Alcan Ingot - Executive Summary |
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Alcan Ingot, Inc. (Alcan) located in Henderson, Kentucky is a primary aluminum smelter plant. It has approximately 16,000 pounds of chlorine in storage. The chlorine is stored and used at two locations, the casting plant and the potable water treatment plant, in one-ton cylinders. The chlorine storage is subject to the requirements of the Occupational Safety and Health Administration (OSHA) regulations under 29 CFR 1910.119 for Process Safety Management (PSM) based on Alcan's storage of greater than 2,500 pounds of chlorine. Alcan's Health, Safety and Industrial Hygiene Group has completed and implemented such a program. Alcan is also subject to CAA Section 112(r)(7) requirements for chlorine in each plant. This regulation requires affected facilities to develop hazard assessments, management programs, prevention programs, and emergency response programs. A facility is covered by the RMP rule if it has in inventory a regulated chemical in greater than the threshold quantity. Fo rchlorine, the level is 2,500 pounds; therefore, the Alcan plant is also regulated by the RMP regulations. Alcan has previously met many of the requirements with the implementation of the Process Safety Management Plan. The attached Risk Management Plan submittal shows that Alcan is meeting the requirements of 112(R). Also, 240,000 gallons of propane is stored in five, 90,000 gallons capacity, underground storage tanks. There is no PSM requirement for propane in the OSHA regulations. The CAA Section 112(R)(7) regulation states that facilities that store greater than 10,000 pounds (approximately 2,300 gallons) of flammable substances including propane must comply with this rule. At this time, changes in the regulations for flammable substances, including propane are pending. Alcan is voluntarily submitting information pertaining to propane in this program. Alcan reserves the right to revise the Risk Management Plan to reflect the requirements of the stayed rule. In compliance with the regulations, Alcan has conducted one worst-case analysis for each covered process. Alcan has also conducted at least one alternative analysis for each covered process. The table below provides a summary of these analyses. The USEPA approved SLAB air dispersion model was used to determine the distance to toxic endpoint in each scenario. Scenario Chemical Release Description Distance to Toxic Endpoint Worst-case Chlorine (casting) 1 ton cylinder 1.9 miles Chlorine (potable water) 1 ton cylinder 2.1 miles Propane 90,000 gallon tank 0.56 mile Alternate Chlorine (casting) Pipe release outside (29 lbs) 0.11 mile Chlorine (potable water) Empty cylinder release (50 lbs) 0.13 mile Propane #1 Pipe release- loading (39543 lbs) 0.28 mile Propane #2 Propane trailer upset (8501 lbs) 0.16 mile Alcan is located in a rural area; therefore, the residential population impacted by the scenarios shown above is minimal. Each of the worst-case scenarios only impacts a few commercial/ industrial areas and two residences. The actual residential population in the radii of impact totals to 8 people. There are no environmental receptors impacted by the worst-case impact areas. The alternate scenarios considered were based on more realistic incidents. The radius of impact for each of these scenarios does not cross the plant boundary; therefore, they do not impact any off-site public or environmental receptors. Alcan Ingot has had only one accidental release of chlorine in the past five years. This release was occurred over a period of five minutes and it was estimated that less than 4 pounds of chlorine was released. There were no off-site injuries or other impacts as a result of this incident. Following this incident, Alcan upgraded the equipment involved in the incident, installed new process controls, and revised the operating procedures and emergency response plan to help prevent the occurrence of this incident in the future. There have been no accidental releases of propane in the past five years. A Program 2 Prevention Program is in place for Alcan's propane storage systems. The elements included in this program consist of the following: oSafety information oHazard review oWritten operating procedures oTraining programs oMaintenance procedures oCompliance audits oIncident investigations The required safety information has been compiled based on Alcan's ongoing programs and procedures. A hazard review was performed and the results are documented in the Risk Management Plan. Alcan is in compliance with the training requirements of Part 68, as documented in the Risk Manag ement Plan. The plant's preventive maintenance procedures were reviewed and found to be in compliance with Part 68. The procedures are outlined in the Risk Management Plan. A schedule and mechanism for conducting periodic compliance audits has been established as well as a procedure and format for conducting incident investigations. A Program 3 Prevention Program is in place for Alcan's chlorine storage systems. The elements required for a Program 3 Prevention Program as required in 40 CFR Part 68, Subpart C are included in Alcan's Process Safety Management Plan required by 29 CFR 1910.119. The elements include: oProcess Safety Information oProcess Hazard Analysis oOperating Procedures oTraining oMechanical Integrity oManagement of Change oPre-Startup Review oCompliance Audits oIncident Investigation oEmployee Participation oHot Work Permits oContractors The required safety information has been compiled based on Alcan's ongoing programs and procedures. A process hazard analysis was performed and the results are documented in the Process Safety Management Plan and the Risk Management Plan. Alcan is in compliance with the requirements for all of the above-mentioned elements. The method in which Alcan handles each element is outlined in the Risk Management Plan. A schedule and mechanism for conducting periodic compliance audits has been established as well as a procedure and format for conducting incident investigations. A copy of the Process Safety Management Program Manual is maintained on file with the Risk Management Program to provide easy access to the referenced information. Alcan has several process controls in use to help prevent the occurrence of major hazards. Alcan strives to maintain a safe working environment for it's employees and other people who live and work near the plant. Alcan is involved with the Henderson County Local Emergency Planning Committee and maintains an emergency response plan in compliance with the requirements of 112(R). The Local Emergency Planning Committee has also approved Alcan's Emergency Response Plan. During emergency situations, the Emergency Preparedness Coordinator, or in his absence the senior Security Office on duty (or his designate), will relay information to the fire departments, Henderson Community Hospital, and State Police, coordinating any action they need to take. State Police will coordinate evacuation of areas outside the plant if needed, or restricting use of public roads. All Emergency Response Team members are trained in: Hazwoper - Hazardous Waste Operations and Emergency Response, Basic First Aid, Community CPR, Incident Command System, Blood Borne Pathogens, Confined Space Rescue, and Basic Fire Fighter curriculum dealing with incident fires and advanced interior attack firefighting. A copy of the Risk Management Plan will be submitted to USEPA as required by the June 21, 1999 deadline. A copy of this plan will also be submitted to the Kentucky Division for Air Quality and the local planning committee to make it available for public review. |