Cold Metal Products, Youngstown Facility - Executive Summary

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Cold Metal Products, Inc. is committed to the safety and health of our employees, our community, and the environment.  To this end we have formal policies and procedures identified in our Preparedness, Prevention, and Contingency Plans, our Spill Prevention Control and Countermeasure Plans, and other formal programs and action plans established by our personnel to help fulfill this commitment.  This Risk Management Plan will be used as another program tool to further enhance this commitment. 
 
Cold Metal Products, Inc. is a manufacturer of Cold Rolled Steel Shapes.  One of our product lines requires the use of Hydrofluoric Acid (70%) as a surface preparation chemical.  We purchase the HF in bulk and mix it in a ratio of 20 parts water and 1 part HF in our Anneal & Pickle Process.  The AP Line is used as product demands, however, the materials in the process are replaced approximately every other month.  At this time, HF is transferred from an outside storage tank to our AP Line.  When f 
ull, our HF Tank holds about 40,000 lbs of material and the tank itself is kept under pressure with dry nitrogen to prevent corrosion.   The transfer line for the HF contains this product only during the transfer of HF to the AP Line.  At the completion of the transfer the line is blown clear with dry nitrogen and the materials remain stored in the HF Tank itself. 
 
Using the OCA Guidance, we have determined that the Worst Case Scenario is a total tank failure and release.  This scenario assumes a newly filled tank and a release of the total 40,000 lbs. of material.  Cold Metal Products has written operating procedures for the use of this product and administrative controls during the tranfer of of this product into the AP Line.  In addition, we have established passive mitigation in the form of a concrete Dike surrounding the HF Tank. This Dike, in the event of a tank failure, would contain the spill and the release to the local receptors (residential homes) would be limited since the  
Dike limits the exposed surface area of the material and thus reduces the release rate.  It is calculated that this release could then affect the population for approximately a .31 mile radius (188 people).   
 
For an alternative release scenario, we have determined that a release could occur if we had a rupture or failure of the piping system during the transfer of HF from the Tank to the AP Line.  This is the only time a release could occur from the piping system since the line is blown clear with dry nitrogen after every use.  Therefore, no material remains in the line when it is not used.  Should the line rupture during materials transfer, the leak would be detected almost immediately since our Administrative controls have the operator visually inpsecting the system before and after the AP Line refill.  It was determined that if we were to spill approximately 2,000 pounds of the HF before the rupture was discovered and manually shut down, we could affect the local population to the  
radius of .19 miles (70 people). 
 
Cold Metal Products, Inc. has in place a comprehensive Safety, Health, and Environmental Program to assist our employees in safeguarding not only themselves, but the local community.  We have established programs and policies to comply with OSHA's Emergency Response Standards, as well as, the EPA's regulations regarding Hazardous Materials, their use, and the disposal of any Hazardous Wastes.  Our Preventive Maintenance program has a formal policy for process review and the immediate repair of any equipment or process which may result in a release.  While we have annual, formal training programs for our employees in Hazardous Materials, Hazardous Waste, etc., we also have pre-start visual checks of our equipment which would result in immediate response by our maintenance personnel to make repairs.  In addition, we have a formal, weekly inspection report which is documented for the AP Line and related equipment.  This inspection also results in immediat 
e action from our maintenance personnel to effect repairs. 
 
A review of our accident history indicates that we have never had a release of HF from our AP Line or related equipment. 
 
Cold Metal Products, Inc., has a detailed emergency reponse program.  We have reported our Hazardous Materials, including HF, to the Local Emergency Planning Committee so we may be included in the local agency's reponse program.  Our written response programs delail spill controls, emergency procedures, and emergency contact information, i.e., phone numbers for our personnel to use in an emergency.  While we have not had occasion to use our emergency system, we continue to stess the emergency plan in our training programs and will work with our Local Hazardous Materials Response agencies to help ensure a safe workplace and surrounding environment. 
 
It should also be noted that Cold Metal Products, Inc. continues to review it's equipment, materials, policies, and procedures to ensure continued improvement in 
our Hazardous Materials Program.  We continue to discuss new or updated processes, updated control and mitigation procedures, and provide updated training to our personnel to ensure their safe use of equipment and the proper response in the event of an emergency.  We also continue to evaluate cost effective materials substitution and other methods to reduce the hazard potential of materials and processes at our facility.
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