Hamilton Facility - Executive Summary |
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Kerr-McGee Chemical LLC is committed to the guiding principles of CMA's Responsible Care. KMC LLC has prepared a policy stating this and has provided the resources to meet the requirements of these guiding principles. The programs that have been developed to meet Process Safety Management and the Risk Management Program are based on these guiding principles and meet the requirements of the regulations.The Hamilton facility has developed an emergency response plan that has been modified to meet the requirements of Subpart E of RMP. The emergency response plan is site specific and has been shared with the LEPC. This facility is an OSHA Star site. The products produced at this facility are sodium chlorate, manganese metal, manganese-aluminum briquettes, and titanium dioxide pigment. Chlorine is used in the manufacture of titanium dioxide pigment and in the cooling tower and water treatment systems. Ammonia is used in the production of manganese metal. Titanium tetrachloride is use d in the production of titanium dioxide pigment. Sulfur dioxide is used in the production of manganese metal. The facility has prepared a worst case scenario for chlorine and alternative case scenarios for ammonia, sulfur dioxide, titanium tetrachloride and chlorine. As required by RMP, the worst case scenario involves emptying a vessel containing 180,000 pounds of chlorine over a period of 10 minutes under meterological conditions of 105 F and 73% relative humidity at night. The model predicted the chlorine would reach the endpoint concentration after traveling 4.4 miles. The alternative case scenario depicts a tubing leak allowing 326 pounds of chlorine to be released. More typical atmospheric conditions were allowed to be considered and the model predicted the endpoint concentration to be reached after the chlorine traveled 0.42 miles. Sulfur dioxide reached an endpoint after 1.0 mile during the alternate scenario modeling. Ammonia reached an endpoint after traveling 0.32 mi les during the alternative case scenario. Titanium tetrachloride reached an endpoint concentration after 0.47 miles during the alternative case scenario. The facility has taken numerous steps to prevent releases from its operations. Some of these include installation of pressure relief valves and excess flow valves on storage tanks. Water deluge systems and diking of tanks and vessels have been utilized. Standard operation procedures and job safety and environmental analyses have been developed for handling these substances at the facility. The facility has implemented prevention programs that meet the requirements of OSHA PSM, EPA RMP(program 3), and CMA Responsible Care. |