Riverton Facility - Executive Summary

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Riverton Facility, Riverton, Wyoming 
Introduction and Policies 
Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public.  Our KEEP management philosophy goals are achieved by the personal commitment of our employees and contractors, and by open communication with our employees, customers, neighbors, and with regulators.  The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP.  Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be unintentional and acknowledged as unacceptable, by rem 
edying any shortcomings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by the law. 
The Riverton Facility is one of many facilities operated by Koch Sulfur Products Company.  At the facility, we manufacture commercial grade sulfuric acid (200 tons per day) from elemental sulfur and spent sulfuric acid in two separate process trains.  Oleum is the only toxic substance regulated under the Risk Management Program (RMP) that is present at the Riverton Facility in amounts greater than threshold quantity.  The facility is classified as Program Level 3 under the regulation.  The purpose of this Risk Management Plan (RMPlan) is to provide information about our operations at the facility, our programs to prevent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the 
Worst Case and Alternative Release Scenarios 
As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for toxic chemicals would be the loss of all of the Oleum in our largest vessel within 10 minutes.  In the case of the Riverton Facility, this would involve our 500-ton oleum tank.  Such a scenario is highly unlikely, however, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that the resulting release could cause off-site impacts would be more than 25 miles.  Although we have numerous controls to prevent such releases (high level alarms, emergency shutdown, and others) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this scenario.  The alternative release scenario, characterized as a more likely scenario that could involve an offsite exposure to oleum vapors, is calculated to reach approximately 1.6 miles from the release 
point.  This distance calculation is also based on the EPA OCA methods, which are known to overpredict the impact of any potential release from such a scenario.  We selected the alternative release scenario based on a release of oleum due to knocking off a 1" nipple on the oleum pump suction line.  We have mitigation measures in place to greatly reduce the chance that such an event could ever occur.  The plant is manned 24 hours a day and facility inspections are conducted every two hours.  Tank level gauges are checked during inspection to ascertain that there are no leaks from the tank or piping.  Heavy equipment is in place at the facility to be used in such cases when containment is necessary.  The presence of these mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur. 
We have discussed these potential oleum releases with our employees and with local emergency response officials in Fremont County, thereby further reduci 
ng the possibility of any impact on the public. 
Prevention Program 
The Riverton Facility has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1998.  Our ongoing analysis of the potential hazards of our process, detailed training of our employees, and constant emphasis on safety have helped us avoid any serious accidents over the last 5 years.  Part of this program has also involved identifying and taking steps to avoid potential accidental chemical releases.  A few examples of the additional prevention features implemented at this facility include: 
7 We installed a vacuum system on the oleum tank in order to prevent venting of SO3 vapors into the atmosphere.  The SO3 vapors collected by the vacuum system are returned to the process. 
7 We have installed a SO2 monitor on our sulfur furnace stacks in order to limit the SO2 concentration in the stack gases to 2000 parts per million (pp 
m).  When the SO2 concentration exceeds 1,975 ppm, an alarm will sound which will enable the operator to take necessary corrective actions such as reducing the sulfur throughput. 
7 We have installed a pump failure shutdown interlock system on the 99% sulfuric acid recirculation pump which will shutdown the process in order to prevent the release of oleum vapors to the atmosphere. 
7 We have provided alarms at safety showers, at eye wash stations, and at emergency button locations in order to enable Koch personnel or contractor employees to request assistance in case of an injury or accident. 
7 We provide safety orientation to all our contractor employees to enhance personal safety. 
These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it in 1991. 
Five Year Accident History 
No incident having resulted in offsite impacts or onsite injuries from a RMP regulated substance has occurred at the River 
ton Facility within the last five years.  Although we take pride in that record, we also place daily emphasis on our prevention and safety programs to ensure this record continues. 
Emergency Response 
We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the Riverton Facility with the Fremont County Volunteer Fire department.  Also involved in emergency response of the facility would be the Fremont County Sheriff, Fremont County Emergency Management Agency, Freemont County Ambulance, Riverton Fire District, City of Riverton Police, City of Riverton Emergency Management Agency, Riverton Memorial Hospital, and Wyoming State Highway Patrol.  The Riverton Facility Plant Manager is responsible for coordinating all emergency actions.  A specific Emergency Response Plan for the facility is in place and that plan has been coordinated with local officials, along with evacuation procedures, regular drills, and tr 
aining.  Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. 
Planned Changes to Improve Safety 
Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the Riverton Facility.  Some of the key components of the safety improvements we expect to achieve are as follows: 
7 The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures. 
7 The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards. 
7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk  
of hazardous releases, thereby serving as an integral part of our safety program. 
7 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection. 
7 An ongoing dialogue with the Fremont County Emergency Management Director or his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops.  In this way, we shall bolster our strong commitment to the safety of our workers and the community. 
We encourage all interested citizens or community organizations to contact the Fremont County Emergency Management Director for the latest information on emergency response for the county.  We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis.
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