Alchem Aluminum Coldwater Inc. - Executive Summary
Alchem Aluminum Coldwater Inc. Risk Management Plan Executive Summary |
The accidental release prevention and emergency response policies at the stationary source. Alchem Aluminum Coldwater Inc. (Alchem) has implemented a Risk Management Program in accordance with the requirements of the Chemical Accident Prevention Provisions. In the event of an emergency, Alchem has coordinated emergency response efforts with the Coldwater Fire Department and the City of Coldwater's Local Emergency Planning Committee (LEPC).
The stationary source and regulated substances handled. Alchem manufactures aluminum ingots, sows, and molten aluminum in crucibles from various types of recycled aluminum scrap. At the time of this submittal, Alchem is subject to the requirements under the Chemical Accident Prevention Provisions since the facility maintains chlorine on-site in a quantity greater than the 2,500 pound threshold. Chlorine is used at the facility to remove impurities from the recycled aluminum.
The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario. Alchem has administrative controls (operating procedures) which limit the amount of chlorine which can be stored on-site. In addition, Alchem maintains passive mitigation measures by enclosing part of the chlorine operation within buildings. The worst-case release scenario at the Alchem facility is based on the accidental release of the greatest amount held in a single vessel, as specified in the regulation. Therefore, the worst-case release scenario is assumed to be failure of a one-ton chlorine cylinder. According to calculations performed using EPA guidance, the distance to the defined toxic endpoint of 0.0087 mg/L is 1.3 miles for the worst-case release. The alternate release scenario is assumed to be failure of a gasket or transfer hose when connecting the chlorine cylinder to the chlorine system.
According to calculations performed using EPA guidance, the distance to the toxic endpoint is 0.2 miles for the alternate release scenario.
The general accidental release prevention program and chemical-specific prevention steps. To meet the requirements of the Chemical Accident Prevention Provisions, Alchem has implemented the RMP Prevention Program 3 requirements.
The five-year accident history. During the previous five years, Alchem has not had an accidental release of chlorine that caused off-site deaths, injuries, or response or restoration activities at environmental receptors. Additionally, Alchem has had only two accidents related to chlorine in the past five years that resulted in injury to an Alchem employee.
The emergency response program. Alchem has developed an emergency response plan in accordance with the requirements of the Chemical Accident Prevention Provisions. Additionally, Alchem has coordinated emergency response with both the Coldwater Fire Department a
nd the City of Coldwater's LEPC. In the event of an emergency, Alchem will follow the procedures outlined in the emergency response plan.
Planned changes to improve safety. Alchem is currently evaluating and processing recommendations from a recent process hazard analysis performed for the chlorine operation.