Madison-Kipp Corporation - Executive Summary |
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EXECUTIVE SUMMARY Madison-Kipp Corporation is a manufacturer of precision aluminum and zinc diecast components located at 201 Waubesa Street, Dane County, Wisconsin. Madison-Kipp Corporation is committed to operating in a manner that is safe for Madison-Kipp workers, its neighbors and the surrounding environment. Madison-Kipp Corporation uses chlorine gas in its RCI furnace to adjust the metallurgy of the aluminum it melts for diecasting purposes. Madison-Kipp maintains three full one-ton containers and one empty container in a scrubber controlled storage room in the northeast corner of the Atwood Avenue production facility. The chlorine room has a four-hour fire rating, is diked, and has a scrubber that activates when the chlorine concentration in the room reaches 3 PPM. The scrubber is capable of neutralizing the entire contents of a one-ton container. An alarm and exterior light warns of the scrubber activation. Two containers are placed on a scale and one of the two supplies chl orine to the furnace. The other two containers are stored along side the scale. Piping for the chlorine system runs from the chlorine room up to the ceiling, along the ceiling to the RCI furnace, and down to the chlorine-nitrogen panel. This piping is also encased within PVC piping for redundant protection should a leak develop within the primary pipe. This additional piping would carry any leaked chlorine back to the storage room for scrubber control. Chlorine is then piped from this panel to the aluminum furnace under low-pressure. The system is currently limited to using no more than 35 pounds of chlorine per hour. At an internal administrative maximum use restriction of 30 pounds per hour (assuming continuous maximum operation) a chlorine delivery from a local supplier would be necessary about every eight days. Actual chlorine usage requires a delivery no more frequently than every four to six weeks. WORST CASE RELEASE SCENARIO CHLORINE Due to the capability of the scrubber sys tem to control releases occurring within the room, it has been determined that a worst case release scenario would have to be limited to an external operation involving chlorine. A worst case release would therefore have to occur during transport of a full container. A possible scenario would involve a one-ton container being dropped during delivery, causing a total failure of the container and a release of the entire contents during a ten-minute period. USEPA has established worst case scenario parameters for the release of a toxic gas within Risk Management Planning Consequence Analysis Guidance (May 1996). This guidance points to the use of stability class F and 1.5 meter per second wind speeds for evaluation of worst case scenarios. Stability class F cannot exist in Madison, Wisconsin during daylight hours and certainly cannot exist with air temperatures of 770F (another guidance requirement for worst case scenarios). Using Risk Management Planning Consequence Analysis Guidance (May 1996) Table 16 (Dense Gas Distances to Toxic Endpoint, 10-Minute Release, Urban Conditions, D Stability, and 3 m/s Wind Speed) and interpolating between 150 and 250 pounds per minute release rates, as well as 0.0075 to 0.01 mg/L toxic endpoints, results in an estimated worst case distance of 8,316 feet (1.575 miles). On the basis of the estimated 8,316 feet distance and on a 1990 Census Tract Map obtained from the City of Madison the area of possible impact was established as a circle with a radius of 1.5 miles. ALTERNATE RELEASE SCENARIO CHLORINE A possible alternate scenario for an outdoor release of chlorine would involve failure of a fusible plug on a chlorine container during delivery. This failure may be due to a fire involving the delivery truck, producing enough heat to melt one of the fusible plugs or some other event causing a plug failure. While the Madison Fire Department response time to Madison-Kipp Corporation is 10-minutes, it is assumed that the container will release its contents over a period of time of an hour. Using Risk Management Planning Consequence Analysis Guidance (May 1996) Table 17 (Dense Gas Distances to Toxic Endpoint, 60-Minute Release, Urban Conditions, D Stability, and 3 m/s Wind Speed) and interpolating between 150 and 250 pounds per minute release rates, as well as 0.0075 to 0.01 mg/L toxic endpoints, results in an estimated alternate scenario impact distance of 3,030 feet (0.574 miles). FIVE-YEAR ACCIDENT HISTORY CHLORINE Madison-Kipp Corporation installed the chlorine system in 1990. Mr. James Lenz, Plant Engineering & Environmental Manager for Madison-Kipp Corporation, confirmed that there have been no accidents in the last five years. ACCIDENTIAL RELEASE PREVENTION PROGRAM It is the policy of Madison-Kipp Corporation to operate our processes and produce our products without creating unacceptable safety risks. To carry out this policy Madison Kipp Corporation will identify and control safety hazards and conduct ac cident prevention programs to both protect our employees and the community. With regard to chlorine operations and the possibility of an external release scenario, Madison Kipp Corporation relies on its vendor to insure the delivery vehicle driver complies with USDOT regulations. During each delivery Madison Kipp Corporation positions two employees along with the truck driver to move the chlorine container using a crane designed to move chlorine from the delivery truck into our storage room. These employees are trained in both the tasks of moving chlorine containers, release prevention and the emergency reaction procedures. EMEGENCY RESPONSE PROGRAM Madison Kipp Corporation works very closely with Emergency Response personnel (Madison Fire Department Hazardous Material Team) to ensure readiness in responding to an accident. This readiness has included cooperative training on our system installation, operation and safety/maintenance procedures. This training has included on site inst allation of a chlorine container leak repair kit (B-Kit). Notification of any accidental release would be accomplished by calling 911 to alert both emergency responders and the public. Several telephones are located in the local area of the chlorine system. |