Feldspar Monticello Plant - Executive Summary

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INTRODUCTION 
 
The Feldspar Corporation is committed to operating in a manner that is safe for Feldspar employees, the public, and the environment.  As part of this commitment, the Feldspar Monticello Plant has established a system to help ensure safe operation of the processes at this facility.  Once component of this system is a risk management program (RMP) that helps manage the risks at the Feldspar Monticello Plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule).  One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at the Feldspar Monticello Plant.  This plan is intended to satisfy the RMPlan requirement of the RMP rule (paragraphs 68.150 through 68.185) and to provide the public with a description of the risk management program at the Feldspar Monticello Plant. 
 
 
 
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
The Feldspar Corporation is committed to the safety of workers and the public and to the preservation of the environment through the prevention of accidental releases of hazardous substances.  The Feldspar Monticello Plant implements reasonable measures to prevent such releases.  In the event of an accidental release, the Feldspar Monticello Plant will control and contain the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. 
 
 
THE FELDSPAR MONTICELLO PLANT AND REGULATED SUBSTANCES 
 
The Feldspar Monticello Plant processes feldspar ore into a form that can be used in such products as china and cosmetics.  Aqueous hydrofluoric (HF) acid is used to control pH in the floatation portion of the feldspar refining process.  HF acid at solution concentrations of 50 wt% or greater are regulated by the RMP rule.  Although dilute (much less than 50 wt%) HF acid solutions  
are used in the floatation process, 70 wt% HF acid is stored in a large tank at the Feldspar Monticello Plant. 
 
A maximum of 3,200 gallons of 70 wt% HF acid is stored in one 6,400-gallon tank located at the Feldspar Monticello Plant.  The weight of HF acid in 3,200 gallons of 70 wt% solution is approximately 33,000 lb, which exceeds the RMP rule threshold quantity for HF acid in a process (1,000 lb).  Because the HF acid storage process is not covered by the requirements of the Occupational Safety and Health Administration's process safety management regulation, and because the potential exists for offsite consequences resulting from an accidental release of HF acid, the process falls under Program 2 of the RMP rule. 
 
 
OFFSITE CONSEQUENCE ANALYSIS 
 
Based on the requirements of the RMP rule, the Feldspar Monticello Plant must perform an offsite consequence analysis for one worst-case and one alternative release scenario for aqueous HF acid, a toxic substance.  The worst-case release sce 
nario is failure of the 6,400-gallon storage tank, releasing 33,000 lb of aqueous 70 wt% HF acid.  A diked area contains the released aqueous HF acid, which evaporates and forms a vapor cloud.  The maximum distance to the toxic endpoint concentration is 1.6 miles.  Several houses are located within this distance from the storage tank; based on 1990 census data, approximately 97 people live within this radius.  One roadside park and a portion of the Oconee National Forest also lie within this area. 
 
The alternative release scenario for aqueous hydrofluoric acid is rupture of a 1-inch diameter pipe connecting the aqueous HF acid (70 wt%) storage tank to a holding tank inside of the processing plant.  The pipe contains 70 wt% HF acid only when acid is pumped from the storage tank to the holding tank, which occurs intermittently during the day.   A Feldspar employee observes the pumping throughout its duration.  Therefore, this scenario assumes that the solution is released through the hol 
e for 2 minutes before a worker detects the release and isolates the line.  The released acid forms a pool, with HF evaporating from the pool and forming a vapor cloud.  The maximum distance to the toxic endpoint is 0.06 mile.  No public or environmental receptors lie within this distance from the storage tank. 
 
 
SAFETY INFORMATION 
 
The Feldspar Monticello Plant complies with Mine Safety and Health Administration (MSHA) regulations.  The Feldspar Monticello Plant maintains material safety data sheets (MSDSs) for hazardous substances that are handled at the facility, including 70 wt% HF acid.  The MSDSs document the physical properties of these hazardous substances.  Also, the HF acid storage tank was constructed according to the ASME Boiler and Pressure Vessel Code, Section VIII. 
 
 
HAZARD REVIEW 
 
The Feldspar Monticello Plant performs and periodically updates hazard reviews of the HF acid storage process to help identify and control process hazards.  Checklists are used to guide the ha 
zard review.  These checklists include items to help ensure that the Feldspar Monticello Plant operates and maintains the equipment in a manner consistent with applicable design specifications and regulations. 
 
 
OPERATING PRECEDURES 
 
The Feldspar Monticello Plant develops and maintains operating procedures to define how tasks related to process operations should be performed.  The operating procedures are used to (1) train employees and contractors and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. 
 
 
TRAINING 
 
The Feldspar Monticello Plant trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks.  A training documentation file is maintained to help ensure that refresher training is provided as necessary. 
 
 
MAINTENANCE 
 
The Feldspar Monticello Plant properly maintains the process equipment.  The Feldspar maintenance program includes (1) procedures to safely guide wo 
rkers in their maintenance tasks, (2) worker training in the maintenance procedures, and (3) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails. 
 
 
COMPLIANCE AUDITS 
 
The Feldspar Monticello Plant performs periodic compliance audits of the 70 wt% HF acid process to verify that it is operating in compliance with the requirements of the RMP rule.  A compliance audit report is prepared after each audit, and any deficiencies noted by the audit are corrected in a timely manner. 
 
 
INCIDENT INVESTIGATIONS 
 
The Feldspar Monticello Plant investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment.  The Feldspar Monticello Plant trains employees to identify and report any incident requiring investigation.  An investigation team is assembled, and the investigation is initiated within 48 hours of the incident.  The results of the investigation are documented, recommendat 
ions are resolved, and appropriate process enhancements are implemented. 
 
 
HF ACID-SPECIFIC PREVENTION STEPS 
 
Industry standards are followed at the Feldspar Monticello Plant to help ensure safe handling of aqueous HF acid.  The vendor supplies aqueous HF acid via a Department of Transportation (DOT)-approved tank truck and follows DOT standards when loading the aqueous HF acid storage tank.  The storage tank design and construction are consistent with ASME Boiler and Pressure Vessel Code, Section VIII.  Workers who perform operations involving HF acid receive training emphasizing safe handling procedures for HF acid developed by the Feldspar Monticello Plant. 
 
 
FIVE YEAR ACCIDENT HISTORY 
 
The Feldspar Monticello Plant maintains a 5-year accident history that fulfills the requirements of the RMP rule.  This history indicates a good record of accidental release prevention over the past 5 years.  No releases of regulated substances have occurred from the Feldspar Monticello Plant in the  
last 5 years that have resulted in consequences of interest (i.e., deaths, injuries, or significant property damage on site; or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site). 
 
 
EMERGENCY RESPONSE PROGRAMS 
 
The Feldspar Monticello Plant has coordinated with local emergency response officials (the Jasper County EMS) regarding the hazardous materials stored on site, including 70 wt% HF acid.  The Feldspar Monticello Plant provides appropriate information to the Jasper County EMS, and they maintain regular dialogue with each other. 
 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
No changes to improve process safety currently are planned.  However, the Feldspar Monticello Plant will stay alert to changes that could improve process safety in the future.
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