Climax Molybdenum Company - Executive Summary |
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1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY POLICIES Climax Molybdenum recognizes management's responsibility in protecting its employees, equipment, property, and the environment. The safety and health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the facility. The Climax Molybdenum PSM/RMP program assigns and documents the specific responsibilities for developing, implementing, and integrating the OSHA PSM and the EPA RMP standards into its safety program. The Climax Molybdenum PSM/RMP program focuses attention on "Making PSM/RMP the way we manage our ammonia based "Processing Operations" rather than a project we expect to complete and put on the shelf when the filing date has passed. Climax Molybdenum believes that employee participation is the key to a successful program. Operating level employees, particularly the Ammonia System Operators, have been deeply involved in the developme nt and implementation of the PSM/RMP Program and they assume the major responsibility for operating safely. 2. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Climax Molybdenum processes Molybdenum containing intermediate materials into various end products. The storage processing system contains no more than 62,000 pounds of Anhydrous Ammonia. 3. SUMMARY OF WORST CASE AND ALTERNATIVE RELEASE SCENARIOS Section ?68.25 of the RMP Regulation defines a worst-case scenario as a release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to a specified endpoint. At Climax, the worst-case scenario is identified to be the release of the storage vessel containing ammonia. The vessel contains up to 61,700 (at 97 deg. F) which is assumed to be released over a 10 minute period. The ammonia will then volatilize into the atmosphere. Modeling of this release was performed using DEGADIS. The toxic endpoint calculate d was 2.0 miles. This release would affect residential and industrial areas. The alternative release scenario is based on a 1/4 inch hole in a liquid ammonia line. This failure will assume that 1,908 pounds of ammonia will released over a 30 minutes period. Modeling of this release was also performed using DEGADIS and shows that the toxic endpoint will extend to a distance of 0.31 miles. This release would industrial areas. 4. DESCRIPTION OF THE CLIMAX MOLYBDENUM ACCIDENTAL RELEASE PREVENTION PROGRAM Climax Molybdenum conducts an annuall PSM/RMP implementaion progress audit of the entire PSM/RMP Progam to identify strengths and weaknesses and make improvements. Climax Molybdenum considers the PSM/RMP manuals to be "living" documents that must be updated and revised regularly to maintain ther viability. Climax Molybdenum emphasizes and insists on "employee participation" from the Ammonia Storage and Use system operators in all aspects of the development, implementation, and i ntegration of the PSM/RMP Program. Climax Molybdenum provides a comprhensive, computer based, user friendly training program with "one-on-one" teacher involvement in specific training modules for each ammonia process employee. Climax Molybdenum maintains a pro-active "open-door" policy toward neighbors and concerned community citizens. Facility tours and risk management discussions are scheduled and conducted upon written requests. 5. FIVE YEAR ACCIDENT RELEASE HISTORY There have been no releases of ammonia that have resulted in an injury, or that had an off-site impact, or that resulted in significant property damage either on-sit or off-site. 6. EMERGENCY RESPONSE PROGRAM Climax's emergency response policies have been designed to comply with all applicable state and federal Regulations. These policies summarize the actions to be taken in response to a chemical spill. In the event of a spill, the HazMat Team will react with the proper actions, as listed in the Emergency Respo nse Plan, in association with the local fire department 7. PLANNED CHANGES TO IMPROVE SAFETY Climax Molybdenum recognizes that (even though their ammonia release and injury experience has beenexcellent) their PSM/RMP program will provide much needed improvement to their safety effort. The PSM/RMP program is considered to be a set of "living" documents and procedures that will require constant attention, development, and revision before "Safety" becomes second nature. Climax Molybdenum expects to improve safety performance by emphasizing the following elements tof their PSM/RMP program: (1) Employee Participation is the "Key" to a successful program. Both the managers and system operators are deeply involved in identifying the P&IDs, developing and updating the Standard Operating Procedures, and performing the documented Preventative Maintenance Inspections. (2) The Climax Molybdenum PSM/RMP program is (a) computer based, (b) user friendly, (c) includes one-on -one involvement with specified and qualified trainers, (d) written to minimize paperwork and maximize documentation, and (e) written to be understood and used by the operating level employees. (3) All recomendations developed during the Process Hazards Analysis were designed to improve the safety performance of the Climax Molybdenum Anhydrous Ammonia Storage and Use Process System. Climax Molybdenum expects to evaluate each recommendation in a timely manner and implement, as soon a possible, those recommendations that will reduce the possibility of release and/or mitigate the consequences of an unintentional release. |