Wise Alloys LLC - Sheffield Plant - Executive Summary
Executive Summary |
Wise Alloys LLC owns and operates an aluminum processing facility in Sheffield, Alabama. This facility is known as the Sheffield Plant and is located at 501 West 20th Avenue. The aluminum processing facility consists of a plant which manufactures bare and coated aluminum coil. Reynolds Metals Company operated the facility from the early 1950's until 1999. It was purchased by Wise Alloys LLC in April 1999. This facility has processes include aluminum coil coating, slitting, leveling, packing, shipping and storage. The facility employs 107 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 Sheffield 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 Sheffield Plant has es
tablished 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 Sheffield 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 Sheffield Plant.
The RMP at the Sheffield 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 regulated by the RMP rule (regulated subst
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 Sheffield 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 Sheffield Plant. In fact, the Sheffield 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 Sheffield Plant, less hazardous alternatives are always considered. Whe
n a hazardous substance is used at the Sheffield 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 Sheffield 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 the design, construction and operation of equipment. Each project is thoroughly reviewed before approv
al. 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 Sheffield 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 Sheffield Plant's goal is to minimize impacts from an accidental release: In the event of an accidental release, the Sheffield 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. In addition, Wise Alloys works with the local fire department and with the local emergency planning committee (LEPC) to help prevent in
juries 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 Sheffield 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 Sheffield 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 a
ll 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 Sheffield 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-Sulfur Dioxide, At Coil Coaters
Process Quantity 6,000 lb., RMP Threshold-5,000 lb.
Regulated Substance-Flammable Liquids, Coatings/Solvents Tanks
Process Quantity 216,000 lb., RMP Threshold-10,000 lb.
Sulfur dioxide is used at the coating lines' wastewater treatment facility to adjust pH as part of the wastewater treatment system. One-ton containers are utilized at this wast
ewater treatment facility.
Coatings and solvents (for use at the coating lines) are stored in the plant yard in aboveground storage tanks.
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 Sheffield 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 Sheffield Plant:
3.1 Toxic Substances - Sulfur Dioxide
The "worst-case release scenario" for sulfur dioxide is a failure of 1 one-ton sulfur dioxide containers to the sulfur dioxide feeder pipe at the wastewater treatment room at the coating lines which would release 2,000 pounds of sulfur dioxide 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 distance of 0.9 miles before the concentration of sulfur dioxide 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 2,820 people live within this distance from the wastewater treatment room; several public receptors are also located within this distance. No environmental receptors are located within this distance.
The "alternative-release scenario" for sulfur dioxide is the failure of connections from two 1-ton containers to the sulfur dioxide feed header pipe at the wastewater treatment room associated with the High Speed Cleaning and Coating Line. This would result in a release of 2,000 lbs of sulfur dioxide 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, a F stability class and urban topography, the chlorine cloud would travel 0.2 miles before reaching a sulfur dioxide concentration of below 3ppm (which is the endpoint Emergency Response Planning Guidelin
e value established in the RMP rule). The U.S. Census indicates that no people live within this distance from the wastewater treatment room; several public receptors are located within this distance. No environmental receptors are located within this distance.
3.2 Program 3 Processes-Flammable Substances
The "worst-case release scenario" for flammable substances is the rupture of the largest coatings storage tank located in the plant yard which would release 54,000 lbs of coatings/solvents. For this scenario involving a release of volatile flammable liquids, the total quantity of the flammable substance is assumed to form a vapor cloud within the upper and lower flammability limits, and the cloud is assumed to detonate. The worst-case release scenario was evaluated using RMP*COMP. Under the EPA default worst weather conditions, the cloud would create an overpressure level of 1 psi at a distance of 0.3 miles. The U.S. Census indicates that 108 people live within this distance from
the coatings tank spot; several public receptors are also located within this distance. No environmental receptors are located within this distance.
The "alternate release scenario" for flammable substances is the spillage of a single tote tank of coating near the coating line which would release 3,400 lbs of coatings/solvents. For this scenario involving a release of volatile flammable liquids, the total quantity of the flammable substance is assumed to form a vapor cloud within the upper and lower flammability limits, and the cloud is assumed to detonate. The worst-case release scenario was evaluated using RMP*COMP. Under the EPA default worst weather conditions, the cloud would create an overpressure level of 1 psi at a distance of 0.1 miles. No people live within this distance from the coatings spill spot; No public receptors are located within this distance. No environmental receptors are located within this distance.
4. The General Accidental Release Prevention Program and t
he Specific Prevention Steps (68.155)
Beginning in 1994, the Sheffield 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 Sheffield Plant fenceline;
The following sections briefly describe the elements of the Sheffield Plant's Program 3 prevention program that addresses EPA's RMP rule prevention program requirements.
4.1 Program 3 Prevention Program
The Sheffield Plant's Program 3 prevention program consists of the following twelve elements:
4.1.1 Process Safety Information
The Sheffield Plant maintains technical 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 Sheffield 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 Department. 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 chemistry, overview of the process operations, process variables with consequences of deviations, equipment and instrument descriptions, troubleshooting guidelines, start-up and shutdown pro
cedures 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 Sheffield 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 recommendations. 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 Proce
Sheffield 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 operat
ing procedures are used both to help in operating the plant's processes and as a training guide.
The Sheffield 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 reviewed and changes to the training program are implemented as appropriate.
4.1.5 Mechanical Integrity
The Sheffield Plant maintains the mechanical integrity of process equipment to help prevent equipment failures tha
t 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 Sheffield 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 Sheffield 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 operate 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 c
overed 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 Sheffield 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 prevention 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 preve
ntion program are implemented.
4.1.9 Incident Investigation
The Sheffield 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 Sheffield Plant has a formal program including training for incident investigations and the report generation.
4.1.10 Employee Participation
The Sheffield 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 preven
tion 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 Sheffield 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 work can begin. Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation.
The Sheffield Plant established a program to help ensure that contractor activities ar performed in a safe manner. The program reviews the safety recor
d 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 Sheffield Plant can proudly report zero for the 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 Sheffield Plant has established a written emergency response plan and maintains an emergency response team trained in t
hese 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
OSHA 29 CFR 1910.120(p) and (q) - Hazardous Waste Operations and Emergency
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
The Sheffield 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 Emergency 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
The LEPC committee meets every two months and conduct annual exercises of the emergency response plan, the Sheffield 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 Sheffield 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.
General Certification. To the best of my knowledge, information, 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
Wise Alloys LLC
* The Certification with original signature is presented in the attached cover letter.