AK Steel Corporation - Executive Summary |
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1. Accidental Release Prevention and Emergency Response Policies AK Steel Corporation in Middletown, Ohio complies with EPA's Accidental Release Prevention Program Rule (40 CFR Part 68). The enclosed Risk Management Plan addresses the requirements of 40 CFR Part 68 as they relate to the storage, handling, and processing of ammonia. Through our compliance with Part 68, we promote overall plant, worker, and community safety. Our Risk Management Program enables our facility to prevent the occurrence and minimize consequences of significant releases of ammonia, including leaks, spills, fires, explosions, and other types of catastrophic accidents. In order to reduce the likelihood and severity of accidental chemical releases that may affect on-site workers and off-site populations and environmental receptors, the Company policy is to fully comply with the spirit and the letter of EPA's Accidental Release Prevention Program rules (40 CFR Part 68). The Company has developed a formal R isk Management Plan in compliance with 40 CFR Part 68. All employees are expected to understand their role in developing and implementing the plan and to diligently adhere to its provisions. The Middletown facility's Risk Management System has clearly defined lines of authority and designation of responsibilities to ensure that the risk management plans are developed, implemented, and revised. AK Steel's safety and risk programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. 2. Facility and Regulated Chemical Description AK Steel's Middletown, Ohio manufacturing facility is subject to the requirements of 40 CFR Part 68, the Accidental Release Prevention Provisions (112r) of the Clean Air Act, due to two on-site processes containing regulated chemicals above their threshold quantities. Hydrogen, a regulated flammable substance, is present above the 10,000 pound threshold. Anhydr ous ammonia, a regulated toxic substance, is present in a quantity greater than its 10,000 pound threshold. Hydrogen meets the criteria for Program 1; and Ammonia is Program 3. Thus, the remainder of this summary does not include the hydrogen process, as it is not subject to the prevention and emergency response requirements of EPA's RMP rules. 3. Accidental Release Prevention Program The Middletown facility complies with EPA's Accidental Release Prevention program rules for ammonia. All elements of the accidental release prevention requirements under Part 68 have been developed and implemented for ammonia at the Middletown facility. The anhydrous ammonia system was designed and constructed in accordance with ASME, ANSI, API, other industry codes and standards. A process hazard review was conducted for ammonia and all identified problems were addressed. Written operating procedures associated with all facets of ammonia storage, handling, and transfer are in place. All person s working with ammonia or ammonia containing equipment have been trained on operating procedures and understand the consequences of deviation from the procedures. A mechanical integrity program is in place for ammonia equipment and operations. 4. Five-year Accident History No accidental releases of ammonia have occurred during the last five years that resulted in offsite impacts of any kind. 5. Emergency Response Program The emergency response program at the Middletown facility is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written emergency response plan. The plan is coordinated with the Butler County Local Emergency Planning Committee (LEPC) and the Middletown Fire Department. The AK Steel response team trains and drills monthly. We have conducted annual drills for implementation of the emergency response plan at the facility with th e participation of the LEPC and fire department. The emergency response plan includes procedures for notification of the fire department and notification of any potentially affected neighbors. |