Avesta Sheffield Pipe Co. - Executive Summary

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Avesta Sheffield Pipe Co. (ASP) operates a stainless steel pipe and tube manufacturing facility, located on approximately 76 acres of owned property in Wildwood, Florida.  The facility is situated in the northeastern portion of Sumter County.  The facility consists of two main manufacturing buildings (South Plant and North Plant), which are used for pipe forming and welding activities, a covered and contained acid pickling area, and an industrial wastewater treatment plant. 
ASP manufactures 0.840" outer diameter (OD) to 4.500" OD stainless steel pipe in the South Plant and 5.00" OD to 72.00" OD pipe in the North Plant.  The average pipe length is 21 feet.  The pipe manufacturing process consists of forming flat stainless steel into the desired pipe diameter, welding the seam, heat treating (annealing), water quenching, straightening, cutting to length, cleaning (acid pickling), inspecting, and shipping. 
The acid pickling process utilizes a substance regulated under Section 112(r) of  
the Clean Air Act.  The substance is 70% hydrofluoric acid used to remove metal oxides from the surface of annealed pipe.  At any one time, this substances may be stored at a quantity above the threshold quantity listed in 40 CFR 68, Subpart F. 
The accidental release prevention program utilized at ASP consists of the elements required by the EPA risk management program.  ASP is committed to preventing accidental releases by providing and maintaining the highest practically achievable standards of safety, occupational health, and working environment.  ASP's goal is to discover, correct, and address conditions which may cause personal injury or illness, offsite consequences, or property damage.  Health, safety, and the protection of the working environment and the surrounding property have equal status with other primary business objectives, and are an integral part of planning and implementing every aspect of the company's operations.  In addition, ASP adheres to all applicable OSHA, D 
EP, and EPA regulations and continually reviews the regulations for any applicable changes or additions to the rules. 
Health, safety, and the protection of the working enviroment and the surroundings are the direct responsibility of ASP management.  Management and supervision take the initiative as an integral part of their duties to assure that safe working procedures and practices are employed to eliminate the risks of accidents and health hazards.  A continual alertness to identify and immediately correct unsafe practices or hazardous working conditions is paramount.  Information and training is provided to maintain an awareness of safety and the working environment. 
ASP's Emergency Response Plan (ERP) consists of a description of activities, inspection and prevention procedures, emergency notification, site control zones, personal protective equipment, decontamination and cleanup, emergency response equipment and communication, potential spill sources and control, evacuation plan 
, arrangement with local authorities, cleanup and post emergency response, and emergency response review.  All pertinent personnel attend an annual emergency response/hazardous material training class.  The LEPC, SERC, OHM Corporation (emergency response contractor), FDEP, Wildwood Fire Department, Wildwood Police Department, Sumter County Sheriff's Department, Leesburg Regional Medical Center, and Munroe Regional Medical Center all have updated copies of ASP's ERP.  In addition, the Wildwood Fire Department periodically performs mock training sessions at the ASP site.  Both the Wildwood Fire Department and OHM Corporation have been onsite to review ASP's ERP procedures, and become visually familiar with the plant surroundings. 
The worst-case scenario for HF acid involves the liquid release of the maximum amount of HF acid in inventory into the storage dike area.  Using EPA's RMP*Comp Modeling Program and an urban topography, since many large trees, thick vegetation, and buildings sur 
round the tank storage area, the distance to the endpoint is 0.6 miles.  According to Landview GIS Software, the estimated residential population within this radius is 57.  The only public receptors are residences and there are no environmental receptors.  The mitigation systems in use include a containment dike and neutralization capabilities.  The dike surrounding the tank has an area of 1400 sq. ft. and a wall height of 2.1 ft, which equates to about 22,000-gallons of storage volume.  This is more than enough volume to handle the entire contents of the HF acid tank, plus enough hydrated lime to neutralize the acid, which will prevent further fuming.  Process controls in use include vents, scrubbers, manual shutoffs, and emergency supplied air.  It should also be noted that the HF acid tank's wall thickness is measured semi-annually to track any wall thickness deterioration.  By using ultrasonic testing equipment to survey the entire tank wall, the corrosion rates of the tank wall ca 
n be tracked.  This allows the tank to be taken out of service and replaced well before any leaking hazards arise.  In addition, an alternative release involves a punctured HF acid pipe, which releases acid into the diked area.  Again using EPA's RMP*Comp Modeling Program and an urban topography, the distance to the endpoint is 0.2 miles.  The estimated residential population within this radius is 6. 
In the last five years, ASP has had no chemical release incidents to include in this report.  ASP is proud of this accomplishment and believes it is the direct result of its dedication to maintaining a safe working environment. 
ASP takes great pride in its safety, environmental, quality, and risk management systems.  These systems have proven to be effective in the past, and will always be in a continuous state of improvement.  ASP will continue to improve safety by holding all-employee safety meetings, safety committee meetings and inspections, safety project meetings, supervisor/employ 
ee training, and safety incentives.
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