Allegheny Rodney Strip Division - Executive Summary |
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Introduction Allegheny Rodney Strip Division (Rodney) operates a metal manufacturing facility in New Bedford, Massachusetts which is subject to U.S. EPA regulations governing Accidental Release Prevention (ARP) Requirements: Risk Management Programs under Section 112(r) of the Clean Air Act (40 CFR Part 68). This Risk Management Plan (RMP) has been developed in accordance with the requirements specified under 40 CFR Part 68, Subpart G. The RMP certifies that Rodney has instituted a Risk Management Program at their facility that is in compliance with U.S. EPA ARP requirements. The RMP includes an Executive Summary and Data Elements following the format published by U.S. EPA. In addition to identifying the applicable corporate policies and risk management systems, the RMP identifies a set of worst case and alternative release scenarios, the potential off-site consequences of those releases, and the facility's five-year accidental release history. This RMP certifies that prevention an d emergency response programs are in place so as to minimize risks to both workers and the potentially affected public. Accident Release Prevention Program and Emergency Response Policy It is the policy of Rodney management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68. The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to Rodney employees, the public and the environment. This objective will be accomplished by utilizing good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Rodney's management is committed to providing the resources necessary to implement this policy. Rodney has developed a management system to implement and maintain compliance with the ARP Program and related OSHA Process Safety Manag ement and emergency response programs. At Rodney, the Environmental Manager has primary responsibility for ensuring overall implementation and compliance with these programs. Other individual employees such as the Environmental Manager, Health and Safety Coordinator,Operations Supervisor, and Vice President of Operations are responsible for the technical implementation of individual sections of these programs. Facility Description The Allegheny Rodney Strip Division facility in New Bedford, Massachusetts utilizes two processes that are subject to the requirements of 40 CFR Part 68. The hydrofluoric acid is used in the pickling and cleaning lines and is classified by the North American Industrial Classification System (NAICS) as industry number 331221 which includescold-rolled steel shape manufacturing. The hydrogen used at Rodney is part of the annealing process and is classified by the North American Industrial Classification System (NAICS) as industry numbers 332811, which includ es metal heat treating. Rodney processes metal to manufacture thin gauge metal foil. The facility processes stainless steel, carbon steels, nickel and titanium alloys, and other metals and alloys. Process operations used at Rodney to manufacture thin gauge metal foil include rolling, annealing, pickling, cleaning, coating, slitting, cutting and machining and welding. Rodney uses a number of hazardous compounds at the site; these include both toxics and flammables. Of these, hydrogen gas, which is used in the annealing process, and 70% hydrofluoric acid, used in the Furnace 12 acid pickling solutions, exceeds the threshold amounts. Other toxic compounds that are used at the site are either not of sufficient quantity to be regulated or are found at such a concentration that they are exempt from the RMP regulations. Program Level Identification The EPA Risk Management Regulation identifies three levels of requirements defined as "programs". Program 2 and 3 are applicable to processes that do not qualify for Program 1. Program 2 applies to any process that is ineligible for Program 1 and is not subject to Program 3. Program 3 applies to all processes, such as the hydrogen process present at Rodney, that are subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM). The Furnace 12 hydrofluoric acid process at Rodney falls under Program 2 as it is not subject to Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM). However, the hydrogen process at Rodney's facility is subject to OSHA PSM Standard, and it is therefore a Program 3. Rodney's Accident Prevention Program elements are adopted directly from the compliance program for the PSM standard, consistent with the Program Level 3 RMP Program requirements under 40 CFR Part 68. Program 3 related information is included in the Data Elements section of the Risk Management Plan Worst-Case and Alternative-Release Scenarios The RMP regulations require that each facility identify worst-case and alternative case release scenarios. For the purposes of developing and maintaining adequate Risk Management Plans, the EPA has defined in its governing rules and guidance a series of modeling methods and assumptions, which are to be used as administrative guides for planning purposes. In order to standardize and simplify the many factors that can potentially occur in an accidental release situation, some of these assumptions may not take into account the available preventive measures or mitigation methods that could diminish or even eliminate the implied risks that are suggested by "worst-case" analyses. For that reason, both the results for the standardized "worse-cases" defined by the EPA methods and a set of alternative cases which are believed by Rodney to more realistically represent situations that may possibly, but rarely, occur within the lifetime of the facility are also presented. EPA has defined a worst-c ase release as the instantaneous release of the entire contents of the largest