Hobet Mining, Inc. - Executive Summary |
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The accidental release prevention and emergency response policies at your facility: Hobet Mining, Inc. (Hobet) relies on numerous programs to ensure early identification of and proper response to potential emergencies, including: Training and drills in emergency preparedness, disaster response and control, and first aid; Frequent auditing of all preparedness programs; safety training and education; and Regular review, follow-up, and maintenance of all company operations and equipment. Our facility shall invite the local fire department and/or emergency responders to tour and inspect our plant, participate in joint emergency drills, and gain familiarity with our operations. Hobet makes an effort to support our communities through sponsorship of local activities and participation in many local organizations. A description of your facility and the regulated substances handled: This plant utilizes anhydrous ammonia in the plant circuit for pH control in order t o allow for maximum washing efficiency. The tank is located adjacent to the plant on the hillside in a mountainous rural setting. The 55 employees mentioned in the application are distributed across three daily shifts. The maximum number of employees at the plant is anticipated to be 20. For more information, visit our web site at www.archcoal.com or contact the Plant Manager. The worst-case release scenario: The USEPA RMP regulations require the worst-case release scenario to assume that the entire contents of the largest vessel are released. This event is highly unlikely and has never occurred at our facility. Based on our analysis using USEPA-approved methods, the worst-case release scenario for anhydrous ammonia could potentially affect offsite receptors. There were no specific administrative controls or mitigation measures considered in the analysis to limit the distance reported. The alternative-case release scenario: The USEPA RMP regulations require an analysis of the alternative-case release scenario. The alternative-case release scenario represents an accidental release that is more reasonable than the worst-case, but is still highly unlikely to occur. Based on our analysis using USEPA-approved methods, the alternative-case release scenario for anhydrous ammonia could impact offsite receptors. There were no specific administrative controls or mitigation measures considered in the analysis to limit the distance reported. The general accidental release prevention program and chemical-specific prevention steps: This facility is operated in accordance with the USEPA prevention program requirements. A written management system is in place along with written operating procedures. The management system procedures ensure training for operations employees, numerous management checks and balances, and strict attention to changes in the operations with a thorough review and examination of potential incidents that could lead to an accidental releas e. Hobet maintains a 24-hour guard at the facility that would enable the facility to quickly coordinate emergency response and communicate key first aid or medical information to local health care providers in the event of a release. This facility has emergency medical treatment information readily available for use in an emergency. Five-year accident history: We have never had a release of anhydrous ammonia that resulted in or could have resulted in an offsite impact. The emergency response program: Our employees will not respond to accidental releases of the regulated substance but will rely on the local emergency responders when there is a need for response. Our employees regularly undergo training in defensive emergency response activities. This facility has a written emergency response plan that is updated regularly. Planned changes to improve safety: Our facility continually evaluates and implements employee suggestions. We make changes to improve safety based on comments and information developed within our organization and the industry. Toward continuous improvement we are looking at ways to minimize risk through process improvement and re-design. |