Wabash Alloys, L.L.C - Executive Summary |
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Accidental release prevention and emergency response policies at Wabash The policy of Wabash Alloys, is to develop those programs necessary to protect the health of its employees against on-the-job hazards which may cause sickness or injury now or in the future. Also, as the operator of a facility at which substances may be used that in uncontrolled situations could cause harm to the public and damage to the environment, we will strive for environmental excellence with a commitment to continual improvement, pollution prevention and compliance with legislative requirements. The Risk Management Program (RMP) is one of these programs. Each employee in areas where the RMP is applicable will be knowledgeable of the related policies and procedures and the supervisors or a designated person is required to insure that they understand them. Employees and supervisors are required to comply with our policies and are subject to corrective action in those cases determined to indicate wi llful violation. A written plan of action regarding the implementation of employee participation in the program has been developed as a part of our Release Prevention Program as specified by 29 CFR 1910.119. A compilation of safety information to enable Wabash Alloys and the employees involved in the chlorine operations to operate safety has been accumulated. This process safety information includes information pertaining to the toxicological and physical hazards of the chemical listed. This plan of action includes information pertaining to the technology of the processes, and information pertaining to any equipment used in the processes. A complete hazard analysis and study of the chlorine systems' mechanical integrity has been completed on the chlorine receipt, storage, and utilization operations have been completed. This analysis was completed by safety and health staff, engineering and maintenance personnel, and certain operational personnel. This analyses involved a rev iew of each operation of the processes to address steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions. The assessment also included information concerning the emergency action plans related to the process; development and implementation of safe work practices regarding the control of entrance and exit of personnel in the process areas; pre-startup safety; mechanical integrity of equipment; inspection and testing, correction of deficiencies in equipment, planned or unexpected changes to the process, equipment, and procedures to the processes. A system was developed and is maintained to promptly address the team's findings and recommendations. The hazard analyses will be updated as needed and at least every five (5) years. Wabash Alloys has developed and implemented written operating procedures to provide clear instructions for safely conducting activities involved in the processes at each operation by our e mployees, consistent with the process safety information and to address steps for each handling phase, limitations, safety and health considerations, and safety systems and their functions. Other written documentation of standard operating procedures as a part of this program is included in the following documents: Job Safety Analyses Mechanical Integrity Study of Process Equipment Preventive Maintenance Program Written Emergency Response Plan Employee Emergency Action and Evacuation Plan Each employee involved in operations within the processes where the chlorine is received, processed, or used at the facility has been trained in an overview of the processes and in the operating procedures as outlined by OSHA regulations. Refresher training is required every three years, and more often if necessary. Training includes: a. Emphasis on the specific safety and health hazards; b. Emergency operations in the case of a release including sh utdown; and c. Safe work practices applicable to the employee's job tasks. Designated personnel have specific responsibilities related to the use of contractors who perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to areas where the Chlorine is received, stored, or processed in the facility. These responsibilities include specific requirements in selection of contractors regarding the contractor's safety performance and programs; the provision of information concerning the emergency action plans related to the process; development and implementation of safe work practices regarding the control of entrance and exit of contract employers and contract employees in the process areas, periodic evaluation of the contractor related to safety management at the process; maintenance of certain records related to contractor employee injury and illness; development of written procedures for any new processes, and provision of training to employees. Contractors performing work on or adjacent to equipment or processes in which Chlorine is present must have clearance from the Maintenance Supervisor prior to beginning operations. Each contractor will also complete the Wabash Alloys Divisional Visitor and Contractor Safety Rules form prior to entry into the facility. In those cases where contractors will perform work directly to or on the process equipment in which the Chlorine is present, the Safety Coordinator and Maintenance Supervisor will provide an orientation section to them prior to beginning operations. This orientation will include an introduction to the Wabash Alloys Process Safety Management Program, information concerning the toxicological and physical hazards of Chlorine, and the emergency response plan in the case of an incident involving a release. Upon completion, the contractor will be issued a permit by the Maintenance Supervisor to begin work. The Wabash facility and the Chlorine Process Wabash Alloys provi des employment for 85 workers in Dickson, Tennessee. This facility is one of eight other Aluminum recycling plants in the United States owned by Connell LLC. As a manufacturer of aluminum ingots its products are sold globally under its corporate company, Connell, LLC, 1 International Place, Fort Hill Square, Boston Massachusetts. The Wabash Alloys site is approximately 30 acres