Wabash Alloys, L.L.C - Executive Summary

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       Wabash Alloys provides employment for 170 workers in Syracuse, New York.  This facility is one of eight other Aluminum recycling plants in the United States owned by Connell Ltd.  As a manufacturer of aluminum ingots its products are sold globally under its corporate company, Connell, Ltd, 1 International Place, Fort Hill Square, Boston Massachusetts. 
Site Description: 
   The Wabash Alloys facility is located at 6223 Thompson Road, Syracuse, New York.  The site is approximately 20 acres in size.  The site is serviced with electricity, water, natural gas, and sewer lines.   
   The surrounding vicinity consists generally of residential structures.   
A 90-ton chlorine tanker car is stationed on the north side of the property.  Access to the property is to the east side with the employee parking lot to the southwest.  The entire site is fenced. 
Operation Description 
   The site process involves the sorting, grading, processing (removing organics via a rotary kiln), melting, and alloying of met 
als 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 fo 
r shipment as a molten material.  Particulate emissions from the crusher are controlled with a baghouse.  The emissions from the dryer are treated first using a secondary combustion unit, and then with a baghouse.  Emissions from melters, ingot and sow molding processes, and dross cooling operations are controlled using a baghouse. 
Chlorine is receives in a 90-ton tanker car via Conrail on the Carrier Spur.  The tanker comes in on the Carrier Spur and must be pulled onto a neighbor's property - Oberdorfer/Citation.  Wabash Alloys has a formal agreement with them.  Delivery is made once every month.      Wabash Maintenance personnel connect the tanker to a transfer station.  Assess to the connection area is by stairs to a platform.  The connection is made by flexible piping.  The tanker is padded with nitrogen continuously during the transfer. 
The chlorine is transferred from the tanker car through pipes over the driveway going from North to the South side to a vaporizer room.  A new vapor 
izer was installed in January 1999.  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.  Each inlet line has a pressure sensitive valve which automatically closes if pressure on the gas side decreases.  Also, the nitrogen line is automatically opened to purge the line.  Close to the needle valve is the tubing connection that connects to a carbon lance, which feeds the gas to the pump housing.  Here the chlorine reacts with magnesium and aluminum to demag and clean the aluminum alloy. 
Operation - Connecting 90 ton tanker 
   (1)  Receipt of Chlorine 
    Wabash Alloys receives Chlorine by rail.  Wabash personnel complete the connecting of the tanker to the transfer lines.  There is only one person present during transfer.   
Operation - Filling of Vaporizer 
    (2)   Filling Vaporizer 
   A manual value is opened allowing flow of li 
quid chlorine to the vaporizer.  An electric water heated in the vaporizer room heats the vaporizer.  A 1" pipe leads to the vaporizer at approximately 50 pounds pressure regulated by an inline regulator.  The flow continues from the vaporizer through a 1" pipe to the furnaces.  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 one main and four regulators from the chlorine control room.  Regulated to 50 psi the chlorine gas travels to the furnaces where the flowrate is controlled. 
 There is a warning light to alert passer-byers that a transfer is in progress is used. 
During the transfer the volume is monitored by the amount of weight present.  A gauge in the Office, Building 1 monitors the weight.  The tank car sets on a weight scale.  During transfer, a maintenance person is station at the tanker and in the Office with communication by radio. There are also  
pressure gauges on the outside of the building that are monitored during the transfer. 
   There are concentration monitors to monitor releases of chlorine in the vaporizer room. 
Community Description   
Geography and Weather: 
The city is located in Onondaga County which covers 784 square miles.  The city of Syracuse covers 3,087 square miles.  The terrain is rolling hills and flat plains.  The altitude is between 364 to 681 feet.  There are four seasons with average temperatures of 24 degrees in January, 45 in April, 71 in July and 62 in September.  The annual average snowfall is 112 inches and 36 inches of rainfall.  
   Population and Labor Force 
   The estimated population in 1998 is 155,865 with a labor force in all of Onondaga County of 226,300. 
   In Onondaga County there are 78 elementary Schools, 27 Junior High and 20 High Schools.  
   Syracuse is located at the crossroads of two interstate highway systems east/west I-90, the New York State Thruway, and north/sou 
th I-81. 
