Armco Inc - Zanesville Operations - Executive Summary |
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EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies Armco Inc's Policy is to fully comply with all applicable environmental laws and regulations. This includes compliance with EPA's Chemical Accident Prevention Program rules (40 CFR Part 68). The Risk Management Plan along with other safety and environmental programs already in-place enables Zanesville Operations to prevent the occurrence and minimize the consequences of significant releases of hydrogen and hydrofluoric acid, including leaks, spills, and other types of catastrophic accidents. Armco's emergency response program is designed to provide rapid response to suspected problems to keep hazardous materials from being released into the environment, minimize the effects of any spills and provide proper clean-up and required notifications as soon as possible following any incidents. 2. Facility and Regulated Chemical Description Armco Inc - Zanesville Operations is a specialty steel proces sing facility located on Linden Avenue in Zanesville, Ohio. The facility is subject to the requirements of Chemical Accident Prevention Program rules (40 CFR Part 68) of the Clean Air Act, due to on-site processes containing the regulated chemicals, hydrofluoric acid and hydrogen, above the threshold quantities specified by the rules. Hydrogen is stored and used at the facility's steel finishing operations. It is stored as a liquified gas in quantities greater than the 10,000-pound regulatory threshold. Hydrofluoric acid is stored and used at the facility's steel finishing operations. It is stored as a 70% water solution in quantities greater than the 1,000-pound regulatory threshold. Hydrofluoric acid meets the criteria for a Program 2 process as specified in the RMP rules. Because hydrogen is regulated under OSHA's Process Safety Management rules, it meets the criteria for a Program 3 process as specified in the RMP rules. 3. Worst-Case and Alternative Case Scenarios Hydr ogen Worst-Case Scenario: Instantaneous release of the entire contents of a 20,000-gallon storage tank. The entire contents are assumed to be released as vapor which finds an ignition source resulting in an explosion as per EPA's offsite consequence guidance (ten percent of the hydrogen released is assumed to participate in the explosion). This worst-case scenario has the potential to result in offsite consequences on public receptors at the offsite endpoint of 1.0 psi overpressure. Alternative Scenario: A process piping failure at a flange, joint, weld or valve results in a release of hydrogen. Rapid operator response results in the release being limited to less than 10-minutes in duration. The resulting release was assumed to cause a vapor cloud explosion when ignited with three percent of the hydrogen participating in the explosion. This alternative scenario has the potential to result in offsite consequences on public receptors. Hydrofluoric acid solution (70%) Worst-c ase Scenario: Instantaneous release of the entire contents of a 6,000-gallon storage tank into the containment area below the tank. Application of the containment area as a form of passive mitigation was used in the worst-case release analysis. The distance to the toxic concentration endpoint of 0.03 mg/L for the worst-case scenario has the potential to result in off-site consequences on a public receptor. Alternative Scenario: A hydrofluoric acid storage tank is overfilled resulting in a release of hydrofluoric acid to the containment area. Tank filling operations are continuously monitored and tank levels are verified manually before any trucks are unloaded. These control measures along with rapid operator response result in the release being limited to less than 10-minutes in duration. The distance to the toxic concentration endpoint of 0.03 mg/L for the alternative scenario has the potential to result in off-site consequences on a public receptor. 4. Chemical Accident Pre vention Program Armco Inc complies with EPA's Chemical Accident Prevention Program rules for hydrogen and hydrofluoric acid solution. All elements of the Chemical Accident Prevention Program requirements under Part 68 have been developed and implemented for both hydrogen and hydrofluoric acid at Armco Inc - Zanesville Operations. Hydrogen The hydrogen system meets the requirements of EPA's Chemical Accident Prevention Program. The hydrogen system was designed and constructed following good engineering practices with the storage tank being designed to meet ASME standards. The process hazard analysis was most recently revised on May 21, 1999 using the HAZOP method and all identified potential problems were addressed. Written operating procedures for hydrogen storage, handling, and transfer are in place. All persons working with hydrogen or hydrogen containing equipment have been trained on operating procedures and understand the consequences of deviation from the procedures. A me chanical integrity program is in place for hydrogen equipment and operations. Hydrofluoric acid The hydrofluoric acid system meets the requirements of EPA's Chemical Accident Prevention Program requirements. The hydrofluoric acid storage tanks were designed and constructed following good engineering practices. A hazard review was conducted for hydrofluoric acid on May 20, 1999 using a hazard review checklist published in Supplemental RMP Guidance for 70% Hydrofluoric Acid Users, December 1998, developed by AlliedSignal Inc. HF Products and all identified potential problems were addressed. Written operating procedures for hydrofluoric acid storage, handling, and transfer are in place. All persons working with hydrofluoric acid or hydrofluoric acid containing equipment have been trained on operating procedures and understand the consequences of deviation from the procedures. A preventive maintenance, inspection, and testing program is in place for hydrofluoric acid equipment and o perations. 5. Five-year Accident History Hydrogen No accidents involving hydrogen have occurred in the last five years. Hydrofluoric Acid Two accidents involving Hydrofluoric Acid have occurred in the last five years. Both incidents involved Contractors. The first incident involved three personnel from an industrial rubber lining company. During the removal of the storage tank's rubber lining, the workers received acid burns to their hands resulting in hospital treatment. The second incident occurred when a contractor, working within an empty pickle tub, walked past an acid supply pipe that had a faulty valve. The valve allowed the bypass of hydrofluoric acid vapor. The worker received a superficial acid burn. Proper PPE would have eliminated this accident. The faulty valve was replaced and a checklist developed prior to entry into pickle tubs. Incident investigations immediately followed both accidents and all recommended corrective actions have been implemented. 6. Emergency Response Program Armco Inc - Zanesville Operations has trained employees for emergency response and maintains a written emergency response plan. The plan is coordinated with Muskingum County (Ohio) Local Emergency Planning Committee (LEPC) and the local Fire Departments. The Armco response team trains and drills monthly and conducts annual drills for implementation of the emergency response plan at the facility. The emergency response plan includes procedures for notification of local fire department and outside emergency response personnel as needed. Emergency responders including employees and off-site emergency and fire personnel have copies of the emergency response plan and are familiar with its use. 7. Planned Changes to Improve Safety Armco will continue to evaluate and improve it's comprehensive safety program. |