Source and Regulated Substances Our Niagara facility includes a halides manufacturing process. Cl2 and TiCl4 are the only toxic chemicals regulated under the RMP Rule by Part 68 that U.S. Vanadium has on-site as part of a process. U.S. Vanadium has no flammable substances regulated by Part 68. C. Offsite Consequence Analysis Scenarios Releases of Cl2 and TiCl4 have been modeled as follows: Worst-case Release Scenario Cl2 The worst-case scenario for a release o f chlorine reaches the toxic endpoint at a radius of 4.5 miles and would reach a residential population of approximately 77,000. Public receptors affected by this release are residences, schools, hospitals, public parks, and businesses. Worst-case Release Scenario TiCl4 The worst-case scenario for a release of titanium tetrachloride reaches a radius from the site is 0.61 miles to the toxic endpoint. The public receptors located within this release radius are residences, recreation areas, and major industrial sites. Alternative Release Scenario Cl2 The alternate case or more-likely scenario for a release of chlorine will reach a radius of 0.58 miles. The public receptors located within this release radius are residences, recreation areas, and major industrial sites. Alternative Release Scenario TiCl4 The alternate case or more-likely scenario for a release of titanium tetrachloride is reached at 0.17 miles. The public receptors affected by this alternative scen ario would include major industrial sites. D. General Accidental Release Prevention Program and Chemical- Specific Prevention Steps As part of our general prevention program, we have integrated chemical- specific prevention steps that help minimize the possibility of any leak of a hazardous substance that poses a potential danger both onsite and/or offsite. Our program includes the following steps and programs that lead to successful risk reduction and accident prevention: 1) Process safety information 2) Process hazard analysis 3) Operating procedures 4) Training 5) Mechanical Integrity 6) Management of change 7) Pre-startup review 8) Compliance audits 9) Incident investigation 10) Employee participation 11) Hot work permit 12) Contractors E. Five-year Accident History As a result of U.S. Vanadiums programs on safety and accidental release prevention, we have had no reportable releases in the past 5 years involving substances covered under Part 68. F. Emergency Response P rogram Our emergency response plan provides key background, planning and training for the handling of and responding to releases of regulated substances. The plan also defines procedures for proper notification of off-site public receptors (residences) in an emergency situation. Procedures for notification of local authorities with which our plan is coordinated are also given in the plan. The main objective involved in the implementation of this plan is the protection of workers, the public and the environment during emergency situations. G. Planned Changes to Improve Safety U.S. Vanadium conducts Process Hazard Analyses (PHAs) that develop a list of suggestions for the improvement of process safety. These PHAs are performed every 5 years or when a process is changed, whichever comes first. The list of suggestions produced from the PHA is used to help improve safety for the employees, the pubic and the environment by reducing the risk of potential releases of regu lated substances and emergency situations. |