SANDVIK STEEL COMPANY - Executive Summary
The Sandvik Steel Company is committed to operating in a manner that is safe for Sandvik workers, the public, and the environment. As part of this commitment, Sandvik established a system to help ensure safe operation of the processes at this facility. One component of this system is a risk management program (RMP) that helps manage the risks at Sandvik and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at Sandvik. This plan is intended to satisfy the RMPlan requirement of the RMP rule ('68.150 through '68.185) and to provide the public with a description of the risk management program at Sandvik.
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
Sandvik is committed to the safety
of its workers and the public, and to the preservation of the environment through the prevention of accidental releases of hazardous substances. In the event of an accidental release, Sandvik controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment.
SANDVIK FACILITY AND REGULATED SUBSTANCES
The Sandvik Steel Company processes stainless steel and uses aqueous hydrofluoric (HF) acid in its stainless steel pickling and deglassing processes. HF acid at solution concentrations of 50 wt% or greater are regulated by the RMP rule, and although only dilute (about 4 to 8 wt%) HF acid solutions are used in the pickling and deglassing tanks, HF acid at a solution concentration of 70 wt% is stored in a large tank at the Sandvik facility for use in the processes.
A maximum of 5,000 gallons of 70 wt% HF acid is stored in one 5,000 gallon tank located at the Sandvik site. The weight of HF acid in 5,000 gallons o
f 70 wt% solution is just under 51,000 lb, which exceeds the RMP rule threshold quantity (1,000 lb) for HF acid in a process. Because the HF acid storage process is not covered by the requirements of the Occupational Safety and Health Administration's Process Safety Management regulation and because the potential exists for off-site consequences resulting from an accidental release of HF acid, the HF bulk storage process falls under the RMP Program 2 prevention program.
OFFSITE CONSEQUENCE ANALYSIS
The RMP rule requires Sandvik to perform an offsite consequence analysis for one worst-case and one alternative release scenario for aqueous HF acid, a toxic substance. The worst-case release scenario is catastrophic failure of the 5,000 gallon tank releasing 51,000 lb of aqueous HF acid (70 wt%). A diked area contains the released aqueous HF acid, which evaporates, forming a vapor cloud. Migration of a hydrofluoric acid vapor cloud to offsite receptors will be controlled and minimiz
ed by using an existing water deluge system. Trained emergency response personnel, equipped with the required personal protective equipment are onsite and can immediately initiate the control procedures identified in the Preparedness, Prevention and Contingency Plan (PPC Plan).
An agreement has been executed with an Emergency Response Contractor who will respond to a spill or release if site personnel should require assistance during a catastrophic chemical release. Additionally, an offsite Emergency Response Plan for this facility has been developed by the Lackawanna County Emergency Management Agency.
The alternative release scenario for aqueous hydrofluoric acid is a discharge from a 1/2-inch diameter rupture in a pipe located at the bottom of the tank. This scenario assumes that the solution is released through the opening for 60 minutes before workers detect the release and isolate the pipe. The released acid would form a pool within the diked area, with HF evaporating from
the pool and forming a vapor cloud. The vapor cloud would be knocked down, and offsite migration of the vapor cloud controlled by utilizing a water deluge system located at the tank farm. Personnel trained in emergency response procedures, and which are identified in a current Preparedness, Prevention and Contingency Plan are readily available to implement control methods which would minimize offsite migration of an acid vapor cloud.
The US EPA's RMP Offsite Consequence Analysis Guidance was used to determine the offsite impact.
Population data was obtained from U.S. Census Bureau Software "Landview III".
ACCIDENTAL RELEASE PREVENTION PROGRAM AND
CHEMICAL-SPECIFIC PREVENTION STEPS
The RMP rule requires a Program 2 prevention program for the aqueous HF acid bulk storage process. The following paragraphs describe the prevention program elements at Sandvik that apply to these units.
Sandvik maintains a variety of technical documents that are used to help ensu
re safe operation of the Sandvik processes. Material safety data sheets document the physical properties of hazardous substances handled at this facility, including HF acid. The engineering design documents include the operating parameters, the design basis and configuration of the equipment in each covered process, and references to applicable codes and standards.
Sandvik performs and periodically updates hazard reviews of the HF acid storage process to help identify and control process hazards. Checklists are used to guide the hazard review. These checklists include items to help ensure that this plant operates and maintains the equipment in a manner consistent with the applicable design specifications, codes, standards, and regulations.
Sandvik develops and maintain operating procedures to define how tasks related to process operations should be performed. The operating procedures are used to (1) train employees and contractors, and (2) se
rve as reference guides for appropriate actions to take during both normal operations and process upsets.
Sandvik trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks. A training documentation file is maintained to help ensure that refresher training is provided, as necessary.
Sandvik properly maintains the process equipment. The maintenance program includes (1) procedures to safely guide workers in their maintenance tasks, (2) worker training in the maintenance procedures, and (3) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails.
Periodic compliance audits of covered processes are performed to verify that the Sandvik processes are operating in compliance with the requirements of the RMP rule. A compliance audit report is prepared after each audit, and any deficiencies noted by the audit are corrected in a timely m
All incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment, are investigated by Sandvik. Sandvik trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancement are implemented.
HF Acid-Specific Prevention Steps
Industry standards are followed at Sandvik to help ensure safe handling of aqueous HF acid. The vendor supplies aqueous HF acid via a Department of Transportation (DOT)-approved tank truck and follows DOT standards when loading the aqueous HF acid storage tank. The storage tank design and construction are consistent with A.S.M.E. standards. Workers who perform operations involving HF acid receive training developed by Sandvik which emphasizes safe handl
ing procedures for HF acid.
FIVE-YEAR ACCIDENT HISTORY
A 5-year accident history that fulfills the requirements of the RMP rule ('68.42) is maintained by Sandvik. This history indicates a good record of accidental release prevention over the past 5 years. No significant releases of hydrofluoric acid have occurred from Sandvik in the last 5 years that have resulted in consequences of interest (i.e., deaths, injuries, or significant property damage on site; or known deaths, injuries, evacuations, sheltering-in-place, property damage , or environmental damage off site.
EMERGENCY RESPONSE PROGRAMS
Sandvik has established a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations. This plan has been communicated to local emergency response officials through the local County Emergency Management Agency and the applicable Fire Department. Regular dialogue is maintained between Sandvik and the local fire chief, and Sandvik p
rovides appropriate information to the fire chief. Sandvik periodically conducts emergency response drills at Clarks Summit Facility.
PLANNED CHANGES TO IMPROVE SAFETY
Sandvik constantly strives to improve the safety of the processes at this facility through both the incident investigation program and an active, responsible Safety Steering Committee. The following changes to improve process safety are planned or have recently been completed:
a. All acid transfers are now done on the first shift only mainly using outside contractors who do this as their normal job.
b. Additional training has been given to all members of the Spill Team and is now part of the annual training.
c. All piping from the storage tank to the process tanks has been completely replaced as per specifications supplied by the vendor.
The latitude and longitude data stated in the registration information section have been verified utilizing a Global Positioning System instrument.