Peninsula Copper Industries, Inc. - Executive Summary

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Policy Statement and Regulatory Basis 
Peninsula Copper Industries, Inc. (PCI), its management and employees are committed to the safe, responsible management of all manufacturing operations.  The safety of our employees and neighbors is of primary importance.  Our combined safety programs include the Risk Management Program, Process Safety Management Program for Highly Hazardous Chemicals (PSM), Emergency Response Plan, and other supporting policies and procedures.   These are created and maintained to provide a high degree of protection against the uncontrolled release of ammonia and provide sufficient warning to employees and nearby residents of any incident with the potential for a catastrophic release. 
PCI's Risk Management Plan  meets the requirements of 40 CFR part 68, Risk Management Plans and, 29 CFR part 1910.119, Process Safety Management of Highly Hazardous Chemicals.  PCI's Emerg 
ency Response Plan has been submitted and approved by the state of Michigan and Houghton Co. LEPC, as required by EPCRA  and is revised and updated as needed. 
PCI's Risk Management Plan applies to anhydrous ammonia (CAS 7664-41-7), its storage and use pursuant  40 CFR part 68 and 29 CFR 1910.119 as well as State of Michigan Air Quality Division, Air Use Permit Special Conditions.   Ammonia -containing solutions containing less than 20% ammonia by weight are exempt from these regulations. 
Approach to Safety 
Safety is addressed throughout the corporation using cross-functional teams to advise and assess its current programs and evaluate the need for additional processes and procedures to maximize safety for its employees and community neighbors.  Expert support resources from government and industry supplement internal resources and provide necessary guidance on safety management as well as compliance with all applicable regulations.  
Process Description 
PCI manufactures cupric ox 
ide, a finely divided black powder that is used in a variety of industrial and agricultural applications.   The first step in the production of cupric oxide involves dissolving metallic copper in a solution of ammonia, carbon dioxide and water.  The anhydrous ammonia is used as part of the leaching solution.  The copper-rich solutions are oxidized, precipitated, and dried to produce the resultant product, cupric oxide. The anhydrous ammonia (NH3) is sparged into the solution tank within the plant.  Once in solution the concentration of ammonia normally ranges from 8%-12% by volume.   
Anhydrous ammonia is received in the liquid state and stored as a liquid with a vapor space above the liquid. Maximum storage capacity is 12,000 gallons.  The tank is filled to approximately 80% capacity, or 9,600 gallons.  This practice allows room for the vapor space in the tank.  Tank pressure is about 80-90 psig.  Ammonia is delivered to the system as a vapor under regulated pressure of 25-30 psig. 
Worst Case Scenario 
The worst case scenario involves the release of the entire contents of the ammonia storage tank within a 10 minute time period.  The maximum volume contained in the tank is 56, 200 pounds of anhydrous ammonia.   A total release could impact a population of approximately 2000 people within a 2.8 mile radius.   PCI's Offsite Emergency Response Plan was developed jointly between PCI and the Houghton Co. Office of Emergency Measures, approved by the county  Local Emergency Planning Committee in 1992 and submitted to the state of Michigan.   
The plan is filed with the Houghton County Office of Emergency Measures,  the state of Michigan, and the Hubbell Volunteer Fire Department.  Two table top incident response exercises have been conducted by the LEPC and responder agencies and a full scale onsite exercise may be conducted in 1999.   PCI and its employees have been trained to provide information and logistical support to responder agencies.  No active response by PCI  
employees is provided at present. 
The potential for a catastrophic release appears to be minimal.  The storage facility is enclosed in a fenced area and heavy guarding protects the tank from accidental impact from yard equipment and delivery vehicles.  The tank and all associated piping are equipped with excess flow valves, emergency shut off valves, both automatic and manual.   The entire ammonia storage facility is permitted by the  Michigan Department of Environmental Quality, Air Quality Division.  Annual inspections are performed by state officials as well as the inspections required by the Process Safety Management regulations and other state and federal occupational safety agency regulations. 
Alternative Scenario 
The alternative scenario describes a potential release if a vapor feed pipe to the plant and its associated shut off valve should fail.  Due to the this exit avenue, vapor and liquid would likely escape into the immediate area  and continue until the release was det 
ected.  Any disruption of flow to the plant would be detected, at a maximum, after one hour due to operating procedures which require the flows and tank volume to be manually recorded.  This scenario would impact perhaps 30 residents or employees of neighboring businesses.  Preventive measures as described above  should minimize the likelihood of any uncontrolled release even for brief periods of time. 
Prevention Program Elements 
PCI has instituted a comprehensive prevention program as required by the OSHA's Process Safety Management regulations and the permit conditions in our state of Michigan Air Use Permit.  LaRoche Industries is the owner of the storage tank and associated equipment upstream of the vapor lines to the plant.  LaRoche conducts regular inspections on all components of the system to ensure safe, reliable operation.   
PCI involves employees in this program at all levels,  in cross-functional safety teams whose responsibilities include the evaluation of internal saf 
ety processes related to ammonia storage and handling.  Frequent inspections provide current information on the condition of the equipment and its operation as well as reinforcing the awareness of the hazards associated with anhydrous ammonia.  PCI's Hazard Communication Training Program focuses heavily on the hazards and safe handling of ammonia. 
Accidental Release Report 
PCI has neither observed nor recorded any incidents of accidental release of anhydrous ammonia in the past five years. 
Emergency Response Program 
As described above, PCI takes a defensive response posture.  Any employee who observes an unplanned release is directed to either immediately contact a supervisor or, if in his/her judgement the release threatens the safety and health of plant employees or residents the emergency response procedures will be activated.  The appropriate reaction is to activate the evacuation alarm and assemble plant personnel to the designated meeting location(s) place.  Emergency respo 
nse agencies shall be notified as soon as it is safe to do so.   PCI management will be notified and serve as liaisons between responder agencies and the company.  PCI's internal emergency response procedures are being reevaluated by a cross-functional safety team at this writing.  PCI's Emergency Response Plan and EPCRA offsite response plan will be updated during the summer of 1999. 
Training is accomplished annually or during new employee orientation.   Local VFD's are provided a plant tour and review of  PCI's operation annually.   County incident response exercises include PCI staff. 
Planned Safety Improvements 
PCI's entire safety program including the specific programs referenced in this document are continually being reviewed and updated.  PCI's PSM program is presently being evaluated and updated where needed.   This approach is part of the company's continuous improvement philosophy.   Additional monitoring equipment is being evaluated to determine if installation would imp 
rove the overall safety of the ammonia storage system..  Water sprays are also a possible option if they are deemed appropriate for our type of installation.  We are consulting with our supplier and regulatory staff to investigate what systems are being used throughout the industry.   A fact finding report will be available for internal review by the end of second quarter 1999.
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