Western Zirconium - Executive Summary

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Introduction 
 
Western Zirconium, a division of Westinghouse Electric Company LLC, is an integrated manufacturing facility, which extracts zirconium from sand and produces zirconium metal and metal products.  The facility, which employs about 400 people is located in a remote area of Weber County, Utah, near the eastern shore of the Great Salt Lake.  The zirconium produced by Western Zirconium is used worldwide primarily by the commercial nuclear fuels industry.  The process of separating zirconium metal from the sand which contains it, involves the use of several chemicals including chlorine and ammonia.  Because of the nature of the manufacturing process, the facility typically maintains a sizable inventory of these chemicals on-site.  We also maintain a large quantity of propane, which is used for supplemental heating and to fuel a calciner and the plant boilers.  The employees of Western Zirconium are proud of our 20-year history of safe handling of these chemicals.  While the produ 
cts we produce are used by nuclear power utilities, the products we make do not contain radioactive materials.   
 
The following paragraphs present some additional information about Western Zirconium, its commitment to safety and protection of the environment, and how we employ this commitment to minimize risk to the community. 
 
Our Commitment to Safety and the Environment 
 
The employees and management at Western Zirconium believe that nothing is more important than the health and safety of its employees, its contractors, the general public, and the protection of the environment.  Western Zirconium prides itself on its commitment to meet or exceed all applicable legal and regulatory requirements.  Since 1992 Western Zirconium has held "Star" status under the Occupational Safety and Health Administration's (OSHA) Voluntary Protection Program (VPP). 
 
OSHA VPP recognizes worksites that have achieved and are maintaining excellence in worker safety and health protection through cooperation a 
mong labor, management, and government.  The VPP is composed of three programs.  The Star Program is the highest level of the VPP and designates sites that have distinguished themselves with the highest level of safety and health excellence.  By granting Western Zirconium Star status OSHA has recognized our management commitment and meaningful employee involvement in safety and health programs.  These programs include worksite analysis for hazards, hazard prevention and control, and employee safety and health training.  
 
Our commitment to safety and environmental protection includes the following specific commitments: 
7 A commitment to prevent accidents and to minimize, as far as reasonably achievable, the consequences of any accident which may occur; 
7 A commitment to meet all statutory requirements for safety and environmental protection; 
7 A commitment to strive for continual improvement in performance; 
7 A commitment to strive to increase safety and environmental awareness among em 
ployees and the public; 
7 A commitment to consider safety and environmental effects in designing and operating plant processes; 
7 A commitment to minimize waste and encourage the reuse and recycling of materials; 
7 A commitment to the efficient use of energy, water and raw materials; 
7 A commitment to monitor discharges, disposals and the environment around the company site to ensure compliance with appropriate standards; 
7 A commitment to encourage dialogue with employees, members of the public, local authorities, regulators and other interested parties; 
 
How We Minimize Risks to the Community 
 
The manufacture of zirconium and the fabrication of zirconium products entails the use of chlorine, silicone tetrachloride, propane, ammonium hydroxide (aqueous ammonia) and anhydrous ammonia.  The facility stores these chemicals in tanks and rail cars and transfers them into process equipment through pipelines.  Because these chemicals are inherently toxic or flammable, the management and empl 
oyees of Western Zirconium have spent a considerable amount of time and effort assessing potential dangers associated with storing and using these chemicals in our processes.  In doing so, we employed EPA and OSHA recognized approaches for evaluating potential hazards.  Potential dangers associated with these chemicals include potential toxic release, fire, and environmental impact. 
 
The risk associated with a chemical hazard is evaluated based on several variables, including the likelihood of a release occurring, the inherent hazards of the chemical involved, the quantity released, the potential impact of the release on the public and the environment, and mitigating influences such as safety planning and safety systems.  Pursuant to the requirements of EPAs Risk Management Program, we have analyzed worst case scenarios using assumptions developed by EPA and site specific alternative scenarios.  For specific reasons discussed below, we believe the alternative site specific scenario is 
more representative of a realistic worst case.  For both scenarios, we have followed procedures outlined in EPAs Risk Management Plan Off-site Consequence Analysis Guidance document.  Data developed using EPAs guidance document is very conservative, that is, it overestimates the distance a toxic release would likely travel.  
 
For purposes of this analysis, the worst case scenario for a toxic substance release from Western Zirconium is the near instantaneous release of a rail car quantity of chlorine.  The cloud formed by this sudden release of chlorine gas might reach off-site endpoints and distant public receptors.  However, Western Zirconium believes that in reality this is a very improbable scenario.  Chlorine rail cars must meet stringent design standards.  For example, chlorine rail cars are built to withstand a rollover with minimal damage.  Even in the worst accident, it is highly unlikely that the entire contents of the car would be released.  A more likely alternate scenari 
o would involve a pipe or valve break, which would cause the release of a much smaller quantity that could be quickly contained.  Because Western Zirconium is located in a relatively remote, unoccupied area, a cloud formed by a pipe break would not reach distant public receptors.  In addition to the safety inherent in chlorine rail car design, Western Zirconium employs other safeguards including automatic shutoffs and monitoring systems.  Chlorine, ammonia and other chemical processes at Western Zirconium comply with OSHAs Chemical Process Safety Management Standard.  The worst case scenario for flammable substances is the near instantaneous release of the entire contents of an 18,000-gallon storage tank of propane when filled to the greatest amount allowed, and a subsequent vapor cloud explosion.  Again, because of the size of the Western Zirconium site, such an explosion has no off-site consequences.  The Western Zirconium propane system complies with the National Fire Protection As 
sociations (NFPA) National Fuel Gas Code.  No chemical releases have occurred at Western Zirconium during the last five years that resulted in off-site injuries or property damage.  One on-site injury from chlorine occurred during this same time period.  In response to the accident, operational procedures to prevent recurrence were implemented.  
 
Low public risk exists for the following reasons: 
 
7 Western Zirconium uses generally recognized best management practices and methods to prevent accidental releases of hazardous chemicals.  These methods include such things as employee training, preventative and predictive maintenance procedures to prevent equipment failures, automatic shutoffs, and monitoring systems.  Well established operating procedures are used to ensure that process equipment is operated within safe limits. 
 
7 Western Zirconium's safety program includes an Emergency Response Plan and on-site response teams.  Our ability to respond to an emergency has always been a top  
priority for Western Zirconium.  The plant has its own well trained and equipped Fire and Hazardous Materials Response Teams staffed by employees.  These response teams receive special training comparable to local fire departments.  Our response teams periodically conduct training exercises with local fire departments.  Western Zirconium emergency response is coordinated by the Weber County, Utah, Local Emergency Planning Committee (LEPC).  Because of our expertise in handling chemical emergencies, the public emergency response agencies have asked Western Zirconiums Fire and Hazardous Material Response Teams for assistance, on occasion, to protect the community from chemical emergencies caused by others.  The local communities know they can call on us at any time to assist them as needed. 
 
7 In the event a release would occur, it is generally the area most near the site of the release -- within a half mile or less  that would be most affected.  The Western Zirconium facility is locat 
ed in a remote unoccupied area with no adjacent residential population.  Western Zirconium owns the vacant land surrounding our facility, which reduces the risk of a chemical release leaving our site.  
 
For More Information 
If you would like to learn more about Western Zirconium or Westinghouse Electric Company LLC, please visit our Internet web page at www.westinghouse.com or contact Mr. Kent J. Bradford, Manager of Environmental Health and Safety at bradfokj@westinghouse.com
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