Wise Alloys LLC - Alabama Reclamation Plant - Executive Summary |
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Wise Alloys LLC owns and operates an aluminum reclamation facility in Muscle Shoals, AL. This facility is known as the Alabama Reclamation Plant and is located at 1009 Ford Road. The reclamation facility consists of a plant which manufactures molten aluminum or aluminum ingot.. Reynolds Metals Company built the facility in 1969 and it was purchased by Wise Alloys LLC in April 1999. This facility is one of the largest in the world of its kind and has processes including aluminum delaquering, melting, casting, and storage. The facility employs 142 full-time employees. 1. Accidental Release Prevention and Emergency Response Polices at the Stationary Source (68.155(a)) Wise Alloys LLC is committed to operating the Alabama Reclamation Plant in a manner that is safe for workers, the public and the environment. It is our policy to adhere to applicable Federal, State and local rules and regulations, industry standards and best practices. As part of this commitment, the Alabama Reclamation Pl ant has established a system to help ensure safe operation of the processes of this facility which includes the prevention of accidental releases of hazardous substances. One component of this system is a risk management program (RMP) that helps manage the risk at the Alabama Reclamation Plant and complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirement Risk Management Programs (the RMP rule) and OSHA 1910.119. The document is intended to satisfy the RMP plan requirement of the RMP rule and to provide the public with a description of the risk management program at the Alabama Reclamation Plant. The RMP at the Alabama Reclamation Plant consists of the following three elements: 7 A hazard assessment to help understand (a) the potential off-site consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances re gulated by the RMP rule (regulated substances) 7 A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes) 7 An emergency response program to help respond to accidental releases of regulated substances from covered processes Information further describing these elements is provided in this RMP Plan. Although the risk management program at the Alabama Reclamation Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety and environmental program at the Alabama Reclamation Plant. In fact, the Alabama Reclamation Plant has a comprehensive safety and environmental program in place, establishing many levels of safeguards against release of a hazardous substance as well as injuries and damage from such a release. Wise Alloys LLC's policy on the use of hazardous substances: Before using a hazardous substance at the A labama Reclamation Plant, less hazardous alternatives are always considered. When a hazardous substance is used at the Alabama Reclamation Plant, Wise Alloys reviews the potential for an accidental release of this substance which could adversely affect plant workers, the public and the environment, and takes steps to prevent any such effects. This is accomplished through the facility's Management of Change (MOC) and Process Hazard Review (PHR) procedures which are followed for all new installations or modifications of existing processes. Wise Alloys strives to prevent accidental releases of the hazardous substances used at the facility. Wise Alloys implements reasonable controls to prevent foreseeable releases of hazardous substances. When a hazardous substance is used at the Alabama Reclamation Plant, the equipment is carefully designed, installed, operated and maintained to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in th e design, construction and operation of equipment. Each project is thoroughly reviewed before approval. In addition, Wise Alloys requires the documentation of standard operating procedures and training of affected employees with regard to these procedures as part of the MOC procedure. The Alabama Reclamation Plant Mechanical Integrity program provides an ongoing process to verify the mechanical integrity of the equipment, piping and instruments to prevent the release of hazardous substances. The Alabama Reclamation Plant's goal is to minimize impacts from an accidental release: In the event of an accidental release, the Alabama Reclamation Plant controls and contains the release in a manner that will be safe for workers and will prevent impact to the public and the environment. Wise Alloys utilizes emergency response plans as required by government regulation. Wise Alloys trains its workers to respond to an accidental release, reducing the consequences of a release if it occurs. The A labama Reclamation Plant also has designated Gate 5 (at the Wise Alloys Plant) as a Special Situations Center to assist in all emergencies. In addition, Wise Alloys works with the local fire department and with the local emergency planning committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur. Wise Alloys has assisted the LEPC in writing and implementing the Colbert County Community Awareness and Emergency Plan (CAER). The Alabama Reclamation Plant emergency response plan has been developed to meet the emergency planning, response and notification requirements of the Federal, OSHA, and EPA regulations. This plan outlines the responsibilities and actions required to control an emergency that limits itself to within the Alabama Reclamation Plant. If the emergency extends beyond the plant boundaries and affects the surrounding communities. The Colbert County Community Awareness and Emergency Plan (CAER) is initiated by a call to 911 and a statement of the type of emergency. Wise Alloys is an active participant in the community: Wise Alloys is an active participant in plant and community programs which promote education, safety and environmental awareness. The facility conducts monthly safety meetings in which employee participation at all levels is requested in designing, implementing and maintaining safety programs. Safety is a primary concern in our facility. In order to effectively implement these policies. Wise Alloys established a management system headed by the Environmental Services Department and the Safety Departments to oversee safety and environmental-related activities. 