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September 8, 2000

On August 28, 2000, Apache experienced a minor release of Anhydrous Ammonia into the atmosphere at approximately 4:30 a.m. Appropriate regulatory and emergency response agencies were notified. A relief valve on a heater vessel operating per design opened due to high pressure and caused the release. Apache immediately performed a technical review of the release and will continue to do so to determine what can be done to eliminate or reduce the chances of a reoccurrence of this incident.

At the time of the release and in accordance with Apache procedure, Apache personnel immediately proceeded to the company's property line to obtain ammonia readings. While several locations had readings of zero, one location had a reading of less than 5 parts per million (ppm), a low level reading. According to the American Industrial Hygiene Association, work can be safely conducted with ammonia levels at 25 ppm and OSHA standards state that work can be conducted safely with ammonia levels at 50 ppm. Notwithstanding this fact, Apache initiated as a precaution the Community Warning Siren and Community Alert Network (CAN) system between 4:45 and 5:00 a.m. A representative from 911 authorized the sounding of the all-clear siren at approximately 5:15 a.m.

Since area neighbors are accustomed to only hearing the alert siren when it is tested each Wednesday at 1:00 p.m., and this was the first official use (non-test) of the siren in at least ten years, the 4:30 a.m. siren resulted in numerous phone calls to the plant and to 911. Some neighbors responded to the Community Alert Network (CAN) message by implementing Shelter-In-Place in their homes. Apache had previously supplied Shelter-In-Place kits, starting in January, 1999, to its nearby neighbors to ensure proper response in the unlikely event of a release. After sheltering in place, some neighbors did not hear the all-clear siren. To prevent this from occurring in the future, an all clear CAN message will be initiated along with the All Clear alert siren once an all clear is authorized by Emergency Services personnel.

At Apache we are committed to being a good neighbor. While the process of warning our neighbors during the release on August 28 worked well for the majority of our neighbors, it was not as effective for a few as evidenced by their failure to hear the "all-clear" siren. Therefore, to increase the effectiveness of our warning system, we commit to do the following:

1. conduct additional community meetings during the next 30 days to again inform residents about our Risk Management Plan and Shelter-In-Place;
2. place an informational Public Service Announcement in the local newspaper and on the local radio station on a monthly basis reminding the community how the Community Warning Siren works and what to do in the unlikely event the system is activated;
3. mail an information packet regarding the products used at Apache, pertinent emergency response methods, and access to Shelter-In-Place instructions and videos to over 900 St. David addresses within the next 30 days; and,
4. conduct an annual plant Open House.

1. as needed, mail the Apache Update to over 1,500 community and state residents as the main vehicle to communicate the latest activities at the plant;
2. secure community input from area residents through the Apache Community Advisory Committee;
3. actively participate in the Local Emergency Planning Committee & the St. David Citizens Committee;
4. conduct annual community drills to test emergency community preparedness; and
5. provide emergency preparedness educational workshops for students and teachers in our local schools.

We will continue to use the comments and suggestions of our neighbors and other area citizens to improve our communication. If you would like to provide additional input, please call Cindi Byrns at 520-720-2114, or Lyndon Denton at 520-720-2190.

Apache scheduled, publicized, and held three community information and education meetings to roll out Apache's Risk Management Plan in January of 2000. Although the meetings were very widely publicized via radio and newspaper, the meetings were very sparsely attended. In September, Apache will schedule and publicize additional meetings to inform area residents about Apache's Risk Management Plan and Shelter-In-Place. Information to be covered will include details regarding the Community Warning Siren, and the actions to be taken if it sounds. To assure the best possible notification of these meetings, in addition to radio and newspaper announcements, we have made arrangements to provide mail notification to each of the 900-plus St. David Postal Patrons.

Apache is constantly seeking ways in which to reduce emissions from its facility even though current emissions are well below federal and state health based standards. To that end, we continue to test and evaluate the best method to reduce emissions of nitrous oxides (NOx) that occur during the one to two-hour start-up period of the nitric acid plants. Initially, Apache was aggressively pursuing the installation of a start-up heater that has been proven to lower emissions from the small nitric acid plant. We have also identified another method for reducing emissions from both nitric acid plants by introducing hydrogen peroxide into the processes. Simply put, the hydrogen peroxide (H2O2) reacts with the nitrous oxide (NOx) to produce nitric acid and water. This ultimately reduces emissions and the quantity and duration of the orange colored plume of NOx that occurs during each nitric acid plant start-up. If successful, we would be the first company in our industry to deploy this technology for start-up emission reduction. We are currently completing the evaluation of the hydrogen peroxide method, and will soon determine whether the start-up heater or hydrogen peroxide method will be installed permanently.

If you have any questions or comments, please contact Lyndon Denton, Director of Resources, at

520-720-2190.