Noranda Aluminum, Inc.-Primary Products - Executive Summary |
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Accidental release prevention and emergency response policies at Noranda Aluminum, Inc. - Primary Products. The policy of Noranda Aluminum, is to develop those programs necessary to protect the health of its employees against on-the-job hazards which may cause sickness or injury now or in the future. Also, as the operator of a facility at which substances may be used that in uncontrolled situations could cause harm to the public and damage to the environment, we will strive for environmental excellence with a commitment to continual improvement, pollution prevention and compliance with legislative requirements. The Risk Management Program (RMP) is one of these programs. Each employee in areas where the RMP is applicable will be knowledgeable of the related policies and procedures and the supervisors or a designated person is required to insure that they understand them. Employees and supervisors are required to comply with our policies and are subject to corrective action in th ose cases determined to indicate willful violation. A written plan of action regarding the implementation of employee participation in the program has been developed as a part of our Release Prevention Program as specified by 29 CFR 1910.119. A compilation of safety information to enable Noranda Aluminum and the employees involved in the Propane operations to operate safety has been accumulated. This process safety information includes information pertaining to the toxicological and physical hazards of the chemical listed. This plan of action includes information pertaining to the technology of the processes, and information pertaining to any equipment used in the processes. A complete hazard analysis and study of the Propane systems' mechanical integrity has been completed on the Propane receipt, storage, and utilization operations have been completed. This analysis was completed by safety and health staff, engineering and maintenance personnel, and certain operational personnel. This analyses involved a review of each operation of the processes to address steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions. The assessment also included information concerning the emergency action plans related to the process; development and implementation of safe work practices regarding the control of entrance and exit of personnel in the process areas; pre-startup safety; mechanical integrity of equipment; inspection and testing, correction of deficiencies in equipment, planned or unexpected changes to the process, equipment, and procedures to the processes. A system was developed and is maintained to promptly address the team's findings and recommendations. The hazard analyses will be updated as needed and at least every five (5) years. Noranda Aluminum has developed and implemented written operating procedures to provide clear instructions for safely conducting activities involved in the processes at each operation by our employees, consistent with the process safety information and to address steps for each handling phase, limitations, safety and health considerations, and safety systems and their functions. Other written documentation of standard operating procedures as a part of this program is included in the following documents: Mechanical Integrity Study of Process Equipment Preventive Maintenance Program Written Emergency Response Plan Employee Emergency Action and Evacuation Plan Each employee involved in operations within the processes where the Propane is received, processed, or used at the facility has been trained in an overview of the processes and in the operating procedures as outlined by OSHA regulations. Refresher training is required every three years, and more often if necessary. Training includes: a. Emphasis on the specific safety and health hazards; b. Emergency operations in the case of a release including shutdown; and c. Safe work practices app licable to the employee's job tasks. Designated personnel have specific responsibilities related to the use of contractors who perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to areas where the Propane is received, stored, or processed in the facility. These responsibilities include specific requirements in selection of contractors regarding the contractor's safety performance and programs; the provision of information concerning the emergency action plans related to the process; development and implementation of safe work practices regarding the control of entrance and exit of contract employers and contract employees in the process areas, periodic evaluation of the contractor related to safety management at the process; maintenance of certain records related to contractor employee injury and illness; development of written procedures for any new processes, and provision of training to employees. Contractors performing work on or adja cent to equipment or processes in which Propane is present must have clearance from the Maintenance Supervisor prior to beginning operations. In those cases where contractors will perform work directly to or on the process equipment in which the Propane is present, the Safety Manager and Maintenance Supervisor will provide an orientation section to them prior to beginning operations. This orientation will include an introduction to the Noranda Aluminum Process Safety Management Program, information concerning the toxicological and physical hazards of Propane, and the emergency response plan in the case of an incident involving a release. Upon completion, a record is generated including the names and signed initials of those in attendance. The Noranda facility and the Propane Process Noranda Aluminum, Inc. - Primary Products is the largest employer in New Madrid, Missouri providing employment for 1200 workers making up approximately 62 % of the city's employment. It is a publicly owned company on the Public Toronto, Canada Exchange. As a manufacturer of aluminum billets its products are sold globally under its corporate company, Noranda, Inc., at BCE Place, 181 Bay Street, Suite 4100 P.O. Box 755, Toronto, Ontario, M5J 2T3, telephone number 416 982 7111. The facility is located on the Mississippi River in the St. Jude Industrial Park at Latitude N36 degrees30'44" and Longitude W089 degrees33'59". Worst-case release scenario and alternative release scenario As a part of the Noranda Aluminum proactive program concerning the hazards of Propane to its workers and