2. The Stationary Source and Regulated Substances Handled (68.155(b) ): The Alabama Reclamation Plant handles several regulated substances that are covered by the RMP rule, as shown in the following list of RMP-covered Program 3 processes at the plant. Regulated Substance-Chlorine, Casting Area Mix Station, Process Quantity- 8,000 lb., RMP Thresh old-2,500 lb. Chlorine is used in the Casting Area as part of a gas mixture which is used to flux molten aluminum and drive off any metal impurities. The chlorine is mixed with other gases at a chlorine mix station. One ton containers of liquid chlorine are utilized at this mix station. 3. The Worst-Case Release Scenario(s) and the Alternate Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario (68.155) ): The Alabama Reclamation Plant performed off-site consequence analysis to estimate the potential for accidental release of a regulated substance to affect the public or the environment. The RMP rule requires the off-site consequence analysis to evaluate a "worst-case release scenario" and an "alternate release scenario." In reality, however, Wise Alloys does not expect a worst-case release scenario to ever occur. The alternative release scenarios are developed to help the LEPC improve the community emergency response plan. The RMP*COMP system was used to calculate a distance to the toxic endpoint. The meteorological data used for the modeling was the EPA default for the worst case and EPA suggested values for the alternative release scenario. The EPA recommended Landview program was utilized to estimate the number of people living within the circle of any release scenarios. USGS maps were utilized to identify the public and environmental receptors located within any release circle. The following information summarizes the off-site consequence analysis performed by the Alabama Reclamation Plant: 3.1 Toxic Substances - Chlorine The "worst-case release scenario" for chlorine is a failure 1 one-ton chlorine containers at the Casting-Mix Station which would release 2,000 pounds of liquid chlorine in a 10-minute period as mandated by EPA. The worst-case release scenario was evaluated using RMP*COMP. Under the EPA default worst weather conditions, the chlorine gas cloud would travel a dista nce of 0.9 miles before the concentration of chlorine was reduced to below 3ppm (which is the 'endpoint' Emergency Response Planning Guideline value established in the RMP rule). The U.S. Census indicates that 130 people live within this distance from the Mix Station spot; several public receptors are also located within this distance. No environmental receptors are located within this distance. The "alternative - release scenario" is the failure of a connecting hose connected from one 1-ton container of chlorine to the chlorine feed header pipe releasing 500 lbs of chlorine in a 10-minute period. The RMP*COMP, was used for alternative release scenarios to determine the off-site consequences. Assuming a wind-speed of 1.5 meters/sec, an F stability class and rural topography, the chlorine cloud would travel 0.3 miles before reaching a chlorine concentration of below 3ppm (which is the endpoint Emergency Response Planning Guideline value established in the RMP rule). No public recep tors or environmental receptors are located within this distance. 4. The General Accidental Release Prevention Program and the Specific Prevention Steps (68.155) Beginning in 1994, the Alabama Reclamation Plant initiated this prevention program to comply with the 14 elements of the OSHA Process Safety Management (PSM) prevention program. In 1996, the EPA RMP rule established two levels of prevention requirements: Program 3 is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment outside the Alabama Reclamation Plant fenceline; The following sections briefly describe the elements of the Alabama Reclamation Plant's Program 3 prevention program that addresses EPA's RMP rule prevention program requirements. 4.1 Program 3 Prevention Program The Alabama Reclamation Plant's Program 3 prevention program consists of the following twelve elements: 4.1.1 Process Safety Information The Alabama Reclamation Plant maintains technica l documents which are used to help ensure safe operation of the plant processes. These documents address (1) physical properties of hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant, and (3) design basis and configuration of the equipment of the plant. Wise Alloys ensures that this process safety information is available to all employees. Material safety data sheets (MSDSs) document the physical properties of the hazardous materials handled at the Alabama Reclamation Plant, including regulated substances in covered processes. The information available for each hazardous substance typically includes: 7 Toxicity information and permissible exposure limits 7 Physical data (e.g., boiling point, melting point, flash point) 7 Reactivity and corrosivity data 7 Thermal and chemical stability data 7 Hazards of mixing substances in the process MSDSs for hazardous substances handled in each process are available from the plant's Safety Depar