Elkem Metals Company, LP, Alloy, WV Facility - Executive Summary |
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Accidental release prevention and emergency response policies: The Elkem Metals Company (Elkem) facility in Alloy, West Virginia utilizes anhydrous sulfur dioxide (SO2) to treat boiler off-gases. Because sulfur dioxide is a compound listed by the Occupation Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA), management of the flue gas conditioning process is regulated by these two agencies. In order to comply with regulatory requirements and to protect the health and safety of its employees, the surrounding community and the environment, Elkem has established a comprehensive risk management program to ensure continued safety of its day-to-day processes and operations. Primary activities, use of regulated substance and quantities stored: In the conditioning process, SO2 is converted to sulfur trioxide (SO3), which is then injected into the flue gas stream. The SO3 adjusts the flue gas properties thereby improving electrostatic precipitator perfo rmance and reducing particulate emissions from the boiler. A maximum of nine 1-ton SO2 cylinders are stored at the facility at one time, for a maximum on site quantity of 18,000 pounds. Worst-case scenario: It is believed that the worst potential release would be the collapse or rupture of one of the SO2 cylinders. Based upon RMP regulatory requirements, it is assumed that all of the material in the cylinder would be released to the environment within 10 minutes. Such an unlikely release has the potential to affect citizens within a 13.17 mile radius of the release site. This area includes the residences and businesses of 22,483 people. Even though this is an extremely unlikely situation, Elkem personnel routinely inspect the cylinders for damage. All cylinders are also periodically subjected to a complete internal and external inspection by certified inspectors. Further safeguards include fusible links that are installed on each cylinder to prevent rupture of the cylinder and SO2 detectors that are permanently installed at the cylinder storage area. These detectors alert personnel to potential leakage allowing them to address any problem before it reaches a serious level. Alternate release scenario: An alternate release scenario would be a hole in the vessel, rather than a vessel rupture, pipe break or a hole in the pipe. In the instance that a hole would occur in the vessel, receptors within 3.42 miles may be affected, which includes the residences and businesses of approximately 4,500 people. In the instance of a transfer hose failure, receptors within 1.32 miles may be affected, which includes the residences and businesses of approximately 1,600 people. In the instance of a gas pipe failure, receptors within 0.33 miles may be affected, which includes the residences and businesses of approximately 7 people. General accidental release prevention: Elkem has established a comprehensive risk management system that meets the requirements of OSHA PSM a nd EPA RMP standards to ensure the safe operation of the conditioning process. To identify potential SO2 release situations, Elkem has analyzed the conditioning process, how the elements interact, how the equipment can fail and has implemented practices to prevent and react to failures. In addition, Elkem has established facility-wide procedures on managing hazardous activities, such as welding, and process-specific procedures addressing the hazards, operations and maintenance activities unique to the conditioning process. All personnel that may be required to perform these activities are trained in the proper procedures. Employees also participate in the development of the procedures and other documentation related to the process in order to utilize their experience and knowledge. Process changes are analyzed before implementation to prevent creation of new hazards, and new equipment is routinely inspected and tested before it is placed in service. Five year accident history: I n the last five years there have been no reportable releases of SO2 from the Alloy, West Virginia facility. Elkem fully investigates every incident that occurs at the facility and has developed an emergency response program that includes on-site personnel specially trained to handle SO2 releases. These specially trained personnel work in coordination with the Fayette County LEPC. |