vessel or connected piping that contains a regulated substance. For toxic liquids or substances such as hydrofluoric acid stored at ambient temperatures it is assumed that the release occurs over a 10-minute period. The Allegheny Rodney facility is located on the west bank of the Acushnet River in New Bedford Harbor. In the immediate vicinity of the facility, the aerodynamic surface roughness is 'urban' in nature, due to the many large buildings, tanks and other structures at the site. For both the worst-case scenario analysis, and alternative release analysis, the following EPAs RMP Offsite Consequence Analysis Guide and RMP*COMP model were respectively used and urban surface roughness was used. Worst-Case Release The EPA Risk Management Program Guidance For Offsite Consequence Analysis (April 1999) was used to simulate the worst-case release scenario for Rodney. The worst-case scenario for the hydrof luoric acid process consists of a 10-minute liquid ground-level release of 500 lbs. of stored 70% hydrofluoric acid at 900F, dispersed under atmospheric conditions of F stability and 1.5 m/sec wind speed. The 70% hydrofluoric drums are kept in a separate room adjacent to the main building that is enclosed on three sides. Within the storage area there is berm separating the HF drums from other chemicals and a trench lining the storage room to promote drainage. Should a release occur, the trench would provide containment of the liquid. The selection of the worst-case release for hydrofluoric acid should, therefore, be viewed as a regulatory necessity, rather than a realistic representation of a worst-case release event. The modeling results for the regulatory defined worst-case release indicate that the distance to the toxic endpoint is approximately 0.2 miles. Within this radius are public receptors, including residents and other industrial buildings. Public and environmental receptors were identified using 1:24,000 scale U.S.G.S maps, supplemented with comprehensive maps of the local area (DeLorme Street Atlas USA, Version 5.) Alternate Release Alternative releases are intended to represent release scenarios that have a greater likelihood of occurrence than a worst-case release. Alternative releases do not necessarily represent the types of releases that the PSM hazards analysis and/or accident history indicate would be most frequent, but rather a release that is somewhat more likely than the worst-case release and that generally still has the potential to affect off-site receptors. In accordance with the EPA's OCAG, a single alternative release scenario is reported. Rodney performed a thorough review of the facility utilizing engineering plans, operational experience, and maintenance records, and the results of the OSHA PSM review in order to determine potential alternative release scenarios that would result in the greatest toxic endpoint distance. In accordanc e with the RMP rule, alternative releases are modeled under typical (rather than worst-case) dispersion conditions. The EPA OCAG default dispersion conditions are neutral atmosphere, with dispersion neither enhanced nor limited (D stability and 3 m/sec wind speed). Unlike the worst-case release (for which an instantaneous spill or 10-minute ground-level gas release is assumed), alternative scenarios can account for the actual release configuration, and account for both active and passive mitigation. The alternative release scenario that resulted in the greatest toxic endpoint distance was a leak in one of the lines connected to the hydrofluoric acid pumps, located within the main building. The hydrofluoric acid is pumped inside the building to two tanks. While there is double wall piping to prevent accidental rupture of a line, there is no leak detection equipment available for these pipes. While Rodney estimates that facility personnel would be able to respond and stop the flow pri or to emptying of a drum, it was conservatively assumed that the drum would completely empty and that the drum was full at the time of the incident. The EPA RMP*COMP software was used to estimate the distance to the toxic endpoint for the alternate release scenario. The model estimated release rate for this scenario was 36 lbs/min. The resulting toxic endpoint distance for this alternative release scenario is 0.1 miles. Within this distance, the public receptors are limited to residents and other industrial buildings. Flammables Worst-Case Release The EPA Risk Management Program Guidance For Offsite Consequence Analysis (April 1999) was used to simulate the worst-case release scenario for the hydrogen process at Rodney. The worst-case scenario consists of a 10-minute gaseous ground-level release of 11,820 lbs. of stored hydrogen, dispersed under atmospheric conditions of F stability and 1.5 m/sec wind speed. This release would result in a vapor cloud explosion. The liquid hydro gen storage system is designed to operate at the facility unattended. The system consists of a double wall, thermally insulated, vacuum jacketed cryogenic tank, piping circuits and process control components. The system is designed to relieve any abnormal conditions that could lead to an explosion, therefore, the selection of the worst-case release for hydrogen should be viewed as a regulatory necessity, rather than a realistic representation of a worst-case release event. The modeling results for the regulatory defined worst-case release indicate that the distance to the toxic endpoint is approximately 0.2 miles. Within this radius are public receptors, including residents, and other industrial facilities. Public and environmental receptors were identified using 1:24,000 scale U.S.G.S maps, supplemented with comprehensive maps of the local area (DeLorme Street Atlas USA, Version 