Missouri Smelting Technology, Inc. - Executive Summary |
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The accidental release prevention and emergency response policies at Missouri Smelting Technology, Inc. (MOST): Safe workplace practices are considered a condition of employment for all MOST employees. By upholding the management principals of the Chlorine Institute, we exercise responsible care facility wide. Our facility and the regulated substance we handle: MOST is a secondary aluminum smelter. MOST utilizes chlorine to treat molten aluminum. In February 1999 construction of our new facility was completed. The chlorine treatment system is completed, although we have not utilized it's service as of June 21, 1999. The chlorine treatment system utilizes liquid chlorine stored in 1-ton containers. Four 1-ton containers are stored onsite. The target startup date of our chlorine system is July 1, 1999. But since we have completed construction of the system, we respectfully submit the MOST RMP for review. The Risk Management Provisions of the US EPA Clean Air Act requires facilities handling a regulated substance to list a Worst Case Scenario, and an Alternative Case Scenario to provide neighboring communities with an off site impact from a chemical release or accident. MOST utilized RMP Comp Software to determine the offsite impacts during a Worst Case Study, and research conducted by the Chlorine Institute to develop an Alternative Case Study. Worst Case Scenario: Utilizing the methodology as described by the US EPA, the off site impact of a complete- instantaneous release of a one ton container of chlorine would have a circular impact of 3.0 miles. It is important to note the following: US DOT Performance Orientated Packaging Standard requires package performance testing and hydrostatic testing which should eliminate the shearing or splitting of a one ton container even if the container is dropped. And even if a container ruptured, we have trained response personnel onsite who have the equipment and knowledge to mitigate chlorine leaks. With respect to t he RMP rule, we feel that a 3.0 circular impact is accurate. Although MOST has never had an incident involving chlorine, the MOST Emergency Response Plan requires our Incident Commander to immediately report any substantial release of chemicals to the Local Fire Department, the Local Emergency Planning Committee, and the State Emergency Response Committee. We also have trained responders on site who would take immediate action during the initial phase of a release. Alternative Release Scenario: Since MOST has never had an incident involving chlorine or any recordable release of a regulated chemical, we utilized the Chlorine Institute to research an alternative scenario. We came to the conclusion that the most-likely event that could result in a release of chlorine would be a line break. Utilizing the Chlorine Institute's Generic RMP Scenario V, we conclude the following: 1. Release rate of 22.6 lbs/min 2. Release duration 60 mins. 3. Quantity released 1,356 lbs. 4. Off site cir cular impact of 0.30 mi. It is important to note the following: MOST's chlorine treatment system was developed utilizing numerous safety checks and release mitigation mechanisms. Our automatic shutoff valves would shutdown our chlorine feed system in seconds during a release. The general accidental release prevention program and chemical-specific prevention steps The Chlorine Treatment System is a process regulated by the OSHA Process Safety directives. Mechanical Integrity Inspections provide operators with a safety checklist to ensure the operational integrity of our process. All operators understand the physical and chemical characteristics of chlorine. Employees involved with the process must have a thorough understanding of all respective operating procedures. Five year accident history: Zero accidents, Zero incidents Emergency Response Plan: The Emergency Response Plan is utilized during a release of chlorine at MOST, Inc. Utilizing an Incident Command System, a plant Incident Commander dictates mitigation directives to trained responders, and communicates with local authorities to protect our neighbors. Annual training is required for all employees. The last training conducted was in February, 1999. With the above listed directives and comments, MOST, Inc. respectfully submits our facilities Risk Management Plan. |