U. S. Vanadium Corporaiton - Executive Summary

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1. Accidental release prevention and emergency response policies: 
U. S. Vanadium Corporation uses anhydrous ammonia as a reactant in the recovery of vanadium products. Anhydrous ammonia is a listed regulated substance under the Accidental Release Program regulations, which governs the Risk Management Plan (RMP).  Certain safety precautions must be observed when handling ammonia to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle ammonia, training of our personnel who operate the circuit, and the safety devices inherent in the design of its storage tank.   
Our emergency response program presents a logical coordinated course of action to be followed in the event of an emergency.   The program utilizes information from the Emergency 
Response Guidebook by the Department of Transportation. The emergency response plan includes procedures for notification of the local fire authority and notification of any potentially affected neighbors. 
2. The stationary source and regulated substances handled. 
U. S. Vanadium Corporation produces high quality vanadium products for the steel and chemical industries utilizing vanadium-bearing feedstocks.  Anhydrous ammonia is used as a reactant in the crystallization process. Ammonia is received by tank trucks only and unloaded into an aboveground-pressurized tank. Liquid ammonia from the bottom of the storage tank is heated through a heat exchanger.  This vaporized ammonia is transferred back into the tank and can then be used in the vanadium process. The maximum amount of anhydrous ammonia that can be stored at this plant site is 70.9 tons.  
3. The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures t 
o limit the distances for each reported scenario. 
Worst-Case Scenario. - The worst case scenario, as specified in the regulations, involves the release of  the contents of the anhydrous ammonia tank in ten minutes. The distance to the toxic endpoint for the worst-case scenario is 5.6 miles.  This scenario does not take into account mitigation in the forms of excess flow valves, relief valves, or water sprays.  No reportable accidental releases have occurred at the facility in the past five years.   
Alternative Scenario. - The alternative scenario modeled was a release from the unloading line carrying anhydrous ammonia from the tank truck to the tank. Active mitigation is in place in the form of excess flow valves, but scenarios were modeled based on a failure of an excess flow valve also.  The distance to the toxic endpoint for this alternative scenario is 0.88 miles.   
4. The general accidental release prevention program and the specific prevention steps.  
This facility complies 
with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. The anhydrous ammonia tank was designed and constructed in accordance with ASME Boiler and pressure Vessel Code.  All operators are trained in ammonia and process safety.  Written work instructions for each process station are detailed in the ISO 9002 manuals on site.   
5. Five-year accident history.  
No accidental release of anhydrous ammonia has occurred at this facility in the past five years. 
6. The emergency response program.
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