Wabash Alloys, LLC - 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 willfu l 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 review of ea ch 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 employees, consis tent 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 shutdown; and c. Safe work practices applicable to the employ ee'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 provides employment for 89 workers in Cleveland, Ohio. This facil ity 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. Operation Description Chlorine 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 three 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. 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. 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 asses sment. 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. The worst case scenario for chlorine was decided as the complete rapid loss of 110,000 pounds of chlorine at a rate of 11,000 lbs/minute. The fo llowing information was determined using the EPA's OCA Guidance reference tables or equations and PHAST model-DNV Technical model, based on the stability class F , 4.5 mph wind speed, and the level of 3ppm for chlorine. This resulted in a release rate of 110,000 lbs/min, and an end point of >25 miles from the spill point. The alternate case scenario for chlorine was decided as the loss of chlorine resulting from a release through a 1 inch transfer hose line break. The following information was determined using the EPA's OCA Guidance reference tables or equations and PHAST model-DNV Technical model, based on the stability class D, 4.5 mph wind speed, and the level of 3ppm for chlorine. This resulted in a release rate of 1,962 lbs/min, and an end point of 1.78 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 Safety Analysis Training Each employee involved in operations within the process where Chlorine is received, processed, or used at t he 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 personnel have specific responsibilities related to the use of contractors who perform maintenance or repair, turnaround, major re novation, 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 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 Accident al 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 continual 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 twenty-four hours per year. This training requires the attendance by all personnel whose job may have any relationship to the chlorine operations. |