CUSTOM ALLOY LIGHT METALS, INC. - Executive Summary
a. Custom Alloy Light Metals, Inc. (CALM) is committed to the safety and well-being of its employees and the public. This commitment is demonstrated by the incorporation of numerous prevention, detection and mitigation measures in the replacement chlorine process for which this Risk Management Plan (RMP) has been prepared. CALM's policy is to implement reasonable measures to prevent a release of hazardous material from occurring, to provide early detection of a release in the unlikely event that one would occur, and to have in place a contingency plan to respond promptly yet safely to such a release. |
b. The RMP has been prepared to address the receipt, handling and use of chlorine in an upgraded chlorine system at the CALM facility at 13329 Ector Street in the City of Industry. Chlorine is received by tank truck, stored in a 5,000 gallon water capacity storage vessel and used in the resmelting of aluminum.
c. The worst case release scenario which was modeled was the release of the en
tire contents of the storage vessel over a period of ten minutes. No credit for any of the safeguards in place to prevent and/or mitigate such an incident were taken. The alternate release scenario which was modeled was the continuous release of chlorine liquid from a pipe or hose. This event was selected based on the findings of the Process Hazard Analysis. No credit for measures to prevent and/or mitigate such an incident were taken. There are offsite consequences associated with both release scenarios.
d. CALM has a comprehensive release prevention program meeting RMP Prevention Program and OSHA Process Safety Management (PSM) requirements. Physical Safeguards to prevent a release of chlorine including best industry practices for the design and construction of the chlorine storage vessel, equipment, piping and instrumentation, the use of expansion bottles and/or rupture disks and pressure switches to safeguard against hydrostatic overpressure of equipment and piping, and various pr
e. There have been no accidents involving chlorine within the five (5) years prior to submission of this RMP. In fact, to the knowledge of current management there have been no such incidents involving chlorine since the facility began operation nearly forty (40) years ago.
f. CALM has installed an Emergency Shutdown (ESD) system as part of the safety improvements described in Paragraph g below. The ESD system includes audible and visible warning and danger alarms to alert onsite personnel. In the case of a warning condition the Shift Supervisor and a trained, designated "buddy" will equip themselves with SCBA and evaluate the situation. If it is determined that the situation is one that can be safely rectified by response other than emergency response under Cal-OSHA Regulations Title 8, Section 5192, Hazardous Waste Operations and Emergency Response, they will take appropriate action. Otherwise the Los Angeles County Fire Department (LACFD) will be summoned, nei
ghbors will be notified and the facility will be promptly and safely evacuated.
g. CALM undertook a comprehensive Process Hazard Analysis (PHA) as part of a major safety upgrade in the summer of 1998. The following changes to improve safety were made:-
- Installation of a comprehensive detection and emergency shutdown system to isolate the chlorine storage vessel in the event of chlorine leak detection, seismic motion detection or other alarm conditions.
- Installation of outer sheathing on chlorine liquid piping to provide a mechanism for early leak detection.
Outfitting of each chlorine delivery tank trailer with an emergency shutdown system comparable to that installed on the fixed storage vessel is planned by the chlorine supplier.