M.C. Aluminum America, Inc. - Executive Summary

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M.C Aluminum America and its management are committed to maintaining the safest working environment possible.  It is the companies' goal to maintain a safe and productive operation for the benefit of the employees and the community.  This is accomplished by safety committees, employee suggestions, monitoring devices, established safety procedures and guidelines and chemical specific training.  If management becomes aware of an issue that jeopardizes safety, plans will be implemented to correct this problem in a timely manner. 
Facility Description 
M.C. Aluminum America is a Secondary Aluminum Smelter S.I.C. 3341.  Our process involves the receiving of many types of aluminum scrap.  Much of the scrap we receive is aluminum turning chips that contain oils and cutting fluids.  The turning chips are dried in any of 2 rotary kiln dryers.  The dried turning chips along with other aluminum scrap such as wheels, radiators, window frames and various other aluminum scraps are melted in any of  
3 reverberatory furnaces.  After a furnace is full, samples are taken to insure that all elements are within customer required specifications.   
On 1 of the 3 furnaces we will inject chlorine to reduce the magnesium content as requested by some of our customers.  We inject chlorine at a rate of 100 lb an hour.  On average we add a total of 200 lb of chlorine to each lot we produce.  It takes approximately 20 hours to produce I lot and we produce an average of 10 lots per month that require the use of chlorine.  This equals an average of 2000 lb of chlorine used per month and the total time that chlorine is in use averages out to 20 hours a month in 2 hour increments.  To accommodate this usage we maintain approximately 3000 lb of chlorine on site.  The chlorine is stored in 2, 1 ton containers in an enclosed cement block building behind the main production building. 
Worst Case Release and Alternative Release Scenarios 
A worst case release scenario was conducted using RMP Comp.  A wo 
rst case release would mean a release of 2000 lb of chlorine in 10 minutes at a release rate of 200 lb/ min.  We keep our chlorine inside a building that would reduce the release rate to 110 lb/ min.  This scenario would have a toxic to end point of 0.9 miles.  Within this 0.9 mile there are approximately 50 homes, 20 businesss and a day care center. 
There are only three ways that a worse case release could happen; 
1.  Something knocking a hole in the container. We have our chlorine in a building that nothing can enter to put a hole in the container.  The building is also located in a place away from all operations. 
2.  The ton container has a fusible plug that ruptures when the temperature of the plug reaches 158 ~ 165  F.  The reason for this is to prevent excessive pressure from building up inside the container.  To protect the containers from reaching these temperatures the building is located away from any heat sources and  because the containers are inside a building they are 
not exposed to the heat of the sun.  the building also has venting to prevent heat build up inside the building. 
3.  The third possibility of a worst case release comes from a container valve breaking off.  Each ton container has a valve that is attached by the supplier.  The valve is where the user makes the connection to the process.  Because of material construction, supplier maintenance and thorough operator training  and the fact that it would take a tremendous amount of force to break the valve it is highly unlikely that this situation would occur. 
General Accidental Release 
General accidents are a possibility, however by following the guidance of OSHA PSM and the procedures and policies implemented through the PSM such as our emergency shut off system, established operating procedures and managerial type controls we believe that  even a general type release is highly unlikely.  The following, lists our most important factors for this belief; 
7 Only trained and competent ope 
rators are authorized to operate the chlorine process or even enter the chlorine building 
7 Each time a new container of chlorine arrives and is connected to the system all new seals and gaskets are used  
7 Each time prior to using chlorine, a leak test is conducted of the system 
7 After using chlorine each time the system is completely emptied so there is not any remaining chlorine in the system other that the container 
7 A chlorine emergency shutoff system is used at the valve of the container.  This shutoff system can be activated at any station throughout the process by pressing an emergency stop button.  The system will also automatically close the container if our monitoring system detects a leak.  This shutoff system has a battery backup. 
7 If the system is activated, the flow of chlorine is stopped within 1.5 seconds 
7 Once the system is activated, any chlorine remaining in the system empties into our furnace were it is of no danger of any negative effect  
7 Our chlorine system 
is not used during weather which may impact the safety of our operation, i.e.  thunderstorms or something that would terminate the electricity. 
Five year accident history 
We are pleased to announce that we have not had a release since we began using chlorine 4 years ago. 
Emergency Response Program 
We have an emergency response program that that has been established under the guidelines set by OSHA and enhanced using the guidelines set forth by RMP.  The program addresss the recognition of a chlorine release that warrants the activation of our emergency response plan.  The response plan explains the safe and swift removal of all non-essential personnel to a safe place of refuge were all can be accounted for. 
The LEPC is our liaison for the hospital, police, sheriff's department and is also the agency who would actually evacuate the effected community in the event of an emergency.  The police will provide security, the fire department will provide support services such as deconta 
mination, medical support, medical transportation.  The LEPC and the fire department are notified of any changes at our facility that might in any way impact the outcome of an emergency response action at our facility.  
The members of our emergency response team are chosen because of their thorough knowledge of the chlorine system which is obtained from the position that each member holds at the company. 
Response training includes;  chlorine system operations and limitations, recognizing the hazards of chlorine and how to use the proper PPE and the limitations of the PPE  when handling chlorine in an emergency operation, proper procedures and equipment to contain and stop a chlorine release, how to administer first aid procedures to those exposed to chlorine and perform the proper decontamination procedures, members will also know what is not compatible with chlorine. 
Training will be conducted at least annually and will include classroom and hands on type training using all equipme 
nt that would be used at an actual chlorine release response.  At the completion of all training a critique is done as would in an actual emergency. 
Planned changes 
We are always looking for ways to improve the safety of our operation and will continue to follow and build upon the existing practices and policies already in place.
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