CR BRIGGS - Executive Summary

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 CR Briggs                                    FEDERAL 
 P.O.Box 668 
 Trona, CA 93592 
              General Executive Summary for  
               CR Briggs Open Pit Gold Mine 
    1.     Accidental Release Prevention and Emergency Response Policies 
 We at CR Briggs  are strongly committed to employee, public and environmental 
 safety.  This commitment is demonstrated by our comprehensive accidental release 
 prevention program that covers areas such as design, installation, operating procedures, 
 maintenance, and employee training associated with the processes at our facility.  It is 
 our policy to implement appropriate controls to prevent possible releases of regulated 
 substances.  Unforeseeably, if such a release does occur, our highly trained emergency 
 response personnel are at hand to control and mitigate the effects of the release. 
    2.     The Stationary Source and  
the Regulated Substances Handled 
 Our facility's primary activities encompass open pit gold mining.  We have three regu- 
 lated substances present at our facility.  These substances include Ammonia, Propane 
 and Hydrochloric acid.  The regulated substances at our facility are involved in several 
 uses.  Ammonia is used in the Specialized Catalyst Reduction (SCR.) of oxides of 
 nitrogen.  Propane is used for heating and the firing of the dore=furnace for gold 
 recovery.  Hydrochloric acid  is used for an acid wash of carbon in the recovery of 
 The maximum inventory of Ammonia at our facility is 59255 lb. while Propane and 
 Hydrochloric acid  are present at our facility in quantities of 27779 lb. and 15658 lb. 
    3.     The Worst Case Release Scenario(s) and the Alternative Release 
    Scenario(s), including administrative controls and mitigation mea- 
    sures to limit the distances for each reported scenario 
 To evaluate the worst cas 
e scenarios, we have used the look-up tables and equations 
 provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as 
 Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance.  
 For alternative release scenario analyses, we have employed the look-up tables and 
 equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance.  
 The following paragraphs provide details of the chosen scenarios. 
 The worst case release scenario submitted for Program 2 and 3 toxic substances as a 
 class involves a catastrophic release from storage tank and transfer piping to the SCR 
 Catalyst System for reduction of oxides of nitrogen.   The scenario involves the release 
 of 59255 lb. of Ammonia in a gaseous form over 10 minutes.  Passive mitigation 
 controls such as dikes, sumps and berms are also taken into account to calculate the 
 scenario.  At Class F atmospheric stability and 1.5 m/s windspeed, the maximum 
 distance of 8.1 mil 
es is obtained corresponding to a toxic endpoint of 0.14 mg/L. 
 One alternative release scenario will be submitted for each toxic substance present in 
 Program 2 and Program 3 processes cumulatively. 
 The alternative release scenario for Ammonia involves a release from the SCR Bed 
 located at the crusher in the storage tank and transfer piping to SCR Catalyst System 
 for oxides of  nitrogen reduction.  The scenario involves the release of 59255 lb. of 
 Ammonia in a gaseous form over 10 minutes.  Passive mitigation controls such as dikes 
 and berms are taken into account to calculate the scenario.  The release is also assumed 
 to be controlled by active mitigation measures that include water curtain(s).  Under 
 neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L 
 of Ammonia is 2.8 miles. 
 The worst case release scenario submitted for Program 2 and 3 flammable substances 
 as a class involves a catastrophic release from the propane stor 
age vessel at refinery 
 used for heating in the gold extraction process.  The scenario involves the release of 
 27439 lb. of Propane.  It is assumed that the entire quantity is released as a vapor, 
 which finds an ignition source, with 10 percent of the released quantity participating in 
 a vapor cloud explosion.  Under worst case weather conditions, the maximum distance 
 of 0.24 miles is obtained corresponding to an endpoint of 1 psi over pressure.   
 The alternative release scenario submitted for Program 2 and 3 flammable substances 
 involves a release from storage vessel at the refinery used for heating in the gold 
 extraction circuit.  The release is assumed to result in a Vapor Cloud Explosion.  The 
 scenario involves the release of 27439 lb. of Propane in 10 minutes.  The release is 
 also controlled by active mitigation measures that include water curtain(s).  Under 
 neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI 
 over pressure  
is 0.16 miles. 
    4.     The General Accidental Release Prevention Program and the 
    Chemical-Specific Prevention Steps 
 Our facility has taken all the necessary steps to comply with the accidental release 
 prevention requirements set out under 40 CFR part 68 of the EPA.  This facility was 
 designed and constructed in accordance with NFPA-58 Standard, 1967 Edition.  Our 
 facility is also subject to EPCRA Section 302 notification requirements.  We also have 
 an air operating permit ID under Title V of the Clean Air Act.    The following 
 sections briefly describe the elements of the release prevention program that is in place 
 at our stationary source. 