tment. Copies of the MSDSs for the hazardous substances within each operating area of the plant are maintained in that area's control room (where possible) so that employees have ready reference to this information. In addition, key MSDSs are provided to the LEPC upon request for use in helping formulate emergency response plans. The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process. The available information includes: 7 Operating parameters 7 Process flow diagrams 7 Process chemistry 7 Maximum intended inventories 7 Safe upper and lower limits for parameters such as temperature, pressure, and flow 7 Design basis and configuration of equipment 7 Piping and instrumentation diagrams, including materials of construction 7 Electrical classification 7 Safety systems 7 Applicable design codes and standards 7 Design basis for relief and ventilation systems Operating manuals contain the process chemi stry, overview of the process operations, process variables with consequences of deviations, equipment and instrument descriptions, troubleshooting guidelines, start-up and shutdown procedures and equipment operating procedures. These documents are used to train (1) train employees, (2) perform process hazards analyses and (3) help maintain the equipment. 4.1.2 Process Hazard Analysis The Alabama Reclamation Plant performs and updates, within every 5 years as required by OSHA, process hazard analyses of the covered process to identify process hazards and generate recommendations that might improve the safe operation of the process. A team composed of personnel with engineering and process operating experience and a leader with process hazard analysis experience is assembled to analyze the hazards of the process. The plant primarily uses the "HAZOP" technique to perform this analysis. The team prepares a written report describing the results of the analysis, including a list of recomm endations. Responsibility to resolve the recommendations is assigned to plant personnel and, when appropriate, changes to enhance the safety of the process are implemented. 4.1.3 Operating Procedures Alabama Reclamation Plant process engineers, technicians and team leaders work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. The operating procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include: 7 Steps for safely conducting activities 7 Applicable process safety information, such as safe operating limits and consequences of process deviations 7 Safety and health considerations, such as chemical hazards, personal protective equipment requirements and actions to take if exposure to a hazardous substance occurs Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown and temporary operations. The operating procedures are used both to help in operating the plant's processes and as a training guide. 4.1.4 Training The Alabama Reclamation Plant trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher courses that covers (1) a general overview of the process, (2) the properties and hazards of the substances in the process, (3) a detailed review of the process operating procedures and safe work practices. Oral reviews and written tests are used to verify that an employee understands the training material before the employee can resume work in the process. The employees are consulted annually at safety meetings to evaluate the effectiveness and frequency of the training. Recommendations from the employees are revi ewed and changes to the training program are implemented as appropriate. 4.1.5 Mechanical Integrity The Alabama Reclamation Plant maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public or the environment. The mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes. The mechanical integrity program includes: 7 Specifications for inspection and testing of process equipment 7 Specifications for replacement parts and equipment 7 Procedures for inspecting, testing and maintaining process equipment 7 Procedures for safe work practices such as Lockout-Tagout; Hot Work; Confined Space Entry; and Line Breaking 7 Training of maintenance personnel 7 Documentation of maintenance activities. 4.1.6 Management of Change The Alabama Reclamation Plant management of change (MOC) program evaluates and approves all proposed changes to chemicals, equipment and procedures for a covered process to help ensure that the change does not negatively effect safe operations. Process changes that are determined to be a replacement in kind (e.g. replacing a valve with an identical valve) are allowed without completing a management of change. All other changes must be confirmed through the management of change program to ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. 4.1.7 Pre-Startup Review The Alabama Reclamation Plant performs a safety review through our MOC procedures of a new or modified process before the process is placed into service to help ensure that the process has been prepared to o perate safely. This review confirms that: 7 Construction and equipment are in accordance with design specifications 7 Adequate safety, operating, maintenance and emergency procedures are in place 7 Employee training has been completed 7 For a covered process a PHA has been performed if the process is new or management of change requirements have been completed if an existing process has been modified The management of change pre-startup safety review check list will be completed during the MOC walk through for new processes, major modifications and/or start up of existing processes that have been shut down for more than 6 months. 