Soda Springs Facility - Executive Summary |
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Kerr-McGee Chemical LLC (KMC LLC) is committed to the guiding principles of CMA's Responsible Care. KMC LLC has prepared a policy stating this and will provide the resources necessary to meet the requirements of these guiding principles. The programs that have been developed to meet Process Safety Management (PSM) and the Risk Management Program (RMP) are based on these guiding principles and meet the requirements of the regulations. The Soda Springs facility has developed an emergency response plan that meets the requirements of the Responsible Care program. This plan has been modified to include the requirements of Subpart E of RMP. The emergency response plan is site specific and has been discussed with the local authorities and emergency response groups. The KMC LLC Soda Springs facility produces several vanadium compounds. The vanadium is extracted from a by-product from a neighboring facility. The steps taken to extract the vanadium include sizing, conversion, leaching, p urification and finishing. The vanadium compounds are shipped to our customers in various size drums on trucks. Safety is a paramount concern of the KMC LLC Soda Springs facility. The facility has operated almost 19 years without a lost-time accident and has gone over two years without an OSHA recordable injury. The facility has been an OSHA STAR worksite since 1987. Anhydrous ammonia is used in the purification step of the vanadium extraction process. The ammonia is added to the process as a gas and is used to promote the precipitation of the vanadium compounds from an aqueous solution. The facility stores approximately 40,000 pounds in a single storage vessel at the site. The ammonia is delivered to the facility by truck. The facility uses approximately 42,000 pounds of ammonia each month. As required by RMP, the facility has prepared a worst case scenario and an alternative case scenario for an ammonia release. The worst case scenario involves a tank rupture and 40,000 po unds of ammonia as a gas is released in 10 minutes. The worst case scenario occurs during a time when there is little wind and the atmosphere is very stable. This means that little dispersion will occur. The alternative case scenario involves a pipe or transfer hose failure or leak. In this scenario, approximately 1,000 pounds of ammonia gas is released in 10 minutes. More typical atmospheric conditions are present. There are no environmental or human receptors that would be affected by this type of release. The facility has taken numerous steps to prevent a release of any size. Some of the steps taken include installation of pressure relief valves on the storage tank that are designed to open well before the design pressure of the tank is reached. There are high pressure alarms on the system that are activated at a pressure lower than the setpoint of the relief valves. In the event that the high pressure alarm is activated, the production operator will take the steps neces sary to bring the tank pressure down to the acceptable operating range. The tank is equipped with manual and automatic valves that can be closed to isolate the tank if there is a leak in the piping from the tank. During unloading, several steps are taken to ensure that a release does not occur. The transfer hoses and fittings are inspected before use, and a production foreman is responsible for the unloading operation. Only materials that are compatible with ammonia are used and before any new materials are used, they are investigated to determine the compatability with ammonia. The tank, relief valves and piping are inspected regularly to detect any corrosion before it is severe enough to cause a release. The relief valves are tested regularly to ensure they will operate properly. The facility has implemented a prevention program that meets the requirements of OSHA PSM, EPA RMP (Program 3), and CMA Responsible Care. Some of the elements of these programs have been described a bove. The Soda Springs facility had one ammonia release in the last five years. The release occurred on March 3, 1995, and approximately 410 pounds of ammonia were released when a transfer hose connection failed. The release was reported to the necessary agencies and there were no on- or off-site impacts or injuries associated with this incident. There were no evacuations or alerts needed as a result of the release. All of the facility employees are trained to respond to an emergency as described in the emergency response plan. All employees are trained in the use of the necessary personal pretective equipment needed to respond to an ammonia leak. This training is done at least annually. In the event of an ammonia release, the employees would meet at the designated gathering points while a team went in to mitigate the situation. KMC LLC will continue to improve the programs that are currently in place as new technology and equipment becomes available. A process hazard analysi s has been performed for the ammonia system. This analysis is reviewed periodically to reflect any changes that might have occurred in the industry. |