in size, and is located in a predominantly industrial area of Dickson. The site is serviced with electricity, water, natural gas, and sewer lines. The surrounding vicinity consists generally of industrial and manufacturing structures. The property is bordered on the west by railroad tracks and residences; to the east by residences; to the north by Printwood Drive and across the street by Tedsik Aluminum, and to the south by wooded areas. The western, active portion of the site is mostly occupied by scrap metal piles, loading docks, and a railroad spur. Two 55-ton rail tanker cars containing chlorine is also on the West Side. One of these cars is connected to the Wabash facility at a time. Access to the property is to the north side as well as employee parking. The entire site is fenced. The site process involves the sorting, grading, processing (removing organics via a rotary kiln), melting, and alloying of metals for sale. As part of the sorting process, large aluminum scrap is shredded or crushed, and ferrous metals are removed using a maseparation process. A dryer with a secondary combustion unit and baghouse is used to remove impurities from the aluminum scrap such as moisture, paints and resins. The sorted aluminum is charged into one of four furnaces where the metal is melted. Once melted, various additives are used to modify the composition and hence the physical characteristics of the metal. The metal is degassed by bubbling nitrogen through the molten metal. Magnesium is removed by bubbling chlorine through the melt to form magnesium chloride. Materials kept on- site for the process are aluminum, magnesium, zinc, copper, silicon, sodium, beryllium, and strontium. Approximately 8,000,000 pounds of these materials are on-site at any given time. Once the molten product is prepared, the melt is either poured and cooled as ingots or sows, or is transferred to heated crucibles for shipment as a molten material. Particulate emissions from the crusher are controlled with a baghouse. Emissions from melters, ingot and sow molding processes, and dross cooling operations are controlled using a baghouse. Chlorine is received at the facility in 55-ton rail cars. The tanker is connected into piping through which chlorine as liquid flows to a vaporizer at a pressure of 150 psi. The vaporizer heats the chlorine to the vapor state by a recirculated hot water electric heater, which is thermostatically controlled. Chlorine gas exits the vaporizer through a regulator and into a piping manifold to furnaces. Each furnace has its own chlorine supply pi pe and flowmeter, which regulates the pressure. At each particular furnace the chlorine gas passes a shut off valve, then through another flowmeter, and then through a needle valve where its flow is regulated by the furnace operator to the molten metal pump. Here the chlorine reacts with magnesium and aluminum to demag and clean the aluminum alloy. Geography and Weather: The city of Dickson is located in middle Tennessee approximately 40 miles west of Nashville and 160 miles east of Memphis. The city is a part of Dickson County, which covers 491 square miles at an elevation 814 feet. Highways to the city include Interstate 40, State highways 70, 46, 96, and 47, and in the future limited access to Interstate 840. Railroads include service by CSX Transportation System and South Central Tennessee Railroad. The nearest airport is the Dickson Municipal Airport with a runway length of 4,000 feet. The annual average temperature is 56.40 F (January 35.10 and July 74.50). The a verage annual precipitation is 58.4" with the prevailing winds being southerly. The mean length of Freeze Free Period (days) is 180-220. Population and Labor Force The population in Dickson County in 1998 was 42,046. The labor market area which includes Cheatham, Dickson, Hickman, Houston, Humphreys, Montgomery and Williamson Counties, Tennessee is 357,880. The Labor Force is 173,410. Government and Law Enforcement The government type is a City Mayor & Councilmen with a County Executive and Commissioners. Law Enforcement is by a police force of 31 full-time police officers in the city and 29 full-time police officers in the county. There is a 911 service available. Fire Department 1 Tanker, 5 pumper trucks, 1 brush truck, 1 ladder truck, 27-full time fire fighters, 10 volunteers. Schools The population is serviced by seven elementary schools, one junior high and two high schools. Medical Care Medical care support is provided by Columbia Horizon Medical Center which i s a 176-bed acute care hospital offering a comprehensive array of services. The facility provides 24-hour emergency services as a LifeFlight heliport link. The hospital also operates the Center for Corporate Health Services, located in the industrial park. Also, the Middle Tennessee Healthcare Group operates a Family Health Center for primary care. In addition the Group operates the Occupational Medical Center in Dickson offering work-related health services. Worst-case release scenario and alternative release scenario As a part of the Wabash Alloys proactive program concerning the hazards of chlorine to its' workers and the surrounding public, its staff has conducted a thorough hazard assessment. For the hazard assessment and the RMP, populations potentially affected are defined as those within a circle that has as its center the point of release and its radius the distance to the toxic or flammable endpoint. Owners or operators may use Census data to define this population. The presence of schools, hospitals, other institutions, public arenas, recreational areas, and large commercial and industrial developments that can be identified on street maps within this circle must be noted. The presence of environmental receptors within this circle must also be listed. The EPA has defined environmental receptors as natural areas such as national or state parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas, that can be exposed to an accidental release. One worst case scenario for chlorine was decided upon as the complete rapid loss of a 55 tons from the tanker car during a one-minute time frame. The only likely causes for such an incident is felt to be from a natural disaster or a derailment of the tanker