Apex Operations - Executive Summary |
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OMG Americas - Apex Operation Risk Management Plan EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies: OMG Americas Apex Operation is a chemical manufacturing plant that specializes in the production of cobalt and tungsten value added chemicals. Much of our feed material comes from the residues and by-products of other industries which is recycled by OMG and the valuable metals are recovered. Safety, health, and environmental issues are an important concern for OMG and compliance with all regulations and public safety issues are a high priority. Our emergency response plans include a written "Hazardous Materials Emergency Response Plan" and a "Spill Prevention Control and Countermeasure Plan" that include procedures on how to control potential accidental releases, how to minimize off-site impacts, and proper notification of emergency responders and regulatory agencies. We have a fully trained Emergency Response Team with a designated Emergency Response Coordinator. 2. Stationary source and regulated substances handled: 7 The primary activity of the facility is the production of cobalt and tungsten chemicals using both hydro-metallurgical and pyro-metallurgical processes. 7 Anhydrous ammonia is used as a processing aid in the recycling of tungsten material and becomes a formulation component of the final product, ammonium paratungstate (APT). 7 OMG maintains one pressurized tank of liquified anhydrous ammonia with a maximum capacity of 9,500 gallons (54,000 lbs). 3. The worst-case release scenario, including administrative controls and mitigation measures to limit the distance for each scenario: OMG Americas is only required to report a worst-case release scenario, an alternative release scenario is not required for Program 1 RMP analysis. 7 Worst-case scenario - Failure of the storage tank would release 54,000 pounds of anhydrous ammonia. It is assumed that the entire contents are released as a liquid within a 10 min ute period which will slowly vaporize to ammonia gas. The release will be passively mitigated by a cement containment dike with 3' high walls and cement floor to prevent the spread of a spill. The limited surface area will slow down the vaporization rate of ammonia gas. 7 The distance to the endpoint of 200 ppm for the worst-case scenario is 0.5 miles. 4. The general accidental release prevention program and the specific prevention steps: This facility complies with all applicable OSHA regulations (Hazardous Waste Operations and Emergency Response) and EPA regulations (including Risk Management Planning, Spill Prevention Control and Countermeasure Plan). 5. Five-year accident history: OMG Americas Apex Operation has not had any accidental releases of any chemicals in the last 5 years. 6. The emergency response program: The facility has a detailed emergency response plan as well as a trained Emergency Response (Hazmat) Team. The Emergency Response Team conducts routine training which includes hands-on mock emergency drills. The local fire department and emergency responders have had tours of the facility and have received copies of the facility's emergency response plan. 7. Planned changes to improve safety: Standard operating procedures for the safe unloading and handling of anhydrous ammonia will be reviewed and updated as necessary. OMG Americas plans to work more closely with the fire department and Local Emergency Planning Commission and to provide the opportunity for emergency responders to train at our facility. |