Wabash Alloys, L.L.C. - Executive Summary |
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The accidental release prevention and emergency response policies at our facility: Wabash Alloys, L.L.C. (Wabash) is committed to maintaining a safe work environment for our employees, contractors, visitors, and surrounding public. Due to the necessity of a timely response associated with a chlorine release, Wabash has committed the resources necessary to respond offensively at each of our facilities. Wabash has trained HazMat Teams that are able to assess and mitigate a chlorine release in minutes. In addition, our facilities regularly meet with outside responders, local fire departments, and local emergency planning committees in order to establish emergency response procedures necessary to protect our surrounding public and the environment. Our facility and the regulated substances handled: The Wabash facility in Tipton, Indiana produces recycled secondary specification aluminum alloys. The Wabash facility has a Program 3 covered process due to the onsite storage and use of chlorine. Chlorine is used at the facility to remove magnesium from molten aluminum. The worst-case release scenario and the alternative release scenario: One worst-case release scenario was modeled for the chlorine covered process using USEPA's offsite consequence analysis guidance document, "Risk Management Program Guidance for Wastewater Treatment Plants", dated May 2000. USEPA requires that the entire contents of the largest vessel be used for the worst-case release scenario. This scenario is highly unlikely and has never occurred at our facility. There were no administrative controls or passive mitigation systems that would reduce the quantity released or limit the release rate taken into consideration when modeling this scenario. The worst-case release scenario for chlorine potentially has an offsite impact. One alternative release scenario was modeled for the chlorine covered process using the same guidance document as stated above. Per USEPA guidance, the alternative r elease scenario is intended to be a more reasonable or likely event than the worst-case release scenario, however, it is still very conservative in nature. The alternative release scenario modeled was a complete one-inch line or hose break with flow limited by the 5/16 inch bore on the cylinder valve. The event modeled has never occurred at our facility. This event was chosen based on the impact distance compared to other postulated scenarios that would have a much smaller impact distance or none at all. There were no active or passive mitigation measures taken into consideration in the alternative release analysis. The alternative release analysis does have the potential for offsite impacts. The general accidental release prevention program and chemical-specific prevention steps: This facility is covered by both USEPA's Risk Management Program rule, as well as, OSHA's Process Safety Management Rule for the chlorine covered process. This facility implements one combined Process Safety and Risk Management Program. This program consists of a written management system that complies with both USEPA's and OSHA's requirements. The backbone of the program is the Management of Change Procedure. This procedure enables the facility to initiate and complete process changes associated with the chlorine system while maintaining the Process Safety and Risk Management Program requirements at the facility. Both the worst-case and alternative release scenarios were modeled based on equipment failure, therefore the mechanical integrity element of the program is key in preventing releases from the chlorine process. This facility utilizes a computerized maintenance management system (CMMS) to implement the preventative maintenance, testing and inspection of the chlorine system. The CMMS supports the routine preventative maintenance program, which in combination with Wabash's employee and contractor training programs provides ongoing assurance that the chlorine system is operated in a safe manner. The five year accident history: This facility has had four accidental releases of chlorine in the past five years, the largest release was 7 pounds. No one offsite was injured, nor were any homes or local businesses evacuated. The emergency response program: Our employees are trained and equipped to offensively respond to releases of chlorine. The HazMat Team routinely undergoes training and participates in drills with the local fire department. The plant has coordinated emergency response procedures with the Tipton County Emergency Management Agency. In the event of a release which could result on an offsite impact, theTipton County Emergency Management Agency will be contacted to alert the general public. Planned changes to improve safety: This facility has been making extensive improvements to the chlorine system as a result of the facility's accident history and process hazard analysis recommendations. The chlorine transfer system was physical ly reconstructed to facilitate access by operations, maintenance, and HazMat personnel. The facility has also reduced their onsite chlorine inventory by 50 percent. An expansion tank was installed in the chlorine system to capture any chlorine vented from the pressure relief valves installed on the system. This improvement eliminated the use of caustic soda, allows for recycle of the chlorine, and significantly reduces the chance of an uncontrolled chlorine release. Wabash has also reviewed employee training programs and operating procedures and has made changes as necessary to increase safety awareness among our employees. The facility will continue to make improvements as identified through our employee participation and internal auditing programs. |