Alchem Aluminum Shelbyville Inc. - Executive Summary |
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Alchem Aluminum Shelbyville Inc. Risk Management Plan Executive Summary The accidental release prevention and emergency response policies at the stationary source. Alchem Aluminum Shelbyville 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 Shelbyville Fire Department and the Bedford County Local Emergency Planning Committee (LEPC). The stationary source and regulated substances handled. Alchem manufactures aluminum ingots 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 t he alternative release scenario, including administrative controls and mitigation measure 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 the chlorine operation within a building to prevent releases to the environment. Alchem also maintains active mitigation methods in the form of a scrubber which can be used to remove chlorine from the room in the event of a release. 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. T he alternate release scenario is assumed to be the failure of a one-ton chlorine cylinder within the enclosed room. Releases within the chlorine room are controlled by the scrubber, so the release of chlorine to the environment is minimal. According to calculations performed using EPA guidance, the distance to the toxic endpoint is 0.1 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 not had an accident in the past five years that resulted to an 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 Shelbyville Fire Department and the Bedford County 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. |