Armco Inc Butler Operations - Main Plant - 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 Butler Operations to prevent the occurrence and minimize the consequences of significant releases of chlorine 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 - Butler Operations, Main Plant is a specialty steel manufacturing facility located on Route 8 South in Butler, Pennsylvania. 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 chlorine, above the threshold quantities specified by the rules. Chlorine is stored and used at the facility's Melt Shop non-contact cooling water and continuous caster cooling water treatment systems. It is stored as a liquified gas in quantities greater than the 2,500-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. Both substances meet the criteria for Program 2 processes as specified in the RMP rules. 3. Worst-Case and Alternative Case Scenarios. Chlorine The Worst-Case Scenario is a failure of a one-ton cylinder inside the chlori ne storage building. The entire contents of a cylinder are assumed to be released as vapor over a ten minutes period as per EPA guidance. The chlorine storage building would provide passive mitigation and is applied to the worst-case scenario. The distance to the toxic concentration endpoint of 0.0087 mg/L for the worst-case scenario has the potential to result in off-site consequences on a public receptor. The Alternative Scenario is a cylinder leak that develops at a connection point resulting in a chlorine release inside the chlorine storage building. The building would limit the escape of the chlorine gas to the outside air. A chlorine detection system located within the building would trigger an alarm indicating a problem. Immediate employee response to the alarm would limit the leak to a duration of less than 30-minutes. The distance to the toxic concentration endpoint of 0.0087 mg/L for the alternative scenario has the potential to result in off-site consequences on a pu blic receptor. Hydrofluoric acid solution (70%) The Worst-case Scenario is an instantaneous release of the entire contents of an 11,700-gallon storage tank into the acid tank farm containment area below the tank. The containment area is sloped to a concrete trough which directs the spill to the facility acid wastewater collection sump. Acid spilled into the sump would be pumped to an on-site wastewater treatment plant and neutralized with lime. Application of the trough 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. The Alternative Scenario is the overfilling of the hydrofluoric acid storage tank, which results in a release of hydrofluoric acid to the tank farm containment area which drains into a concrete trough. The trough area drains to the facility acid wastewater collection sump wh ich directs the spill to an onsite wastewater treatment plant for neutralization. Tank filling operations are continuously monitored by two Armco pipefitters 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 Prevention Program Armco Inc. complies with EPA's Chemical Accident Prevention Program rules for chlorine and hydrofluoric acid solution. All elements of the Chemical Accident Prevention Program requirements under Part 68 have been developed and implemented for both chlorine and hydrofluoric acid at Armco Inc - Butler Operations. Chlorine The chlorine system meets the requirements of EPA's Chemical Accident Prevention Program. The chlorin e system was designed and constructed following good engineering practices with the chlorine cylinders being designed to meet DOT standards. A hazard review was conducted for chlorine on May 12, 1999 using the hazard review checklist published in the EPA document Risk Management Program Guidance for Wastewater Treatment Plants (EPA 550-B-98-010, October 1998) and all identified potential problems are to be addressed. Written operating procedures for chlorine storage, handling, and transfer are in place. All persons working with chlorine or chlorine containing equipment have been trained on operating and maintenance procedures and the potential hazards of working with chlorine. A preventive maintenance, inspection, and testing program is in place for chlorine equipment and operations. Hydrofluoric acid The hydrofluoric acid system meets the requirements of EPA's Chemical Accident Prevention Program. The hydrofluoric acid storage tanks were designed and constructed following good engineering practices. A hazard review was conducted for hydrofluoric acid on May 13, 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 are to be 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 the applicable operating and maintenance procedures and the potential hazards of working with hydrofluoric acid. A preventive maintenance, inspection, and testing program is in place for hydrofluoric acid equipment and operations. 5. Five-year Accident History Chlorine One incident involving chlorine has occurred within the last five years. This incident resulted in minor medical treatment being provided to one employee. There were no off-site impacts. An incident in vestigation immediately followed and involved all appropriate maintenance, operating and management personnel. All incident report findings and recommendations were addressed and resolved. These included recommendations to prevent such occurrences from happening again. Hydrofluoric Acid One reportable incident involving hydrofluoric acid occurred within the last five years. The incident resulted in a release of hydrofluoric acid to an soil on-site and to a storm sewer that ultimately drained into a nearby creek. No human health effects were noted for this incident. An Incident investigation immediately followed this event and involved all appropriate maintenance, operating and management personnel. All incident report findings and recommendations were addressed and resolved. These included recommendations to prevent such occurrences from happening again. 6. Emergency Response Program Armco Inc. - Butler Operations has trained employees for emergency response and maintain a written emergency response plan. The plan is coordinated with Butler County (Pennsylvania) Local Emergency Planning Committee (LEPC) and the local Fire Departments. The Armco response team trains and drills monthly and conduct 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 A comprehensive, above ground storage tank inspection program and review of acid storage tank containment areas is planned during 1999 - 2000 to assure compliance with the requirements of the Pennsylvania Above Ground Storage Tank Program Regulations. Alternate water treatment chemicals are being investigated by the Environmental Control Depart ment to replace the use of gaseous chlorine at the Melt Shop non-contact cooling water and continuous caster cooling water treatment systems. |