Fritz Products, Inc - Executive Summary |
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1. Executive Summary 1.1. Applicability An owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process shall prepare a Risk Management Plan in accordance with 40 CFR 68. In addition, a facility which exceeds the OSHA threshold for highly hazardous chemicals listed in Appendix A to 29 CFR1910.119 is required to meet the Process Safety Management standards under this section. The threshold quantities for chlorine under 40 CFR 68 and 29 CFR 1910.119 are 2500 and 1500 pounds, respectively. Since Fritz Products, Inc. stores chlorine in quantities exceeding these thresholds they are required to meet both requirements. Because of similar elements between the Risk Management Plan (RMP) and the Process Safety Management (PSM) Plan, Fritz Products, Inc. has chosen to integrate their PSM into the RMP. In addition copies of their other plans have been included in this plan as attachments. These include: 7 Pollution Incident Prevention and Spill Prevention Control and Countermeasure Plan; 7 Chemical Spill Control and Prevention Plan; 7 Storm Water Pollution Prevention Plan; and 7 Emergency Response Plan. 1.2. Company Policy Fritz Products, Inc. (Fritz Products) recognizes the intrinsic value for the well being of the employees and customers of their River Rouge, Michigan aluminum plant, and considers that their safety is a primary objective. The facility will provide for a safety program committed to: developing safe work practices and procedures to maintain property and equipment in a safe condition; providing training to its employees to enable them to work without accident; and ensuring that all employees comply with all safety rules, regulations, practices and procedures. All aspects of the safety program will be administered with fairness and consistency. The plant manager will be held accountable and responsible for, and actively support and participate in the program, including communication of, understanding and compliance with, and monitoring of safety performance. 1.3. Stationary Source Information Fritz Products River Rouge facility is a secondary aluminum plant employing approximately 32 employees in River Rouge, Michigan. The facility uses chlorine for de-magging purposes and the site stores a maximum of 16 pressurized storage containers, each with a capacity of one ton. The plant is located on the East Side of River Rouge, with the Detroit River to the East, industrial areas to the North and South, and residential areas to the West. 1.4. Scenarios and Controls The Risk Management Plan addresses the potential off-site impacts from a catastrophic release of Chlorine. Two scenarios are considered in this plan. The first scenario considered is a full release of the chlorine from one 2000-pound vessel of chlorine over a ten minute time period. The release is assumed to occur outside the building during a chlorine delivery, maximizing the impact of the release. The second scenario consid ered is the more likely release scenario of a leak resulting from the rupture of piping, resulting in an indoor release of 16 pounds over a 60-second time period. 1.5. Accidental Release Prevention Program Fritz Products River Rouge Foundry has developed a Process Safety Management Plan and work procedures and controls to ensure that an accidental release of chlorine does not occur at the foundry. The employees have been trained to ensure familiarity with these processes and procedures, and written procedures can be referred to. Periodic and refresher training is also conducted to review these procedures and any new procedures that may be developed and implemented. These procedures are also reviewed with contractors working with the chlorine system. 1.6. Five-Year Accident History Fritz Products has not experienced a release of chlorine at the River Rouge foundry in the five years preceding the preparation and submittal of this Risk Management Plan. Fritz Products will respond approp riately as outlined in our Emergency Management Plan in the event of a chlorine release from the process. In addition, the implementation of this Process Safety Management Plan and Risk Management Plan will help ensure that a release of chlorine does not occur from this process. 1.7. Emergency Response Program Fritz Products has prepared an Emergency Response Plan that is designed for timely, safe and efficient response actions to minimize hazards to human health and safety, the environment, and property in situations involving releases of chlorine from the covered processes at the foundry. See Section 6.0 for details on the plan. This plan is reviewed periodically to ensure that the information is accurate. Local response authorities have been provided with a copy of the plan in the event that they would be required to respond to an emergency at the facility. |