State Metal Industries - Executive Summary

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Two chlorine evaporation systems are fed liquid chlorine from 2000 pound cylinders and each system feeds gaseous chlorine to an aluminum furnace.  The gaseous chlorine is injected into a molten aluminum pump and reacts with magnesium impurity to refine the aluminum.  The Chlorine Building can house up to 8 one-ton chlorine cylinders at a time.  In case of a chlorine leak the building can be manually vented to the plant air pollution control system for dilution, some neutralization with ammonia, and dispersal from a stack. The first system has operated safely for over 10 years and the second system over 4 years.  Both systems have operated without any  offsite consequences.  The facility has an emergency response team on site and drills regularly. 
Accidental Release Prevention and Emergency Response Policies: 
State Metal Industies policy is to comply with all applicable rules and regulations including OSHA Process Safety Management, EPA Accidental Risk Prevention and New Jersey Toxic C 
atastrophe Prevention Act.  The chlorine system and procedures are based on recommendations of the Chlorine Institute. 
Worst-Case Release Scenario and Alternative Release Scenario: 
The RMP*Comp dispersion analysis software provided by EPA was used to model both worst case and alternative case releases.  The worst case release scenario was modelled as the release of a full ton cylinder of chlorine in ten minutes in the open with no mitigation.  This scenario had an offsite consequence radius of 1.3 miles.  Standard Operating Procedures, Training and Mechanical Integrity procedures are used to minimize risk.  Cylinder unloading is scheduled for night hours to minimize any traffic problems and to accomplish the transfer to the Chlorine Building as quickly and safely as possible.  The alternative release scenario involves the complete vaporization of a ton cylinder connected to an evaporator inside the Chlorine Building.  The building provides passive mitigation that reduces the offsite c 
onsequences to only 0.2 miles.  Further active mitigation venting the Chlorine Building through the baghouse and stack will result in no offsite consequences. 
General Accidental Release Prevention Program and Chemical-Specific Prevention Steps: 
In addition to the requirements of EPA (40CFR68) and OSHA PSM (29CFR1910.119), State Metal Industries has been covered by New Jersey's Toxic Catastrophe Prevention Act regulations(Title 7 NJAC Chapter 31) for over ten years.  All systems and procedures are based on Chlorine Institute recommendations to insure safe operation.  Chlorine sensors and an alarm system with both local alarms and a connection to ADT warn of a chlorine leak in the Chlorine Building to facilitate rapid emergency response.  An annual audit of all aspects of the RMP program, including preventive maintenance and emergency response, is conducted. 
Five-Year Accident History: 
There have been no accidents involving chlorine in the last five years and no offsite consequences ev 
Emergency Response Program: 
The Emergency Response Plan includes annual refresher training and a full-scale drill, including suiting up responders with SCBA to use Chlorine Kit B and/or other techniques to stop a simulated leak.  The site coordinators are trained to contact the Camden City LEPC, NJ DEP and the National Response Center as appropriate. 
Planned Changes to Improve Safety: 
The Risk Management Program at State Metal Industries is a mature program that has undergone more than 10 years of continual improvements.  No major planned changes are presently contemplated.  Management remains open to any practical equipment or procedures that will improve safety.
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