Elkem Metals Company, LP, Ashtabula, Ohio Facility - Executive Summary |
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Accidental release and emergency response policies: The Elkem Metals Company (Elkem) in Ashtabula, Ohio utilizes chlorine in the wastewater treatment process. Because chlorine is a listed compound by the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA), the control of the chlorine in the wastewater process is regulated by these two agencies. In order to comply with regulatory requirements and to protect the health and safety of its employees, the surrounding community and the environment, Elkem has established a comprehensive risk management program to ensure continued safety of its day-to-day processes and operations. Primary activities, use of regulated substance and quantities stored: Chlorine is stored at the facility in one railcar in quantities up to 180,000 pounds. In the wastewater process, liquid chlorine is transferred from the chlorine storage railcar to the chlorine building where it is vaporized. Gaseous chlorine i s then fed into the water where it is dissolved and forms hypochlorous (HOCl) and hydrochloric (HCl) acids. The hypochlorous acid further dissociates into hydrogen and hypochlorite ions which are essential to the wastewater treatment process. Worst-case release scenario: It is believed that the worst potential chlorine release would be the collapse or rupture of the chlorine railcar. Based upon RMP regulatory requirements, it is assumed that all of the material in the railcar would be released to the environment within 10 minutes. Such an unlikely release has the potential to affect personnel within a 26.82 mile radius of the release site. This area includes the residences and businesses of 165,000 people. Although this is an extremely unlikely situation, Elkem personnel routinely inspect the railcar for damage. It is also periodically subjected to a complete internal and external inspection by certified inspectors. Further safeguards include relief valves that are installed on the railcar to prevent failure of the tank and chlorine detectors that are permanently installed around the railcar and transfer piping. These detectors alert personnel to potential leakage, allowing them to address any problem before it reaches a serious level. Alternate release scenario: An alternate release scenario is a hole or fracture in transfer piping. In order to prevent pipe failure, all chlorine storage and transfer areas are equipped with chlorine detection systems that automatically stop the flow of chlorine gas to the damaged pipe. This safeguard greatly reduces the amount of gas that would be released. The release has the potential to affect personnel and other receptors within 2.8 miles of the release site (approximately 14,000 people). General accidental release prevention: Elkem has established a comprehensive management system that meets the requirements of OSHA PSM and EPA RMP standards that ensures the safe operation of the wastewater treatment process. To identify potential chlorine release situations, Elkem has analyzed the wastewater process, how the elements interact, how the equipment can fail and has implemented practices to prevent and react to failures. In addition, Elkem has established facility-wide procedures on managing hazardous activities, such as welding, and process-specific procedures addressing the hazards, operations and maintenance activities unique to the wastewater treatment process. All personnel that may be required to perform these activities are trained in the proper procedures. Employees also participate in the development of the procedures and other documentation related to the process in order to utilize their experience and knowledge. Process changes are analyzed before implementation to prevent creation of new hazards, and new equipment is inspected and tested before it is placed in service. Five-year accident history: In the last five years, the Elkem facility in Ashtabula, Ohio has not experience d any off-site impact accidents. Elkem fully investigates every incident that occurs at the facility and has developed an emergency response program that includes on-site personnel specially trained to handle chlorine releases These specially trained personnel work in coordination with the Ashtabula County LEPC. Emergency response program: Recently, three major chemical plants that also are large users of chlorine in the Ashtabula area (Millennium, Ashtachem and Oxychem) came together and held a community forum focused on public awareness, safety precautions and response plans. Representatives from the three plants presented various scenarios and detailed response plans to each scenario. The local Chamber of Commerce and the communitys safety council supported the community forum. |