   Conrail provides direct rail freight service to a variety of Northeastern markets.  
   Over 270 passenger flights arrive and depart daily from the Syracuse Hancock International Airport. 
Five Year History 
   There have been 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. 
Changes Instituted since the PHA 
   There have been significant mechanical changes or changes in work practices since the conduction of the Process Hazard Analysis - HAZOPs in 1997.  These changes include the deletion of a 30-ton chlorine storage tank between the 90-ton chlorine tanker and the vaporizer room.   Also, a second 90-ton chlorine tanker car is onsite awaiting connection as the first car is being used. 
EPA Emergency Notification Applicability - 40 CFR Part 355 
   Because of quantities more than 1,000 
pounds, the facility is also subject to the reporting requirements outlined by the Environmental Protection Agency's (EPA) standard 40 CFR Part 355.  No incidences of chlorine release have occurred at the facility that required notification under the Reportable Quantities provisions of this standard. 
Regulatory Agency Inspections 
   There are no records that audits by federal, state, or local agencies since the purchase of the facility by Wabash Alloys.  During the past five years, the facility has been visited by the OSHA on October 24, 1995 and on December 11, 1995.  Also, the facility was visity by the Department of Environmental Conservation in 1992..  Health and safety audits are conducted annually by a Wabash Division and the Connell LTD audit team. 
Source Prevention & Emergency Response Approach 
   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.  As  
a part of our manufacturing process Chlorine is used to remove impurities from metal (aluminum).  The maximum intended inventory at the facility is 180 tons. 
   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: 
   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 pl 
anning for Worst-Case and Alternative Case Release Scenarios 
   Continual evaluation for methods to improve facility safety - Safety Committee 
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.  The primary methods used by this facility are a part of the Process Safety Management Program as follows: 
   A.  Written Plan of Action - Process Safety Information. 
   This part of the program is one of the most involved and included the development of a written plan of action regarding the implementation of employee participation in the program.  In accordance with a specific schedule outlined by the standard, as per 29 CFR 1910.119, Wabash Alloys has completed a compilation of written process safety information concerning the process and operations involved with Chlorine of these standards of operating procedures.  For purposes of defining a process covered u 
nder this program, the use of Chlorine in the demagging system has been considered "a process," whereas a production or usage system/function is considered an "operation."   By identifying each functional operation, a team was able to ascertain the potential and develop preparation plans in the case of a release.  This compilation of information is to enable Wabash Alloys and the employees involved in the operations related to Chlorine to identify and understand the hazards posed by these processes.  This process safety information includes information pertaining to the toxicological and physical hazards of the chemical listed. 
   B.  Hazard Analyses/Abatement Schedule. 
   This analysis is the heart of Wabash Alloys ' process safety management or Risk Management release prevention program.  The safety and health staff, engineering and maintenance personnel, and certain operational personnel performed an initial process hazard analysis (hazard evaluation) on each operation within the chlori 
ne process.  The analysis was completed by a team with expertise in the operations.  The team included employees who have experience and knowledge specific to the operations of handling and using the chemicals at each of the process operations.  A system was developed and is maintained to promptly address the team's findings and recommendations by the formation of a PSM/RMP committee.  Also, a written schedule of when these actions were to be completed has been developed, indicating by whom and when.  The hazard analyses will be updated as needed and at least every five (5) years.  With the recent changes to the system a hazard analysis was completed. 
   This analyses involved a review of each operation of the process 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 s 
afe work practices in the format of Job Safety Analysis also in regards to 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. 
   C.  Written Operating Procedure. 
   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  
Employee Emergency Action and Evacuation Plan 
   D.  Training. 
   Process Safety Management 
   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.  Training includes: 
   a.  Emphasis on the specific safety and health hazards; 
   b.  Emergency operations in the case of a release including shutdown; and 
 c. Safe work practices applicable to the employee's job tasks. 
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 an Operations Level HAZMAT team.  The team is equipped to respond in a defensive posture 
.      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. 
   E. Contractors. 
   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 must also complete the Wabash Alloys 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 provide an orientation section to them prior to beginning operations.  This orientation includes 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 is issued a perm 
it by the Maintenance Supervisor to begin work. 
   F  Inspection and Testing. 
