Spectro Alloys Corporation - Executive Summary |
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Executive Summary 1. Accidental release prevention and emergency response policies Spectro Alloys Corporation, an aluminum recycling facility, uses chlorine in the smelting process for the purpose of refining our product by removing magnesium and gases from the molten aluminum bath. Chlorine, which is considered hazardous by EPA, exhibits properties which make it necessary to observe certain safety precautions in handling chlorine to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as that of our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle chlorine, the safety devices inherent in the design of this facility, the safe handling procedures that we use and the training of our personnel. Our emergency response program is based upon the Occupational Safety and Health Administra tion's Hazwoper standard pertaining to emergency response (1910.120.) The chlorine emergency response teams are trained on hazard and risk assessment techniques; selection and use of proper personal protective equipment; hazardous materials terms; decontamination procedures; implementation of the emergency response plan; use of field survey instruments and equipment; ability to function within an incident command system; selection and use of specialized chemical personal protective equipment; ability to perform within an incident command system; selection and use of specialized chemical protective clothing; ability to perform containment operations; termination procedures; and a basic understanding of chemical and toxicological terminology and behavior. Chlorine emergency response teams are on site 24 hours a day, seven days a week. The emergency response plan includes procedures for notification of the local fire authority, state and federal emergency response authorities, and affe cted neighbors. 2. The stationary source and regulated substances handled The primary purpose of this facility is to recycle aluminum scrap and supply aluminum stock to the die-cast industry. Chlorine, which is used in the smelting process, is received by truck delivery, in 1 ton cylinders. At Spectro Alloys, five 1 ton cylinders are interconnected using a manifold piping system. The system is contained in a control room. Members of the chlorine emergency response team connect the flexible line connectors from the manifold system to the chlorine valves on the 1 ton cylinders. Once "on line", the chlorine control room is continually montitored by a chlorine gas sensor, which will alert the plant should there be a leak. The chlorine vaporizing system, which enables the chlorine to be sent to the smelting furnaces as a gas, is equipped with high level sensors, high pressure sensors, and chlorine gas sensors at the furnace wells. This process safety equipment is des igned to automatically stop the flow of chlorine from the chlorine control room should any of the safety limits be reached. The maximum total inventory of the regulated substance (chlorine) is 20,000 pounds. 3. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario. Worst-Case Scenario - Failure of a one ton cylinder would release 2,000 pounds of chlorine. It is assumed the entire contents will be released as a vapor, which is heavier than air. The distance to the endpoint of 0.0087 mg/L (3 ppm) is 1.3 miles. Alternative Release Scenario - A flexible line connector becomes disengaged from the one ton cylinder. There is a gas and liquid release. The distance to the endpoint of .0087 mg/L (3 ppm) is 0.3 miles. The vapor released has the potential to extend past the facility's boundary 4. The general accidental release prevention program and the s pecific prevention steps Spectro Alloys complies with the EPA's Accidental Release Preveniton Rule and with all applicable state codes and regulations. Specific prevention steps include compliance with OSHA's Process Safety Management of Highly Hazardous Chemicals, which includes (but is not limited to): process safety information; process hazard analyses; operating procedures; training; and employer responsibilities concerning contractors. The chlorine system and emergency equipment receives scheduled preventive maintenance and inspections. Classroom and hands-on training is utilized to educate affected personnel. 5. Five year accident history Spectro Alloys had an accidental release of chlorine on March 17, 1995. No one off-site was injured and no off-site damage occured; Highway 55 was temporarily closed. Off-site emergency responders were notified. Rosemount Fire Department provided on-scene assistance. 6. The emergency response program Even though proper and safe handling procedures have been established and utilized, there is still the possibility of a chlorine leak. The emergency response plan consists of an emergency coordinator who is responsible for the implementation of the response team on-site and the notification of proper authorities and potentially affected neighbors off-site. The chlorine emergency response team consists of four designated employees from each shift who recevie training to include (but not limited to): the chlorine leak emergency plan, the use and care of emergency equipment, first aid/CPR training and confined space entry and rescue. The chlorine emergency response team training is based on OSHA's 1910.120 Hazwoper standard and principles espoused by The Chlorine Institute. Other employee training related to chlorine and emergency response includes OSHA required training in the areas of emergency action plans, hazard communication, first responder- awareness level, and process safety management standards. Training includes initial and refresher training for all affected personnel. 7. Planned changes to improve safety Spectro Alloys is planning to implement a bulk-package chlorine system in the future. Compared to the use of the ton cylinder manifold system, the bulk chlorine system would minimize handling of the chlorine, which would decrease the potential of an accidental release. |