Incident OverviewPresented at Salinas Valley Safety Day May 24, 2012by Kim Snowden and Bruce Welden

Scope

Local area processor had ammonia release relating to brass fitting. Subsequent talks address response to and mitigation of this release, and prevention of future such releases Thanks to our “processor” for providing the outline and input for this talk

Talk Outline

The Events of the IncidentThe Follow-upThe Fines (EPA and State)Today – How do our planned Talks align with these IncidentConclusion – Our Hope…

So the Events of the Incident:First noted- Site Security who contacted Processor TechProcessor Tech prelim investigation (discuss the actual ammonia release - reason/source)

Photo into room (mock-up)Photo of release points (after the fact)Processor Tech Calls for Assistance

Processor / Contractor use of Emergency Control Box.Discuss quantities of ammonia; 760 Lb/Hr for 1 hours (at 20F, 34 psig); then 175 Lb/Hr for 9 hours (at -40F, 0 psig)Photos of ECB and ADT

Processor Call to National Response CenterFire Dept - Stop leaks (Suit up, Entry, and Close valve) with CUPA on-site.

Release Source: Plan View (Approximate)

View Note: Processor Tech’s view at initial investigaion from door.Release Source

(under RP1)

(Piping to ADT and HPR)

Release Source: P&ID views

View Description: Partial Recirc. Vessel (above) and piping to Oil Pot

Release Source: Photo

View Description: Threaded Steel Plug which replaced Brass Fitting

Release Source: Photo-Close-up

View Description: Threaded Steel Plug which replaced Brass Fitting

Release Source: Brass Fitting

View Description: Brass Fitting and Cap

Note: Eroded Cap where ammonia release occurred

Release Mitigation: ECBProcessor Tech / Contractor used Emergency Control

Box to reduce the ammonia being released.Quantity of ammonia released:

Before ECB use: 760 Lb/Hr for 1 hours (at 20F, 34 psig)After ECB use: 175 Lb/Hr for 9 hours (at -40F, 0 psig) (Estimates by Processor’s engineer using ALOHA)

Release Mitigation: ECB and ADT Flow Diagram

Photo ECB:

Release Source: Brass Fitting

View Description: Brass Fitting and Cap

Note: Eroded Cap where ammonia release occurred

Follow-up: NCR/CalEMA Report

View Description: NRC reported incident to CalEMA <2 hours after initial discovery.

Follow-up: CalEMA Report-Update

View Description:

8 days after incident -“Processor”contacted CalEMA with update –including ammonia release ammonia amount

The Fines (EPA and State EPA):

Emergency Notifications are critical – 4 calls within 15 minutes.Processor contacted the Fire Department and CUPA in good time, yet faced EPA fines. Learn how to prepare and train to make four reporting calls in the requisite 15 minutes.$ 20,200 – for notification ~2 hours after discovery to National Response Center$ 30,300 - for call made 8 days after discovery to the State CalEMA (Note: State CalEMA records show the NRC contacted them within 2 minutes of when the NRC received notification.)

TOTAL of $50,500 Fines

Excerpt from EPA Letter to Processor (Final Fines):

Today- How do our Talks align with this Incident:

XFollow-up

XResponse/Recovery

XXXMitigation

XPreparedness

XXXPrevention

Emergency Response and Notification

Mechanical Integrity

Finding the Brass -Contractor

Finding The Brass -Facility

ECBHealth & Safety

Conclusion – Our Hope…We’ll make no bones about it; it is difficult to get companies to share info on ammonia releases…

Weigh this effort against the Tech or Manager – who may learn just one thing -today–– who may avoid a major ammonia release …

We hope that Regulators will consider this and try to figure positive encouragements for others to share…We hope other Companies, who have had incidents, will altruistically share, as did our Processor today.

Again – to our anonymous Processor – a huge thanks…