5.) Flammables Alternate Release Alternative releases are intended to represent release scenarios that hav e a greater likelihood of occurrence than a worst-case release. Alternative releases do not necessarily represent the types of releases that the PSM hazards analysis and/or accident history indicate would be most frequent, but rather a release that is somewhat more likely than the worst-case release and that generally still has the potential to affect off-site receptors. In accordance with the EPA's OCAG, a single alternative release scenario is reported. Rodney performed a thorough review of the facility utilizing engineering plans, operational experience, and maintenance records, and the results of the OSHA PSM review in order to determine potential alternative release scenarios that would result in the greatest toxic endpoint distance. In accordance with the RMP rule, alternative releases are modeled under typical (rather than worst-case) dispersion conditions. The EPA OCAG default dispersion conditions are neutral atmosphere, with dispersion neither enhanced nor limited (D stabi lity and 3 m/sec wind speed). Unlike the worst-case release (for which an instantaneous spill or 10-minute ground-level gas release is assumed), alternative scenarios can account for the actual release configuration, and account for both active and passive mitigation. The alternative release scenario that resulted in the greatest toxic endpoint distance was a high pressure situation developing within the hydrogen storage tank due to inadequate venting. When vessel overpressurization occurs, the safety relief valve and rupture disk on the tank are triggered, causing a release of hydrogen. The release was estimated to occur for 20 minutes, after which time the emergency response team would have responded and restored the tank integrity. The EPA RMP*COMP software was used to estimate the distance to the toxic endpoint for the alternate release scenario. The model estimated release rate for this scenario was 14,400 lbs./hr. The resulting toxic endpoint distance for this alternative rel ease scenario is 0.1 miles. Both residences and other industrial facilities are found within this distance around the Rodney Facility. Accidental Release Prevention Program Allegheny Rodney is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and to the environment. These regulations include: 7 40 CFR Part 68, Accidental Release Prevention 7 40 CFR Part 112, Spill Prevention, Control and Countermeasure 7 40 CFR Part 264, Hazardous Waste Contingency Plan 7 29 CFR Part 119, Process Safety Management The hydrogen process subject to the Risk Management Regulation is also subject to Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard. Rodney's Accident Prevention Program elements are adopted directly from the compliance program for the PSM standard, consistent with the Program Level 3 RMP Program requirements under 40 CFR Part 68. The RMP Program 3 Prevention Program elements are: 7 Employee Participation 7 Process Safety Information 7 Process Hazard Analysis (PHA) 7 Standard Operating Procedures 7 Training 7 Contractors 7 Management of Change (MOC) 7 Pre-Startup Safety Reviews (PSSR) 7 Mechanical Integrity 7 Safe Work Practices 7 Incident Investigation 7 Compliance Audits Five Year Accident History Rodney has an Incident Investigation program in place to investigate and document incidents that occur in the plant due to either the hydrofluoric acid or hydrogen process that could lead to a major accident involving a Rodney employee. The relevant information is documented on the Incident Investigation report and kept on file for five years. During the past five years, there has been one accident involving hydrofluoric acid that qualifies for reporting under 40 CFR Part 68. This accident involved a leak in the main building that resulted in 11 worker injuries. There were no off-site environmental impacts. Contributing factors to this incident included human error and improper procedures. In order to reduce the risk of a similar accident, changes were introduced within the hydrofluoric process. These changes included revised training, new process controls, revised operating procedures, revised emergency response plan, and improved equipment. Emergency Response Program Consistent with program requirements, Rodney has implemented an emergency response program that includes an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up to date. Rodney has developed an Incident Command System (ICS) for the management of all incidents at the plant, up to and including area-wide disasters. Response activities are coordinated with the local fire department to ensure the appropriate level of response. Planned Changes to Impro ve Safety Rodney, under the recent RMP program, as well as its existing PSM and earlier SARA Title III Community Right-to-Know Act compliance programs has organized its management system to effectively address all hazards and potential risks. Both the advanced planning aspects of process design, operating procedures, and emergency preparedness, and the operational elements of system maintenance, safe operating practices and ongoing personnel training are necessary to support a continual improvement in facility safety. These programs are thoroughly documented so that information about the safe handling of chemicals present at the facility is available to all employees, and can be readily interpreted by emergency response team staff and the Incident Commander. Rodney's safety program incorporates continuous improvement through use of audits, inspections, and on-going evaluations of in-plant safety and program effectiveness. The information gathered is evaluated and improvements that ar e identified are incorporated into the program. |