Holston Army Ammunition Plant - Executive Summary
EXECUTIVE SUMMARY |
Holston Army Ammunition Plant (Holston), located on two sites in Kingsport, Tennessee, is a federal government owned, contractor operated facility which produces RDX and HMX based explosives for the Industrial Operations Command (IOC) of the US Army. The plant was originally built in 1942. In 1999, Royal Ordnance North America became the operating contractor. Holston has had an excellent safety record over the past 57 years and intends to maintain this outstanding record in the years to come. Holston has long standing agreements and coordination with local emergency planning units including Hawkins County and the City of Kingsport.
Holston is subject to EPA's Risk Management Program rule for two listed substances: concentrated nitric acid and anhydrous ammonia.
Holston's nitric acid tank farm stores concentrated nitric acid in aluminum tanks with a capacity of 485,000 pounds per tank. This defines the worst case scenario for nitric acid. Holston stores anh
ydrous ammonia at two registered pressure vessel tank farms - one farm with 70,000-pound capacity tanks, the other with 167,000-pound capacity tanks. These tank capacities define worst case release scenarios for ammonia. Due to the enormous amount of above ground piping present at Holston, it was decided to use a transfer pipeline rupture as a likely alternate case release scenario for nitric acid or ammonia.
Holston is a major producer of concentrated nitric acid required for nitration of organic explosives. Nitric acid production, concentration, and use in making nitric acid / ammonium nitrate solution for use in explosives production are separate processes. The nitric acid tank farm has a secondary containment dike and comprises five tanks, each with a 485,000 pound capacity. Offsite Consequence Analysis requires determination of worst case and alternative case scenarios should catastrophic releases occur. A worst case scenario involves rupture of one of the tanks and compl
ete loss of contents. The tank farm is diked to contain spills thus reducing potential atmospheric release rates and facilitating spill recovery. RMP Comp modeling shows a worst case scenario release of nitric acid would impact offsite receptors. Holston decided an appropriate and reasonable alternative case scenario would be the rupture of a transfer line while pumping acid. RMP Comp modeling shows an alternative case scenario release of nitric acid would reach to the plant boundary and encompass an occluded cemetery thereby potentially having offsite receptors.
Holston uses large quantities of anhydrous ammonia for production of nitric acid via the ammonia oxidation process and production of ammonium nitrate through direct reaction of ammonia with nitric acid. Ammonia is also used to neutralize spent nitric acid in the weak acetic acid recovery process. Two tank farms comprise Holston's storage facilities for anhydrous ammonia which arrives at the plant in railcars. Anhydrou
s ammonia is stored as a liquid under pressure in registered pressure vessel tanks. The worst case scenarios for ammonia involved loss of contents of one tank, either a 167,000-pound tank at tank farm A-1 or a 70,000-pound tank at tank farm 330. Ammonia forms a vapor cloud upon release without passive mitigation (relative to liquid pooling) being a factor. RMP Comp modeling on both tank farms show a worst case scenario release of anhydrous ammonia would impact offsite receptors. Holston decided an appropriate and reasonable alternative case scenario to be rupture of a transfer line during normal transfer of ammonia to process units. RMP Comp modeling shows an alternative case scenario release of anhydrous ammonia would not reach plant boundaries and therefore would not impact offsite receptors.
RMP Comp was used to model toxic endpoints for release scenarios. Based on these scenarios, estimates of population within the determined radii were obtained from the US Census Bureau. U
SGS 1:24,000 scale topographic maps of the Kingsport, Church Hill, Lovelace, and Sullivan Garderns quadrangles were used to show potential zones of impact based on the toxic endpoint radii. Quadrangle maps were also used to determine various offsite receptors as required.
Holston is subject to OSHA PSM. PSM (Process Safety Management) fulfills the remainder of the RMP requirements. Holston's PSM program is both intensive and effective because safe reliable production of explosives depends on it. Elements of Holston's PSM include: process safety information management, process hazard analyses, standard operating procedures, proper training, mechanical integrity checks, Change Management, Pre Start-up reviews, compliance audits, incident investigations, employee participation, hot work permitting, and contractor oversight.
RMP is a cooperative function at Holston. Primary responsibility lies with Environmental Affairs, but many other departments are an integral part of Holston's
RMP. Holston has a fully manned and trained onsite fire department with HAZMAT capabilities that responds to all types of emergencies. The safety department in conjunction with operations management takes responsibility for implementing and maintaining PSM. Contractor management is responsible for seeking Army review and approval of RMP and Army staff retain notification and submission duties.
Holston's lack of an accident history demonstrates Holston's commitment to good risk management planning.