car. The worst case scenario for chlorine was decided as the complete rapid loss of 55 tons of chlorine during a one-minute time frame. The following information was determined u sing the Automated Resource for Chemical Hazard Incident Evaluation (ARCHIE) model, based on the stability class F, 4.5 mph wind speed, and a toxic vapor level of 3ppm for chlorine. This resulted in a release rate of 110,000 lbs/min, and an end point of 24.05 miles from the spill point during summer season at 90 degrees F and 22.84 miles from the spill point during winter season at 40 degrees F. As an alternative case scenario it was decided that the possibility would include damage to a 1" pipe, probably at the connection station where the facility is connected to the chlorine tanker car. The following information was determined using the Automated Resource for Chemical Hazard Incident Evaluation (ARCHIE) model, based on the stability class F, 4.5 wind speed, and a toxic vapor level of 3ppm for chlorine. This resulted in an end point of .16 miles from the spill point. General accidental release prevention program and chemical-specific prevention steps Prevention of a release is a core component of the Wabash, LLC Risk Management Program. This program is designed to insure proper work practices and an on-going mechanical integrity program. This program also insures compliance with 29 CFR 1910.38, 1910.120, 1910.1200, 40 CFR, Part 68, Part 112, and Part 260. Wabash Alloys has developed and implemented written operating procedures to provide clear instructions for safely conducting activities involved in the processes at each operation by our employees, consistent with the process safety information and to address steps for each handling phase, limitations, safety and health considerations, and safety systems and their functions. Other written documentation of standard operating procedures as a part of this program is included in the following documents: Mechanical Integrity Study of Process Equipment Preventive Maintenance Program Written Emergency Response Plan Employee Emergency Action and Evacuation Plan Job Safe ty Analysis Training Each employee involved in operations within the process where Chlorine is received, processed, or used at the facility has been trained in an overview of the process and in the operating procedures as outlined by 29 CFR 1910.119. Refresher training is provided no less than every three years and more often if necessary. Mechanical Integrity Also, each maintenance person who has responsibilities to perform maintenance on the process components receives training on an as needed basis, but no less than every three years. Emergency Response A team of individuals has been trained and is equipped as a HAZMAT team. The team is equipped with Self-Contained Breathing Apparatuses, Level A suits and monitoring equipment to respond in an offensive manner. A record of the training, which contains the identity of the employee, the date of training, and the means, used to verify that the employee understood the training is completed and maintained. Contractors. Designated p ersonnel have specific responsibilities related to the use of contractors who perform maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to areas where the Chlorine is received, stored, or processed in the facility. These responsibilities include specific requirements in selection of contractors regarding the contractor's safety performance and programs; the provision of information concerning the emergency action plans related to the process; development and implementation of safe work practices regarding the control of entrance and exit of contract employers and contract employees in the process areas, periodic evaluation of the contractor related to safety management at the process; maintenance of certain records related to contractor employee injury and illness; development of written procedures for any new processes, and provision of training to employees. Five-year accident history In the past five years, there has been one incident involvin g the release of chlorine (July 28, 1997). This involved the breakage of a copper tube (line) going into a molten metal pump into a furnace. The duration of the release was for a few seconds with the estimated quantity to be less than a pound. One individual was provided medical treatment for upper respiratory tract irritation with hospitalization for one night. The individual revived without any sequelae. No incidences of chlorine release have occurred at the facility that resulted in deaths or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency response program Due to the receipt, usage, and storage of Chlorine in large quantities, Wabash Alloys takes a proactive approach to the protection of its employees, the public, and the environment. In consideration of the hazardous effects that Chlorine may have on human health and the environment the following outlines the facilities prevention and emergency response plans: Written Emergency Response Plan Offensively Trained & Equipped Emergency Action Team in accordance with 29 CFR 1910.120 Development of a Written Implementation Plan of Action Conduction of Hazard Analysis on routine and periodic basis Development of and documentation of safe work practices Initial and periodic training of employees Conduction of pre-startup safety reviews Conduction of Compliance Audits Conduction of incident investigations Contractor Program Safety Program Hot Work Permit Program Process Safety Management & Chemical Accidental Release Prevention Committee Mechanical Integrity & Preventive Maintenance Program Determination and planning for Worst-Case and Alternative Case Release Scenarios Continual evaluation for methods to improve facility safety - Safety Committee Meetings with the Local Emergency Planning Committee and Fir Department Planned changes to improve safety In an attempt to insure a cont inual improvement in the facility worker protection and release prevention programs, training concerning this safety and environmental program and others is conducted for an average of 24 hours per year. This training requires the attendance by all personnel whose job may have any relationship to the chlorine operations. |