   A program has been developed for inspection and testing, correction of deficiencies in equipment, quality assurance, management of changes in the handling of the Chlorine, and procedures to the process, and compliance audits. 
 (1) Mechanical Integrity Program and Assessment - To insure the integrity of the mechanical components of the chlorine process, a professional engineer, in collaboration with Wabash, LLC personnel has developed an On-going Written Mechanical Integrity Program.  This development included a thorough assessment of the process in an attempt to assess the age and present integrity of the component parts.  This assessment included the identification of the component parts for comparison with the manufacturer's specification for maintenance and replacement with "like in-kind components" on a scheduled basis.  In addition, updated Piping and Instrument Diagrams were completed. 
 (2)  Equipment  
Preventive Maintenance and Quality Assurance Program - In an effort to maintain the mechanical integrity and to complete repairs of the equipment in the process, the Maintenance Supervisor oversees a Preventive Maintenance Program.   
 (3)  Management of Change - To insure that proper safety precautions are initiated when change in the operations of the process occurs, the PSM/RMP committee will meet to discuss the planned changes before authorization is given.  The committee will address the following issues prior to approval of a change in the process: 
? The technical basis for the proposed change 
? Impact of the change on employee safety and health, 
? Modifications to operating procedures 
? Necessary time period for the change 
If changes are decided upon, training for personnel in the operation is provided.  Also, any changes to be made are evaluated by performing a Process Hazard Anaysis to identify any hazards and/or actions that must be taken.  Additionally, if a change covered  
by these procedures results in a change in the process safety information, such information will be updated accordingly.   
(4)  Pre-startup safety review - To insure that proper safety precautions are initiated when shut-down and startup of the systems occurs after such things as renovations or major repairs, the PSM/RMP committee will meet to discuss the changes.  The committee will decide if the changes are significant enough to require a change in the process safety information.  If the modification is significant enough to require such a change the committee will confirm the following: 
? Construction and equipment are in accordance with design specifications; 
? Safety, operating, maintenance, and emergency procedures are in place and are adequate 
? A process hazard analysis has been performed for new facilities and recommendations have been resolved or implemented before startup, and modified facilities meet the management of change requirements, and 
? Training of each employee in 
volved in operating the process has been completed. 
 (5)  Compliance Audits - Compliance audits will be conducted with these operating procedures at least every three years to verify that the procedures and practices developed are adequate and are being followed.  The PSM/RMP Committee will certify that they have evaluated compliance with the provisions of the program.  The compliance audit must be conducted by at least one person knowledgeable in the process and a report of the findings will be developed and documented noting any deficiencies that have been corrected.  The written report of the two (2) most recent audit reports will be retained. 
   G.  Incident investigation  
 A crucial part of the Wabash process safety management and release prevention program is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented.  An investigation will be conducted on each incident, which resulted in, or could 
reasonably have resulted in a catastrophic release of the Chlorine in the workplace.  Accident Investigations will be conducted by: 
Plant Manager, Safety Coordinator, Maintenance Supervisor, and Environmental Engineer 
   H.  Emergency planning and response  
 The facility Emergency Response Plan will be maintained according to the provisions of 29 CFR 1910.38 and 29 CFR 1910.120 and EPA guidelines.  A team of individuals has been trained and is equipped as a Operations Level HAZMAT team.   
 Meetings with the Local Emergency Planning Committee Chair and local fire-fighting personnel have taken place to insure proper implementation of emergency response operations should a release occur.  
   I.  Hot Work Permits  
 In accordance with 29 CFR 1910.252, authorization is required from a designated person before cutting or welding is permitted in areas not specifically designed for such purposes.  Based on fire potentials of the plant facility, areas are established for cutting and welding and  
procedures for a permit for other areas.  Prior to welding or cutting in other than established areas, any Wabash Alloys employee or contract employee must acquire a written permit. 
J. Monitoring Devices 
 Air monitoring devices to measure the concentration of Chlorine are located at each of the tanker car platforms and inside the vaporizer room.  If for some reason the concentration of chlorine equals or exceeds 5ppm an audible and visual alarm in the production area engages.  Also, an alarm in the production supervisor's office alerts personnel of the concentration. 
 Actions to be taken should the alarm engage are a part of the facility's written Emergency Response Plan and subjects covered during initial and refresher HAZMAT training.
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