Allegheny Ludlum Corporation - Washington Facility - Executive Summary |
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This Risk Management Plan (RMP) has been developed for Allegheny Ludlum Corporation's Washington facility located Woodland and Griffith Avenues, Washington, Pennsylvania, and is pursuant to the requirements of 40 Code of Federal Regulations (CFR) Part 68. Process Description and Regulated Substances The Washington facility has designed and operates one process for the storage and transfer of 70 percent hydrofluoric acid (HF) into process tubs. The process includes a 10,000-gallon storage tank located in a designated acid storage area and piping used to supply 70 percent HF to the process tubs. This process is located in a part of the plant that is designed for the storage, handling, and use of 70 percent HF. The storage, handling, and use of 70 percent HF at the plant is hereafter referred to as "Process No. 1" in the remainder of this document. The North American Industrial Classification System code for the facility is 331111. The Washington facility process is classified as a Tier II program since the facility is not subject to Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) requirements under 29 CFR 1910.119. Accident Release Prevention and Emergency Response Policies The Washington facility has an excellent record in preventing and minimizing releases of hydrofluoric acid. Please be advised that Allegheny Ludlum Corporation purchased the Washington facility from Bethlehem Steel Corporation in November 1999. Allegheny Ludlum Corporation began operating the Washington facility in February 2000. The Allegheny Ludlum Washington facility is committed to the prevention of releases of hydrofluoric acid. In the event of a release, the Washington facility is committed to a timely response in accordance with their Preparedness, Prevention, and Contingency (PPC) Plan and the applicable components of this RMP. Accident prevention and emergency response programs are described in this RMP. Worst-Case Scenario and Alternat ive Release Scenario The worst-case scenario for Process No. 1 is a failure of the 70 percent HF storage tank and piping system when filled to capacity. An administrative control (i.e., visual inspection to maintain less than or equal to 90 percent fill volume in the tank) is in place at the facility. A release from this process would be controlled by an acid resistant material diked area that provides secondary containment to accommodate 110 percent of the maximum tank capacity. RMP Comp was used to determine the distance to the toxic end point associated with a worst-case scenario release. According to the modeling results, the distance to the specified end point for a worst-case accidental release scenario associated with this process is 0.43 mile, which is greater than the distance to the nearest public receptor. Approximately 2,200 people reside within the area based on 1990 Census data for the City of Washington and Canton Township. The most likely alternative release scena rio for Process No. 1 is a leak from the piping connected to the HF storage tank. Due to a series of shut-off valves, including one near the storage tank, any leak from the piping would not likely exceed 1/2 gallon per minute and could last as long as 1 hour in certain situations. RMP Comp was used to determine the distance to the toxic end point associated with this alternative release scenario. According to the modeling results, the distance to the specified end point for the alternative release scenario associated with this process is 0.06 mile, which is greater than the distance to the nearest public receptor. Within 0.06 mile of the leak location are 3 residences. It is estimated that 14 people reside within the area. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps The Washington facility has safe job procedures (SJP) in place: ? to evaluate the HF tank capacity and volume already in place before unloading begins; ? to describe the use o f HF in the facility's manufacturing operations; and ? for the inspection of process equipment including the HF tanks, piping, and isolation valves. In addition, the Washington facility trains employees regarding safe job procedures, safe work practices, emergency evacuation and response, and routine and nonroutine work authorization. Finally, the facility maintains the ongoing mechanical integrity of the process equipment. Five-Year Accident History There have been no accidental releases associated with this process since Allegheny Ludlum Corporation purchased the Washington facility. One accident involving 70% hydrofluoric occurred on 01/21/99 while Washington Steel Company owned and operated the facility. One employee was injured in the accident. Emergency Response Program The Washington facility maintains a PPC Plan/Spill Prevention Response/(SPR) Plan. The Washington facility has trained employees for an initial response team. This team will don personal protective equi pment (PPE) and be dispatched to control or stop a minor emergency or an accidental release or help move any employee(s) that has been affected by a 70 percent HF release. If necessary, employees will be evacuated to a safe zone. In addition, the existing emergency response program was prepared in cooperation with the Washington County LEPC. In the event of an emergency where off-site response is appropriate, it will be the policy of the Washington Facility to notify the Washington County 911 Center and/or the Local Emergency Planning Committee (LEPC) and request that they respond to the emergency. A fire, explosion, or other occurrence with the potential to create a release of the regulated substance (HF) from the process may pose a danger to public emergency responders. Public emergency responders will not be permitted to enter this area except as previously arranged with the Primary Emergency Coordinator (PEC) or other designated personnel, as identified within this RMP. Fina lly, the Washington Facility has an equipped emergency control center. The emergency control center is sited in a safe zone and serves as the major communication link between the PEC and plant or corporate management as well as with local community officials. Planned Changes to Improve Safety Allegheny Ludlum Corporation replaced the hydrofluoric acid storage tank prior to start up in February 2000. The new tank was designed to meet the latest industry guidelines for storage of 70% hydrofluoric acid. Responsible Person I, Deborah L. Calderazzo, Manager of Environmental Affairs, have been assigned as the qualified person with the overall responsibility for the development, implementation, and integration of the RMP and subsequent program elements for the Washington facility of Allegheny Ludlum Corporation. Currently, I have the responsibility for implementing the individual requirements of this RMP. Should this responsibility be assigned to another person (or persons) other than myself, the names and positions of these people will be documented and the lines of authority will be defined through an organization chart or similar document.Currently, I have the responsibility for implementing the individual requirements of this RMP. Should this responsibility be assigned to another person (or persons) other than myself, the names and positions of these people will be documented and the lines of authority will be defined through an organization chart or similar document. I certify that, to the best of my knowledge, information and belief, formed after reasonable inquiry, the information submitted here is true, accurate and complete. Name: Deborah L. Calderazzo Signature: Title: Manager, Environmental Affairs Date: 20 June 2000 |