St. Marks Powder, Inc. - Executive Summary |
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Introduction: St. Marks Powder, Inc., owns and operates a manufacturing facility near St. Marks, Florida. St. Marks Powder, Inc., is a wholly owned subsidiary of Primex Technologies, Inc., and conducts business under the name "Primex Technologies Ordnance and Tactical Systems Division". In this document, the facility will be referred to as "PRIMEX". The accidental release prevention and emergency response policies at PRIMEX: PRIMEX's overall approach to chemical safety is to prevent incidents, and respond effectively if incidents occur. It is PRIMEX policy to conduct safety reviews/investigations, which include accidental release prevention, whenever changes are made, incidents occur, or at least every five years. It is PRIMEX policy to maintain an on site emergency response capability that includes fire and hazardous materials hazards mitigation. The stationary source and the regulated substances handled: The facility manufactures smokeless propellant for ammunition. One o f the steps of the product production process uses nitric acid and oleum, which is also known as fuming sulfuric acid. Both nitric acid and oleum are regulated substances under the EPA's Risk Management Plan (RMP) regulation. The worst-case scenario and the alternate-case scenario: The worst-case scenario is the failure of a 12,000 gallon tank containing nitric acid and oleum. A containment dike limits the extent of the liquid released and also limits the exposed surface area. The release rate is reduced to 14.0 pounds per minute of nitric acid. This scenario will have some limited offsite impact. The alternate-case scenario is a transfer hose failure resulting in the release of 720 pounds of nitric acid and 680 pounds of oleum. No offsite impact would occur. Administrative controls and mitigation measures include a manual shutoff valve. The general accidental release prevention program and chemical-specific prevention steps: The general accidental release prevention progr am involves: Safety reviews of all new projects. Safety reviews on all changes to existing manufacturing operations. Safety reviews on all manufacturing operations at least every five years. Investigation of all incidents as they occur. The chemical-specific prevention steps include: Specific material handling procedures are enforced to minimize the potential for release. Operators are trained and tested for acid handling responsibilities. Acid tanks and piping are constructed of stainless steel. Acids tanks are tested annually to ensure adequate tank integrity. The five-year accident history: PRIMEX has had no accidents involving accidental release of RMP regulated substances during the last five years. The emergency response program: PRIMEX's emergency response program includes provisions for coordination with outside emergency responders. PRIMEX's on site emergency responders are fire and hazma t trained. Public notification is accomplished through the Wakulla County Sheriff's Office, Division of Emergency Management. Planned changes to improve safety: At this time, there are no planned changes involving RMP regulated chemicals. Employees are continuously retrained to ensure maintenance of safety awareness. |