the surrounding public, its staff has conducted a thorough hazard assessment. For the hazard assessment and the RMP, populations potentially affected are defined as those within a circle that has as its center the point of release and its radius the distance to the toxic or flammable endpoint. Owners or operators may use Census data to define this population. The presence of schools, hospitals, oth er institutions, public arenas, recreational areas, and large commercial and industrial developments that can be identified on street maps within this circle must be noted. The presence of environmental receptors within this circle must also be listed. The EPA has defined environmental receptors as natural areas such as national or state parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas, that can be exposed to an accidental release. The worst case scenario for propane was decided as the complete rapid loss of one full tank of propane (30,000 gallons) during a one minute release time. The following information was determined using the Automated Resource for Chemical Hazard Incident Evaluation (ARCHIE) model, based on the stability class F , 1.5 meters/sec wind speed, and the IDLH level of 2000 ppm for propane. This resulted in a release rate of 150,727 lbs/min, and an end point of 5.3 miles from the s pill point. The Alternate case scenario for propane was decided as the complete loss of one full tank of propane (30,000 gallons) during a spill from a four inch hole or broken pipe. The following information was determined using the Automated Resource for Chemical Hazard Incident Evaluation (ARCHIE) model, based on the stability class F , 1.5 meters/sec wind speed, and the IDLH level of 2000 ppm for propane. This resulted in a release rate of 18,574 lbs/min, for a duration of 8.12 minutes, and an end point of 4.37 miles from the spill point. General accidental release prevention program and chemical-specific prevention steps Prevention of a release is a core component of the Noranda Aluminum Risk Management Program. This program is designed to insure proper work practices and an on-going mechanical integrity program. This program also insures compliance with 29 CFR 1910.38, 1910.120, 1910.1200, 40 CFR, Part 68, Part 112, and Part 260. Noranda Aluminum has developed and implem ented written operating procedures to provide clear instructions for safely conducting activities involved in the processes at each operation by our employees, consistent with the process safety information and to address steps for each handling phase, limitations, safety and health considerations, and safety systems and their functions. Other written documentation of standard operating procedures as a part of this program is included in the following documents: Mechanical Integrity Study of Process Equipment Preventive Maintenance Program Written Emergency Response Plan Employee Emergency Action and Evacuation Plan Training Each employee involved in operations within the process where Propane is received, processed, or used at the facility has been trained in an overview of the process and in the operating procedures as outlined by 29 CFR 1910.119. Refresher training is provided no less than every three years and more often if necessary. Mechanical Integrity Also, each maintenance person who has responsibilities to perform maintenance on the process components receives training on an as needed basis, but no less than every three years. Emergency Response A team of individuals has been trained and is equipped as a HAZMAT team. The team is equipped with Self-Contained Breathing Apparatuses, Level A suits and monitoring equipment to respond in an offensive manner. A record of the training, which contains the identity of the employee, the date of training, and the means, used to verify that the employee understood the training is completed and maintained. Contractors. Designated personnel have specific responsibilities related to the use of contractors who perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to areas where the Propane is received, stored, or processed in the facility. These responsibilities include specific requirements in selection of contractors regarding the contractor's safety performance and program s; the provision of information concerning the emergency action plans related to the process; development and implementation of safe work practices regarding the control of entrance and exit of contract employers and contract employees in the process areas, periodic evaluation of the contractor related to safety management at the process; maintenance of certain records related to contractor employee injury and illness; development of written procedures for any new processes, and provision of training to employees. Five-year accident history No incidences of Propane release have occurred at the facility that resulted in deaths or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency response program Due to the receipt, usage, and storage of Propane in large quantities, Noranda Aluminum takes a proactive approach to the protection of its employees, the public, and the environment. In consideration of the hazardous effects that Propane may have on human health and the environment the following outlines the facilities prevention and emergency response plans: Written Emergency Response Plan Offensively Trained & Equipped Emergency Action Team in accordance with 29 CFR 1910.120 Development of a Written Implementation Plan of Action Conduction of Hazard Analysis on routine and periodic basis Development of and documentation of safe work practices Initial and periodic training of employees Conduction of pre-startup safety reviews Conduction of Compliance Audits Conduction of incident investigations Contractor Program Safety Program Hot Work Permit Program Process Safety Management & Chemical Accidental Release Prevention Committee Mechanical Integrity & Preventive Maintenance Program Determination and planning for Worst-Case and Alternative Case Release Scenarios Continual evaluation for methods to improve facility safety - Safety Committee Meetings wi th the Local Emergency Planning Committee and Fire Department Planned changes to improve safety In an attempt to insure a continual improvement in the facility worker protection and release prevention programs, training concerning this safety and environmental program and others is conducted annually. This training requires the attendance by all personnel whose job may have any relationship to the Propane operations. |