Republic Engineered Steels, Inc. - Executive Summary
RISK MANAGEMENT PLAN
REPUBLIC ENGINEERED STEELS, INC.
BALTIMORE STAINLESS AND SPECIALTY PLANT
Accidental Release Prevention and Emergency Response Policies
Republic Engineered Steels, Inc. (Republic) has developed this Risk Management Plan (RMP) to ensure the safety of all persons who could be affected by an accident or incident at Republic's Baltimore Stainless and Specialty Plant (BSSP) in Baltimore, Maryland. Subsidiary concerns are minimization of damage to the environment or Republic equipment, property and product as well as compliance with the regulations.
Ruthner Pickling Line
Republic's Engineered Steels, Inc. (RESI) is located at 3501 East Biddle Street, Baltimore, Maryland. This site is an active steel mill producing steel rods and bars. Structures at the property include various buildings where steel is produced and formed. One of the production operations at the facility is a Ruthner pickling line that uses hydrofluoric acid to
remove scale from the steel. The maximum amount of hydrofluoric acid present in the process is 4,600 gallons.
Worst-case Release Scenario
The worst-case release scenario was calculated to be failure of the bulk hydrofluoric acid storage tank. The bulk hydrofluoric acid storage tank has a capacity of 4,600 gallons. The off-site consequences analysis for the worst-case release scenario was modeled using RMP*Comp v.1.06. The release rate was 20.2 pounds per minute and resulted in a release duration of 2,371 minutes. Mitigation measures present at the facility include a containment berm, location of the tank within a building, and a drain system which would direct any material released from the tank to sump at the facility. The results of the modeling indicated that the toxic endpoint of 0.016 milligrams per liter (mg/L) of hydrogen fluoride would be reached a distance of 0.6 miles from the release point.
Alternative Release Scenario
The alternate release scenario was assumed
to be a leak that develops in the transfer piping system during refilling of the bulk hydrofluoric acid storage tank. Based on the size and length of the fill pipe, approximately 6.5 gallons of hydrofluoric acid would be released due to a leak in the transfer piping system. The off-site consequences analysis for the alternate release scenario was modeled using RMP*Comp v.1.06. The release rate was 0.0316 pounds per minute resulting in a release duration of 2 minutes. Mitigation measures present at the facility include a containment berm, location of the tank within a building, and a drain system that would direct any material released from the tank to sump at the facility. The results of the modeling indicated that the toxic endpoint of 0.016 mg/L of hydrogen fluoride would be reached a distance of less than 0.1 mile from the release point.
General Accidental Release Prevention Program and Chemical-Specific Prevention Steps
Republic has developed and implemented a Risk Managemen
t Plan (RMP) in compliance with the U.S. Environmental Protection Agency's Risk Management Program regulations, 40 CFR Part 68.
The RMP for Republic's BSSP includes detailed sections on the following:
Process Safety Information
Process Hazard Analysis
Pre-startup Safety Review
Management of Change
Emergency Planning and Response
Off-site Consequences Analysis.
Emergency response is contracted to local firms with specific expertise in handling these types of incidents. Therefore, Republic employees are not trained in emergency response but are trained in identifying incidents which require contacting outside emergency response contracts and the procedures for making these contacts.
Five-year Accident History
Republic maintains detailed incident reports for all processes at their facility. There have been no reportable releases of hydrogen f
luoride from the system in the last five years.