CoorsTek Clear Creek Valley Plant - Executive Summary
This executive summary is a brief overview of the Risk Management Program and the associated policies at the CoorsTek Clear Creek Valley Plant. |
Prevention and Response Policies
The accidental release prevention and emergency response policies are represented in the Emergency Planning and Response Sections of the Clear Creek Valley Plant PSM/RMP manual for the ammonia system. CoorsTek takes an active role in preventing accidental releases at all of its facilities by ensuring that its employees are properly trained in the safe operation of covered processes and the safe handling of treatment chemicals. As for emergency response, CoorsTek has established and maintained procedures for emergency notification and response. These are reviewed with employees on an annual basis and revised to accommodate changes in staffing when they occur.
CoorsTek management understands its duty to provide a safe working environment and to take measures to prevent accidents that may have an effect on the
surrounding community. This understanding is reflected in procedures described and referenced in the PSM/RMP manual.
Stationary Source and Regulated Substances
The Clear Creek Valley Plant manufactures ceramic electronic products. The regulated substance handled at this facility is ammonia. The ammonia is used as feedstock for the ammonia disassociation process at the Nitroneal Generator and Sargeant and Wilber Disassociator. The ammonia is stored in a 16,000 gallon tank with a maximum intended inventory of 65,000 lbs. on site.
Worst-case and alternative release scenarios have been determined after careful review of the regulation and consideration of the storage vessel configuration at the facility. For worst-case release scenario, the regulation is clear. The assumption is that the entire contents of the single largest container of a regulated substance (the 16,000 gallon ammonia tank) is released over a ten-minute period. No active mitigation may be consid
ered. Worst-case meteorological conditions are also assumed to be present. The ALOHA air dispersion model was used to determine distances to the toxic endpoint. A distance of 4.6 miles to the toxic endpoint was calculated for a release of 65,000 pounds in ten minutes.
The alternative release scenario for ammonia consists of a release of 31,321 pounds of ammonia over a one-hour period due to failure (open) of the tank drain valve. No active mitigation devices were considered to influence the release scenario. A distance of 0.5 miles to the toxic endpoint was determined.
Prevention Steps for Ammonia
The prevention program and chemical-specific prevention steps are described in detail in the Clear Creek Valley Plant Ammonia System PSM/RMP manual. The prevention program includes the following elements:
7 Employee participation, which includes provisions for active participation by plant employees in the development and implementation of the plant PSM/RMP program, as well as ready
access to program information
7 Process safety information, which has been collected in the Clear Creek Valley Plant EHS Coordinator and Plant Engineering Supervisor's office and summarized in the PSM/RMP manual
7 Process hazard analyses (PHAs) - The initial PHA for the ammonia system was conducted in 1992; the PHA was updated in May 1998. All recommendations from the 1992 PHA have been addressed; no system changes were recommended in the 1998 PHA.
7 Operating procedures for the ammonia process, which are included in the Clear Creek Valley Plant Ammonia System PSM/RMP Manual
7 Training for all personnel involved in the operation and maintenance of the ammonia system
7 Contractor management program, which includes provisions for the evaluation and selection of contractors to work on the regulated process, exchange of hazard information, system access control, and oversight during work activities on site
7 Pre-startup safety review procedure for implementation for significant system c
hanges to ensure that the construction and equipment installation is according to design specifications, appropriate procedures are in place and accurate, a PHA has been done and the recommendations resolved, and employees are trained prior to startup of the modified system
7 Mechanical integrity program to ensure that the ammonia system equipment is maintained in good and safe working condition. Preventive maintenance for the facility ammonia system includes not only periodic component tests, but also daily visual inspections of system components and operation, to include the ammonia tank itself; the DisAmm vaporizer, retort chambers, and feed lines; the Nitroneal vaporizer, catalytic chamber, heat exchanger, and gas bubbler; and the ammonia scrubber.
7 Hot work permit procedures to ensure that appropriate measures are in place when cutting or welding at or near the ammonia process (using the CoorsTek Cutting, Welding, and Fire Watch Policy and Hot Work Permit form)
7 Management of c
hange program to ensure that proposed system changes are comprehensively evaluated before implementing the change
7 Incident investigation procedures for the investigation of any catastrophic (or potentially catastrophic) incident associated with the ammonia system, using the CoorsTek Clear Creek Valley Plant Incident Report and Investigation form
7 Compliance audits to be conducted at least once every three years to ensure the continued compliance of the Clear Creek Valley Plant ammonia PSM/RMP program. A PSM audit was conducted on the ammonia process in 1996.
7 Trade secrets provisions allowing contractors and employees or their representatives access to system information
In addition to these elements, the facility's PSM program was comprehensively reviewed by OSHA in August 1998, resulting in no citations for non-compliance with the PSM regulatory requirements. The facility responded promptly and satisfactorily to the minor issues identified in the Section 21 letter from OSHA to
Within the five-year period prior to the submittal of this RMP, there were no accidental releases of ammonia meeting the requirements of 40 CFR 68.42.
Emergency Response Program
This facility has established and maintains an emergency response program that is coordinated with local response agencies. The program is described in detail in the Emergency Planning and Response section of the PSM/RMP compliance manual and meets the requirement of 40 CFR 68.95. The goals of the program are to protect onsite employees from the hazardous effects of chemical releases and to minimize the effects of releases on the general public. The program is routinely reviewed and updated to reflect personnel and regulatory changes.
Planned Changes for Improved Safety
Ideas for changes to improve safety are actively sought from employees. During initial employee orientation and in other work group meetings, employees are encouraged and trained to recognize hazards and p
resent ideas to eliminate them or to minimize the potential consequences of those hazards.
During the development of the Clear Creek Valley Plant PSM/RMP program, process hazard analyses were conducted with key employees to meet the prevention program requirements. During these sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases. Each recommendation has been or will be considered for implementation. Though not all recommendations may be implemented, all will be considered. The exercise has provided all affected employees with a heightened awareness of safety issues related to the covered processes.