4.1.8 Compliance Audit The Alabama Reclamation Plant audits covered processes every 3 years to be certain that the prevention program is effectively addressing the safety issues of operations at the plant. The plant assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and this team evaluates whether the preventio n program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to ensure safe operation of the process. The results of the audit are documented, recommendations are resolved and appropriate enhancements to the prevention program are implemented. 4.1.9 Incident Investigation The Alabama Reclamation Plant investigates accidents, including near misses, that could reasonably have resulted in a serious injury to personnel, the public or the environment so that similar incidents can be prevented in the future. The plant trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved and appropriate process enhancements are implemented. The Alabama Reclamation Plant has a formal program including training for incident investigations and the report generation. 4.1.10 Employee Participation The Alabama Reclamation Plant developed a written employee participation program for all covered processes to help ensure that the safety concerns of the plant's workers are addressed. The plant encourages active participation of personnel in the prevention program activities of all processes at the plant. Employees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHAs, MOCs and operating procedures. 4.1.11 Hot Work Permits The Alabama Reclamation Plant established a hot work permit program to control spark or flame-producing activities that could result in fires or explosions in covered processes in the plant. The plant reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252 (a) and created a Hot Work Permit Form to comply with these requirements. Personnel who are to perform hot work are required to fill out the Hot Work Permit Form. The Area Team Leader reviews the form before the w ork can begin. Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation. 4.1.12 Contractors The Alabama Reclamation Plant established a program to help ensure that contractor activities are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that the plant only hires contractors who can safely perform the desired job tasks. The plant explains to the contract supervisors the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant's emergency response procedures. The plant requires that the contractor supervisors train each of their employees who will work at the plant before that worker begins work at the plant site. The plant periodically reviews contractors' training documents to help ensure that safe work practices are followed. 5. Five-Year Accident History (68.155) The Alabama Reclamation Plant can proudly report zero for th e five-year accident history. The plant has not experienced any accidents that fall into the EPA's RMP requirements for a five-year history. 6. The Emergency Response Program (68.155(f) ). The Alabama Reclamation Plant has established a written emergency response plan and maintains an emergency response team trained in these emergency response procedures. All plant personnel are trained in evacuation procedures. The written emergency response plan complies with the following federal and state contingency plan regulations: OSHA 29 CFR 1910.38(a) - Employee Emergency Action Plans OSHA 29 CFR 1910.119(n) - Process Safety Management of Highly Hazardous Chemicals OSHA 29 CFR 1910.120(p) and (q) - Hazardous Waste Operations and Emergency Response (HazWOPER) OSHA 29 CFR 1910, Subpart L - Fire Protection EPA 40 CFR 302.6 - Notification Requirements EPA 40 CFR 355.30 - Facility Coordinator and Emergency Response Coordinator EPA 40 CFR 355.40 - Emergency Planning and Release Notifications EPA 40 CFR 112 - Spill Prevention, Control and Countermeasures Plan EPA 40 CFR 68 - Risk Management Programs for Chemical Accident Release Prevention The Alabama Reclamation Plant has trained employees available 24 hours per day to respond to in-plant chemical emergencies. These employees can respond to chemical emergencies inside the plant fenced area only. The plant maintains certain tools and materials to help contain spill's etc. until a certified contractor can come in and handle the majority of such work. The facility is a member of the Colbert County LEPC committee, whose membership includes: 7 City of Muscle Shoals 7 Muscle Shoals Fire Department 7 Muscle Shoals City Police 7 Colbert County Emergency Services and Emerg ency Preparedness Agency 7 Colbert County Emergency Management Agency 7 Alabama State Police 7 State Division of Public Health 7 Department of Natural Resources and Environmental Control 7 Alabama State Fire School 7 Colbert County Emergency Medical Services Council 7 Industrial Representatives from the Muscle Shoals City Industrial Complex The LEPC committee meets every two months and conduct annual exercises of the emergency response plan, the Alabama Reclamation Plant's emergency response plan has been communicated to the Colbert County Emergency Services and Emergency Preparedness Agency. 7. Planned Changes to Improve Safety (68.155(g) ). The Alabama Reclamation Plant constantly tries to improve the safety of the processes through annual reviews of our plant procedures, near misses and incident investigation programs, and a program soliciting safety and environmental suggestions from the plant employees. 8. Certification General Certification. To the best of my knowledge, inf ormation, and belief formed after reasonable inquiry, the information submitted in this RMP Plan is true, accurate, and complete. Signature: George P. Stoe* Date Signed: June 17, 1999 Title: President Wise Alloys LLC * The Certification with original signature is presented in the attached cover letter. |