Patriot Mining Company, Inc. - K & Z Mine - Executive Summary |
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Patriot Mining Company, Inc. - K & Z Mine Risk Management Plan 40 CFR 68 - Subpart G Executive Summary 1. Accidental Release Prevention and Emergency Response Policies at the Stationary Source Patriot Mining Company, Inc., has policies and procedures that have trained their employees in the safe handling, storage and use of anhydrous ammonia. Employees are also trained in emergency response procedures to prevent and/or mitigate the accidental release of anhydrous ammonia at this facility. The equipment used in the transportation, storage and use of anhydrous ammonia conform to the appropriate federal and state regulations dealing with this material. Equipment and maintenance records are kept on site. Patriot Mining Company uses qualified third party contractors to transport anhydrous ammonia to this facility. Independent safety consultants provide additional training in safety and emergency procedures for Patriot Mining Company employees. Patriot Mining Company has coordina ted its emergency response procedures with the local LEPC. 2. Stationary Source and Regulated Substances Handled There is one stationary source covered by this Risk Management Plan. The regulated substance is anhydrous ammonia. The tank has a capacity of 6,000 gallons. The tank is never filled to a volume greater than 85% of total capacity. 3. Worse Case and Alternative Scenarios Including Administration Controls and Mitigation Measures to Limit Discharge Distances Patriot Mining Company has performed a hazard assessment of its operations and determined that the worse case scenario release of anhydrous ammonia would result from the catastrophic failure of the storage tank filled to 85% of capacity. For this worse case scenario discharge no administrative controls or mitigation measures were considered to limit the anticipated toxic endpoint of the regulated material. The RMP*Comp program was used to determine toxic endpoint data in the worse case scenario. The worse case release scenario has determined the toxic endpoint will extend away from the source radially for 2.5 miles. Patriot Mining Company has performed a hazard assessment of its operations and determined that the alternative release scenario for anhydrous ammonia most likely to result in a toxic release would occur from the failure of a transfer hose during the transfer of the regulated material from a bulk tanker truck to a storage tank. For the alternative release scenario, Patriot Mining Company considered the effects of passive mitigation systems such as the excess flow valves and the active mitigation measures initiated by employees monitoring the material transfer that will limit the duration and amount of material release to volumes below the capacity of both the tanker and storage tank. These actions will reduce the distance to the toxic endpoint for the alternative release scenario to 0.4 miles radially from the source, according to the RMP*Comp program. 4. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The storage tank is equipped with passive mitigation devices. Excess flow valves are designed to prevent the rapid loss of regulated material through piping. The buildup of excess pressure is released through pop-off valves. Transfer operations between bulk trucks and storage tanks are monitored by trained personnel. Employees and contractors have been trained as to the proper handling and hazards of anhydrous ammonia. Storage containers are properly labeled and hazard warnings are posted. Employees working with anhydrous ammonia have been provided with the appropriate personal protective equipment. 5. Five Year Accident History None 6. Emergency Response Program In the event of a reportable release of anhydrous ammonia, Patriot Mining Company employees have been trained assess the dangers presented by the release, take immediate reactions to mitigate the release (when possible) or evacuate the area, don personal protective equipment, communicate with off-site company personnel and contact the local authorities and LEPC. 7. Planned Changes to Improve Safety As the result of the 12/17/99 Compliance Audit, Patriot Mining Company, Inc., will post written operating and emergency procedures at the field location of the storage tank. |