Trent Tube - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: The Trent Tube, East Troy, Wisconsin facilities utilize Hydrofluoric Acid (70% by weight) (HF) as a pickling agent for stainless steel tube. Trent Tube is committed to ensuring that HF is stored and handled in a safe manner. We have conducted hazard reviews of the HF process to ensure that our installations are in compliance with Federal, state and local codes, standards, and generally accepted good engineering practice and reviewed maintenance and operating procedures to enhance safety. Employees and contractors who are involved in storing and handling HF have been trained in safe storage and handling procedures. In case of an accidental release of HF, it is Trent Tube's policy to notify the Village of East Troy, Emergency Services and Superior Special Services (contract agreement for spill response) so that they can respond to the emergency. Trent Tube has procedures in place to notify the appropriate emergency serv ices in case of an accidental release. FACILITY DESCRIPTION AND THE REGULATED SUBSTANCES HANDLED: The primary purpose of Trent Tube's East Troy, Wisconsin facilities are is to manufacture stainless steel tube of varying diameters and lengths. Stainless steel sheet stock is formed, rolled and welded into tubing. In order to pickle the finished tube, lengths of tubing are dipped into a solution of HF (2%-5%), Nitric Acid and water. After pickling, the tubing is inspected, rinsed and bundled for shipping. There are two HF (70% by weight) storage tanks at two different locations within the site. The Plant 3 (Energy Drive) HF storage tank is 6,300 gallons in capacity and is located outside the south-west corner of the building. The Plant 2 HF tank is 6,300 gallons in capacity and is located outside the south-west corner of the building. Both buildings are on contiguous properties and are considered a single source. The RMP regulated substance at the East Troy, Wisconsin facility i s Hydrofluoric Acid (70% by weight). THE WORST-CASE AND ALTERNATE RELEASE SCENARIOS: The Worst-Case Release Scenario for HF is mandated in the RMP rule (40 CFR 68.25) to be the instantaneous release of the entire contents of the largest single storage vessel, to form a liquid pool. There is a containment dike that will contain the entire contents of the largest spill, therefore, evaporation occurs over the surface area of the containment dike. The Environmental Protection Agency's Off-Site Consequence Analysis Guidance (OCAG) formulas and tables were used to determine a rate of evaporation of the spilled pool. The OCAG provided atmospheric, topographic and process parameters in order to estimate the distance that the evaporated pool of HF liquid would disperse to the surroundings. The dispersion distance specified by the RMP rule is the distance to the ERPG-2 (Emergency Response Planning Guideline -2). The ERPG-2 is a number estimated by the American Industrial Hygiene Associati on to be the concentration of HF that is believed nearly all individuals could be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair their ability to take protective action. The worst case ERPG-2 impact areas for both HF storage tanks were determined to be a circle, centered on each storage tank, with radii equal to the ERPG-2 distance. The impacted area for the Plant 3 HF storage tank is a circle with a radius of 0.60 miles. There are public receptors within this area. The impacted area for the Plant 2 HF storage tank is a circle with a radius of 0.40 miles. There are public receptors within this area. Both worst-case release distances are reported because different public receptors are affected. The Alternate Release Scenario for HF is one that is more likely to occur than the Worst-Case Release Scenario. The distance to the endpoint (ERPG-2) is computed using more typical atmospheric conditio ns. A number of alternate release scenarios were considered. The scenario chosen for analysis was a failure of an HF transfer hose or fitting during the delivery of HF to a storage tank. There are two trained delivery personnel in attendance at all times during delivery. These persons are equipped with personal protective equipment and could reach critical shut off valves within 20 seconds time. HF would be spilled on the ground both from the storage tank and delivery truck. The distance to the ERPG-2 endpoint was computed using the OCAG and dispersion data supplied by Allied Signal. The impact area for both HF storage tanks (Plants 2 and 3) was calculated by a circle with a radius of 0.20 miles. There are public receptors within this area. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS: Trent Tube's facilities are in compliance with the USEPA's Accidental Release Prevention Rule (40 CFR 68). The HF equipment was installed according to guidelines provide by the Hyrdrogen Fluoride Industry Practices Institute. HF delivery hoses are wire reinforced, inspected before and after each use and replaced annually. Both HF storage tanks have been thickness tested. THE FIVE YEAR ACCIDENT HISTORY The Trent Tube, East Troy, Wisconsin site has not experienced a release of Hydrofluoric Acid in the last five years that caused deaths, injuries, property or environmental damage, evacuations, or sheltering in place. THE EMERGENCY RESPONSE PROGRAM In the event of an emergency involving hydrofluoric acid, it is Trent Tube's policy to notify the Village of East Troy, Wisconsin, Emergency Services and Supperior Environmental Services, Inc., our designated spill response contractor, and let them respond to the emergency. We have discussed this policy with the Emergency Serv ices. PLANNED CHANGES TO IMPROVE SAFETY None at this time. |