Cedar Lake Plant - Executive Summary |
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Source and Process Description Cooper Natural Resources and its predecessor companies have produced the industrial mineral, sodium sulfate, from underground brine deposits in west Texas since 1933. Their Cedar Lake Plant, located in northeastern Gaines County, has been in operation since 1965. The sodium sulfate produced by the plant is a high purity, non hazardous salt that is shipped to customers throughout the United States for use in the detergent, glass, paper, dyestuffs and animal husbandry industries. The plant is supplied by shallow wells located in the adjacent, highly saline, Cedar Lake. The produced brine is over nine times the salinity of seawater. This brine is conveyed to the plant by pipelines. Refrigeration units in the plant are then used to cool the brine and cause the precipitation of the hydrous form of sodium sulfate, Glauber's salt, Na2SO4 X 10 H2O. The refrigeration system contains approximately 67,000 lbs. of ammonia. The hydrous salt produced by refrigeration is then recovered by filtration and sent to the drying plant where a vapor recompression unit melts the salt in its waters of hydration. Concentration of the saturated solution results in precipitation of anhydrous sodium sulfate, the marketable product. The anhydrous sodium sulfate is subsequently recovered by centrifuges and dried prior to shipment. No reagents or reactive chemistries are used in the process. The method of operation is based on simple phase chemistry alone. The plant produces only high purity sodium sulfate salt and ultra-pure steam condensate. Program Status As more fully described herein, the plant meets the eligibility requirements of Program 1 status as provided in 68.12(b) of the RMP Rule because it meets all of the following requirements: (l)For the five years prior to the submission of an RMP, the process has not had an accidental release of a regulated substance where exposure to the substance, its reaction products, overpressure generated by an explosion involving the substance, or radiant heat generated by a fire involving the substance led to any of the following offsite: (I) death; (ii) injury; or (iii) response or restoration activities for an exposure of an environmental receptor; (2)The distance to a toxic or flammable endpoint for a worst-case release assessment conducted under Subpart B and 68.25 of this part is less than the distance to any public receptor, as defined in 68.30 of this part; and (3)Emergency response procedures have been coordinated between the stationary source and local emergency planning and response organizations. Hazard Assessment: Release Scenarios A Hazard Assessment has been conducted on the facility under the guidelines of Model Risk Management Program and Plan for Ammonia Refrigeration. The results of the Offsite Consequence Analysis for both a worst-case and an alternative accidental release scenario may be found in the enclosed Data Elements Checklist. Worst-Case Release Scenario: For the wors t-case evaluation the amount of ammonia hypothetically released was taken as the largest mass of ammonia that is liquefied under pressure in any vessel in the ammonia refrigeration system. This would be the ammonia accumulator which is an outside vessel containing 6,060 lbs. of liquid ammonia. A duration of ten minutes was used in the evaluation resulting in a predicted distance to the toxic endpoint of 1.4 miles. The direction of the plume, and thus the potentially impacted area, would of course be dependent upon the wind direction during the release incident. As shown on the accompanying map, See Attachment 1, this area is unimproved ranch land. There is one unoccupied house and Farm to Market Road 1066 on the northern extremity of the subject area. Thus, there would be no danger to the public of a release of this magnitude. There could be a potential danger to emergency response units approaching down the company's private road from the north. As stated in the Certification section of this report, the public emergency responders should not enter this area except as arranged with the emergency contact indicated herein. Alternative Release Scenario: For the purpose of this analysis, the alternative release scenario would be more likely to occur than the worst-case scenario. The circumstances of the alternative scenario were a release through a l/4" effective diameter orifice leading to an airborne release. The rate of release from a high-pressure receiver would be 100 lb/min. The predicted distance to the Toxic Endpoint is 1,020 ft., which would pose no danger to the public. Accidental Release Prevention Program and Chemical-Specific Prevention Steps Because anhydrous ammonia is a regulated substance, the plant is also covered by the U.S. Occupational Safety and Health Administration's (OSHA) process safety management standard (PSM). Additionally, the plant submits an annual "Tier II" report to the State Emergency Response Commission, the Local Emergency Plannin g Committee (LEPC) for Gaines County as well as the three local fire departments. The TIER II report lists all hazardous chemicals, including anhydrous ammonia, that may be held above the threshold quantity at the plant. The report also describes the chemical properties and location of each chemical in the plant in order to assist emergency responders should they ever be called to the facility. RMP - Executive Summary Page 3, Continued Cooper Natural Resources is an active participant in the Responsible Care program of the Chemical Manufacturers Association (CMA). The CMA represents nearly 200 chemical manufacturers who account for 90 percent of the country's basic chemical production. The CMA's Responsible Care initiative is a widely recognized program of continuous improvement in six Codes of Management Practice covering health, safety and the environment. Releases at our facility are prevented by well-maintained equipment and well-trained personnel. The company has not hesitated t o invest the resources to both maintain and upgrade the ammonia system: $158 000 in capital having been spent for this purpose in the past 18 months. Plant personnel receive annual ammonia training. The plant's process safety management program, an OSHA regulation, pertains to ammonia directly and has been an important safeguard in the safe operation and emergency preparedness of the plant. The plant is required to report any ammonia spills exceeding 100 lbs., the Reportable Quantity (RQ) for ammonia. These reports are made to the Federal, State and County regulatory agencies. Notwithstanding the safety consequences of an ammonia release. it may be noted that anhydrous ammonia is a commonly used agricultural fertilizer in the surrounding region where amounts much greater than the RQ are routinely applied directly to the soil. Five Year Accident History There have been no accidental releases with offsite consequences, as defined in 68.10(b)(1), see eligibility status above, at the fa cility within the past five years. Emergency Response Program The Cedar Lake Plant is prepared to respond to an emergency situation with ammonia. The facility has a Safety Director on staff. Its emergency response team consists of plant personnel who are knowledgeable of the plant process. They are trained in emergency response and conduct drills on a quarterly basis. They have the emergency gear necessary to enter an ammonia environment for rescue. In the event of a release, the response team is equipped to enter a dangerous area to close shutoff valves or take other measures to isolate the leak, thereby mitigating the release. They are also available and trained to assist the emergency responders in containing the release as quickly as possible. A disaster drill is held annually in cooperation with the Gaines County Sheriff's Dept., the local fire departments and EMS units. This drill has proven to be very beneficial in coordinating the plant's response procedures with the local emergency planning and response organizations. Furthermore, a copy of this Risk Management Plan will be supplied to the local emergency responders and Gaines County LEPC. Planned Changes to Improve Safety The potential risks of ammonia usage are taken very seriously at our plant. The safety of both our employees and neighbors has been, and will continue to be, our number one priority at Cooper Natural Resources. Training and retraining of all of our employees is an on-going activity of our |