Scottsboro Aluminum, LLC - Executive Summary
ACCIDENTAL RELEASE PREVENTION PROGRAM AND EMERGENCY RESPONSE POLICY |
It is the policy of the Scottsboro Aluminum, LLC, Scottsboro, Alabama facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to Scottsboro Aluminum's employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordination response activities, as necessary with the local emergency response providers.
Scottsboro Aluminum's management is committed to providing the resources necessary to implement this policy.
Aluminum melting began at the Scottsboro Aluminum, LL
C plant in 1968.
Aluminum is received in the form of ingots, sows, scrap and RSI and melted in five reverberatory melting furnaces. Molten aluminum is transferred into three holding furnaces and from there is cast into ingots. Ingots are reheated in six Ingot Reheat Furnaces. The hot ingots are rolled into sheets in one reversing hot rolling mill and one tandem hot rolling mill and formed into coils. Some of the coils are coated in a coating or "paint" line prior to shipment. Some of the aluminum coils are slit into narrow strips and formed into continuous aluminum tubing. Coils may be sold directly after hot rolling, or continue to cold rolling, annealing and finishing for further processing. Aluminum products thus formed are shipped to national and international customers.
The only toxic chemical of concern, chlorine, is used in the casting process. It is first mixed with argon as a carrier gas in a mixing shed outside of the production building, then piped to the casting pr
This document presents the RMP for the chlorine system.
WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS
The worst-case chlorine scenario involves the release of the entire contents of a one-ton cylinder of chlorine. For the worst-case scenario, the release rate is not considered. The total quantity of the chlorine is assumed to form a vapor cloud. This cloud is dispersed outward from the source until concentrations are reduced to the toxic endpoint. EPA's RMPComp program was used to calculate the distance to the toxic endpoint (DTE). The worst-case scenario for chlorine at the Scottsboro Aluminum, LLC facility indicates a DTE of 0.9 miles. The model assumed the mixing shed would act as passive mitigation.
Scottsboro Aluminum, LLC investigated one alternate release scenarios. This scenario describes a release which occurs from a pipe break adjacent to the cylinder, with chlorine still liquefied under pressure. The DTE for this scenario is 0.6 miles.
CCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS
The Scottsboro Aluminum, LLC facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and to the environment. These regulations include:
40 CFR Part 68, Accidental Release Prevention
40 CFR Part 112, Spill Prevention, Control and Countermeasure
40 CFR Part 264, Hazardous Waste Contingency Plan
29 CFR Part 119, Process Safety Management
The key concepts in Scottsboro Aluminum's release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees.
Employee participation in the release prevention program is encouraged and supported by Scottsboro Aluminum's management. Key personnel are responsible for conducting
and implementing the findings from the Process Safety Review for the chlorine system.
Scottsboro Aluminum's policy is to construct all new equipment, systems, and facilities in accordance with the most current building and safety codes. This ensures the appropriate safety and release prevention systems are included from the beginning of each project. Scottsboro Aluminum maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release.
Scottsboro Aluminum is committed to providing appropriate training to all employees regarding safety procedures. New employees are provided comprehensive safety training during their initial orientation for the facility. Additional training is provided to maintenance personnel for the systems for which they are responsible.
FIVE YEAR ACCIDENT HISTORY
Scottsboro Aluminum has not had a release of chlorine from the facility that has affected the public or the environmen
EMERGENCY RESPONSE PROGRAM
Scottsboro Aluminum has emergency response capability on site to respond to a chlorine emergency. Scottsboro Aluminum's employees, trained in the safe operation of the chlorine system, will close manual shutoff valves to terminate the flow of chlorine if the valves can be safely approached. For all other scenarios, Scottsboro Aluminum's employees will evacuate the area and allow off-site responders to respond to the chlorine emergency. Scottsboro Aluminum has met with the local fire department and the Local Emergency Response Commission to review the chlorine system and to establish coordination and communication procedures.
PLANNED CHANGES TO IMPROVE SAFETY
Scottsboro Aluminum has completed the safety review of the chlorine system, including a hazard and operability (HAZOP) analysis. Based on the review, Scottsboro Aluminum will be reviewing maintenance of the alarm systems, employee training, and operating procedures.