 Process Safety Information 
 CR Briggs maintains a detailed record of safety information that describes the chemical 
 hazards, operating parameters and equipment designs associated with all processes. 
 Process Hazard Analysis 
 Our facility conducts daily pre-shift inspections to ensure that hazards associat 
ed with 
 our processes are identified and controlled efficiently.  The inspections are undertaken 
 by qualified supervisors and mine personnel with expertise in process operations and 
 are revalidated at a regular interval.  Any findings related to the hazard analysis are 
 addressed in a timely manner. 
 Operating Procedures 
 For the purposes of safely conducting activities within our covered processes, CR 
 Briggs  maintains written operating procedures.  These procedures address various 
 modes of operation such as initial startup, normal operations, temporary operations, 
 emergency shutdown, emergency operations, normal shutdown and startup after a 
 turnaround.  The information is regularly reviewed and is readily accessible to 
 operators involved in the processes. 
 CR Briggs  has a comprehensive training program in place to ensure that employees 
 who are operating processes are competent in the operating procedures associated with 
 these processes.  Refr 
esher training is provided yearly and more frequently as needed. 
 Mechanical Integrity 
 CR Briggs  carries out highly documented maintenance checks on process equipment to 
 ensure proper operations.  Process equipment examined by these checks includes 
 among others; pressure vessels, storage tanks, piping systems, relief and vent systems, 
 emergency shutdown systems, controls and pumps.  Maintenance operations are carried 
 out by qualified personnel with previous training in maintenance practices.  
 Furthermore, these personnel are offered specialized training as needed.  Any 
 equipment deficiencies identified by the maintenance checks are corrected in a safe and 
 timely manner. 
 Management of Change 
 Written procedures are in place at CR Briggs  to manage changes in process chemicals, 
 technology, equipment and procedures.  Process operators, maintenance personnel or 
 any other employee whose job tasks are affected by a modification in process 
 conditions are promp 
tly made aware of and offered training to deal with the 
 Pre-startup Reviews 
 Pre-start up safety reviews related to new processes and to modifications in established 
 processes are conducted as a regular practice at CR Briggs .  These reviews are 
 conducted to confirm that construction, equipment, operating and maintenance 
 procedures are suitable for safe startup prior to placing equipment into operation. 
 Compliance Audits 
 CR Briggs  conducts audits on a regular basis to determine whether the provisions set 
 out under the RMP rule are being implemented.  These audits are carried out at least 
 every 1 years and any corrective actions required as a result of the audits are 
 undertaken in a safe and prompt manner. 
 Incident Investigation 
 CR Briggs  promptly investigates any incident that has resulted in, or could reasonably 
 result in a catastrophic release of a regulated substance.  These investigations are 
 undertaken to identify the situation 
leading to the incident as well as any corrective 
 actions to prevent the release from reoccurring.  All reports are retained for a 
 minimum of 5 years. 
 Employee Participation 
 CR Briggs truly believes that process safety management and accident prevention is a 
 team effort.  Company employees are strongly encouraged to express their views 
 concerning accident prevention issues and to recommend improvements.  In addition, 
 our employees have access to all information created as part of the facility's 
 implementation of the RMP rule, including information resulting from process hazard 
 analyses in particular. 
 On occasion, our company hires contractors to conduct specialized maintenance and 
 construction activities.  Prior to selecting a contractor, a thorough evaluation of safety 
 performance of the contractor is carried out.  CR Briggs has a strict policy of 
 informing the contractors of known potential hazards related the contractor's work and 
processes.  Contractors are also informed of all the procedures for emergency 
 response should an accidental release of a regulated substance occur. 
    5.     Five-year Accident History 
 CR Briggs has had an excellent record of preventing accidental releases over the last 5 
 years.  Due to our stringent release prevention policies, there has been no accidental 
 release during this period. 
    6.     Emergency Response Plan 
 CR Briggs  carries a written emergency response plan to deal with accidental releases 
 of hazardous materials.  The plan includes all aspects of emergency response including 
 adequate first aid and medical treatment, evacuations, notification of local emergency 
 response agencies and the public, as well as post-incident decontamination of affected 
 To ensure proper functioning, our emergency response equipment is regularly 
 inspected and serviced.  In addition, the plan is promptly updated to reflect any 
 pertinent changes t 
aking place within our processes that would require a modified 
 emergency response. 
    7.     Planned Changes to Improve Safety 
 Continual training in Hazmat and Hazardous Waste are some of the major steps we 
 want to take to improve safety at our facility.  These changes are expected to be 
 implemented in the fall of 1999. 
 8. Certification Statement 
 The undersigned certifies that to the best of my knowledge, information, and belief, 
 formed after reasonable inquiry, the information submitted is true, accurate and 
 Name:  Sandra Corporon 
 Title:  Safety Coordinator 
 Date signed:
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