Southwire Company - Copper Division of Southwire - Executive Summary |
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EXECUTIVE SUMMARY Accidental Release Prevention and Emergency Response Policies: It is the policy of the Southwire Company to operate its facilities in a manner which maximizes protection of both its workers and its neighbors. There exists, however remote, a chance that an incident could occur involving the anhydrous ammonia storage system utilized by the Copper Division of Southwire (CDS). To that end, Southwire has taken all prudent precautions so as to further minimize the chance of an incident. All contracted delivery personnel are also required to adhere to Southwire standard safety precautions. CDS has instituted a Release Prevention Control And Countermeasure Plan (RPCC) plan, which includes the anhydrous ammonia storage system. The goal of the RPCC plan is to effectively deal with any such incident. The RPCC plan includes procedures to notify proper professional emergency response personnel. Facility Description and Regulated Substance(s) Handled: CDS is located at 372 Central High Road, Carrollton, Georgia. This facility is engaged in the manufacture and sale of copper rod which is used primarily to make wire and cable. The operations include a smelter for the processing of copper bearing material (99% copper anodes), an electrolytic refinery which produces cathode copper from the anodes, a rod mill, and a storm water treatment plant. Anhydrous ammonia is used as a reducing agent to remove oxygen during the purification of copper bearing materials. CDS utilizes two anhydrous ammonia above ground storage vessels. The anhydrous ammonia is stored in a 6,000 gallon (30,960 pounds) and 18,000 gallon (92,880 pounds) horizontal storage tanks. The anhydrous ammonia in each tank is liquefied under pressure. The average quantity of anhydrous ammonia that is normally stored at this facility is 11,775 gallons (60,814 pounds). Worst-Case Release Scenario and Alternative Release Scenario: Worst-Case Release Scenario - Under the worst case release scena rio, it is assumed that the total capacity from the largest of the two anhydrous ammonia tanks (18,000 gallon or 93,000 pounds) is released within a 10 minute period. The contents of the tank are modeled as a gas since the contents are stored under pressure. The Environmental Protection Agency's (EPA's) modeling software RMP*COMP was used to evaluate this scenario. The resulting distance to endpoint extends off-site and public receptors are within the distance to the endpoint. In broad terms, this toxic endpoint distance is the distance a toxic vapor cloud, fire, or explosion from an accidental release will travel before dissipating to the point that serious injuries from short-term exposures will no longer occur. Alternative Release Scenario - The most likely alternative release for this covered process is from a hose transfer scenario. This scenario could potentially occur during filling of the storage vessel. Under this scenario, the hose that transfers anhydrous ammonia fro m the supply tanker to the storage vessel suddenly becomes uncoupled during a pull away event. A 25 foot long two inch diameter hose used for filling the anhydrous ammonia tanks contains a total of 21.07 pounds of anhydrous ammonia. The total contents of the hose was modeled as a release over a 10 minute period. The EPA's modeling software RMP*COMP was used to evaluate this scenario. RMP*COMP yielded a distance to the toxic endpoint of <0.1 miles (<0.16 kilometers). General Accidental Release Prevention Program and Chemical-Specific Prevention Steps: This facility is in compliance with EPA's Accidental Release Prevention Rule and all applicable state and local codes and regulations. Written operating procedures have been prepared that provide clear instructions and/or steps for safely conducting activities associated with the anhydrous ammonia storage system. All employees and contractors that "operate" the system have been properly trained in these procedures. Five-Year Accid ent History: There have been no accidents within the past five-year period that have resulted in any on-site deaths, injuries, or significant property damage, or any off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency Response Program: This facility's emergency response program includes coordination with the local Fire Department and the West Georgia Regional Hazmat Team. Additionally, CDS has contracted with an outside emergency response company to provide additional emergency response assistance as needed. To better respond to an accident, the local Fire Department performs an annual plant tour of CDS to become familiar with the location of all hazardous materials kept on-site and to identify all hazardous materials used on-site. All personnel at the plant are trained to be familiar with disaster plan emergency procedures, appropriate individuals to notify, evacuation routes, and assembly points. All personnel are tra ined at least annually. Planned Changes to Improve Safety: No specific changes to improve safety are planned concerning the anhydrous ammonia storage system. The Copper Division of Southwire continues to take all feasible precautions to assure continued safe operation of the anhydrous ammonia storage system. |