The Alta Group - Salt Lake City Operations - Executive Summary |
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The ALTA Group - Salt Lake City Operations Risk Management Plan Executive Summary Policies and Procedures The ALTA Group, Inc. places high priority on its responsibility for the environment. As a high technology company operating in growth markets around the world we believe that we have an important role to play in the promotion of sound environmental management of the earth's resources. ALTA has formalized its responsibility by ensuring that all employees are aware of policy and their individual responsibilities. ALTA policy is disseminated widely and is supported by training and the monitoring of progress and controls through regular audits. We seek to achieve continuous improvement of our environmental management systems. Specific policies are in place that require all facilities to maintain a written response pl an which ensures a coordinated course of action in the event of an emergency. The ALTA Group - Salt Lake City Operations has complied with the company's Risk Assessment Policy. This policy requires that all operations are assessed for hazards and risk, from design and construction to commissioning, operation, and decommissioning. The risk assessments include: - Hazard Identification - The ALTA Risk Assessment Protocol - As necessary, advanced risk assessment protocols in the form of Failure Mode and Effects Analysis (FMEA) or Hazard and Operability Studies (HAZOP) We require our facilities to record and investigate all environmental incidents with the aim of preventing their recurrence and to collect environmental data to allow the assessment of the company's environmental performance. Facility Description The ALTA Group - Salt Lake City Operations manufactures high purity titanium. The manufacturing process includes the utilization of titanium tetrachlo ride (TTC). Titanium is produced by a reduction reaction of TTC. Further processing includes crushing, leaching, rinsing, drying, and product sizing. Worst Case Scenario The worst case scenario was prepared using EPA's Offsite Consequences Analysis (OCA) Guidelines. This scenario assumes the rupture of a TTC storage tank, resulting in a liquid spill and vaporization. The tank capacity is approximately 100,000 pounds. Administrative controls incorporated into standard operating procedures keep the level at 90,000 lbs or below. The tank is surrounded by a dike. The dike limits the surface area of the pool thus reducing the evaporation rate if a spill occurred. Offsite impact includes business/industrial areas and a recreational area. There is not a residential impact according to OCA guidelines. A preventative maintenance program is in place that monitors the integrity of the storage tank. Visual inspections are performed on the tank, and the thickness of the tank wall is m easured. An atmosphere of inert gas is maintained on the tank to reduce the chance for internal corrosion. Design code and specifications for all pipes and vessels were followed as provided by the chemical supplier. The supplier has over 20 years of experience with the regulated chemical. Although not considered for the worst case analysis, several active mitigation steps are possible if the storage tank were to start leaking. First, a foam generation system can be used to blanket a spill in the diked containment area. Literature and trials suggest at least an 80% reduction of fume emission for this type of foam. In addition, a large volume safety vessel is located next to the storage tank. Equipment is installed to allow an emergency transfer to the safety vessel if the storage tank starts leaking. Alternate Release Scenario The alternate release scenario was prepared using EPA's OCA guidelines. This scenario assumes the rupture of a flexible transfer line, resulting in a liquid spill and vaporization. Spilled materials would flow into a diked area. The dike limits the surface area of a pool thus reducing the evaporation rate. In addition, a foam system installed at this area is assumed to reduce the release rate to atmosphere by at least 80%, as suggested by literature and trials. Offsite impact includes business/industrial areas and a recreational area. There is not a residential impact according to OCA guidelines. Standard operating procedures are in place for performing transfer operations. The procedure checklist includes requirements for inspecting the transfer line for damage and signs of leaking. The procedure also requires a leak check on the transfer line before each transfer is performed. The flexible transfer line is replaced as part of the preventative maintenance program. Accidental Release Prevention Program The TTC systems were built in accordance with design code and specification as recommended by the supplier. The supplier has over 20 years of experience handling this chemical. The systems include many built in safety devices including level alarms, high level cutouts, safety vents, and pressure relief devices. Standard operating procedures are in place and are updated as needed. Operators performing TTC operations must be certified. Certification includes classroom training, on the job training, a written test, and a demonstration of ability (practical test). A preventative maintenance program is used for testing and replacing components of the systems as needed. Safety critical devices are tested periodically to verify they are functioning correctly. Some components are scheduled for periodic replacement. A schedule is used for physical inspection of tanks and transfer lines. Hazard and Operability Studies (HAZOPS) are used for risk assessments. The opportunity for operator error is included with the studies. Corrective actions resulting from the studies are promptly addressed. Five Year A ccident History The Alta Group - Salt Lake City Operations has been in operation since January 1996. In that time, there have been no accidental releases involving the regulated chemical. Emergency Response Program The ALTA Group - Salt Lake City Operations has agreed with the local emergency response provider that they perform emergency response for this facility. The ALTA Group is incorporated into the local fire department's emergency response program. A close working relationship has been established with the local fire department. Regular tours of this facility are provided for familiarization with chemical storage locations and potential hazards. Planned Changes to Improve Safety Equipment modifications are in progress to allow easier testing of high-level cutout switches. New pressure alarms are being added to storage tanks. Spill-response equipment has been ordered for addressing small chemical spills. A modification to the foam system is planned to provide bette r coverage in the event of a transfer line failure. |