Armco Inc Butler Operations - Stainless Plant - Executive Summary

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1.  Accidental Release Prevention and Emergency Response Policies 
Armco Inc.'s Policy is to fully comply with all applicable environmental laws and regulations.  This includes compliance with EPA's Chemical Accident Prevention Program rules (40 CFR Part 68).   
The Risk Management Plan along with other safety and environmental programs already in-place enables Butler Operations to prevent the occurrence and minimize the consequences of significant releases of hydrofluoric acid, including leaks, spills, and other types of catastrophic accidents. 
Armco's emergency response program is designed to provide rapid response to suspected problems, to keep hazardous materials from being released into the environment, minimize the effects of any spills, and provide proper clean-up and required notifications as soon as possible following any incidents. 
2.  Facility and Regulated Chemical Description 
Armco Inc. - Butler Operations, Stainless Plant is a specialty steel manuf 
acturing facility located on Bantam Avenue in Butler, Pennsylvania.  The facility is subject to the requirements of Chemical Accident Prevention Program rules (40 CFR Part 68) of the Clean Air Act, due to an on-site process containing the regulated chemical, hydrofluoric acid, above the threshold quantity specified by the rules. 
Hydrofluoric acid is stored and used at the facility's steel finishing operations.  It is stored as a 70% water solution in quantities greater than the 1,000-pound regulatory threshold.   
This substance meets the criteria for a Program 2 process as specified in the RMP rules. 
 3.  Worst-Case and Alternative Case Scenario                        
The Worst-case Scenario is an instantaneous release of the entire contents of an 18,000-gallon hydrofluoric acid storage tank into the containment area below the tank.  Application of the containment area as a form of passive mitigation was used in the worst-case release analysis.  The distance to the toxic concent 
ration endpoint of 0.03 mg/L for the worst-case scenario has the potential to result in off-site consequences on a public receptor. 
The Alternative Scenario is the overfilling of the hydrofluoric acid storage tank, which resuts in a release of hydrofluoric acid to the containment area below the tank.  Tank filling operations are continuously monitored by an Armco pipefitter and the truck driver.  The tank level is also verified before any trucks are unloaded.  These control measures along with rapid operator response result in the release being limited to less than 10-minutes in duration.  The distance to the toxic concentration endpoint of 0.03 mg/L for the alternative scenario has the potential to result in off-site consequences on a public receptor. 
4.  Chemical Accident Prevention Program 
Armco Inc. complies with EPA's Chemical Accident Prevention Program rules for hydrofluoric acid solution.  All elements of the Chemical Accident Prevention Program requirements under Part 68 h 
ave been developed and implemented for hydrofluoric acid at Armco Inc. - Butler Operations. 
The hydrofluoric acid system meets the requirements of EPA's Chemical Accident Prevention Program.  The hydrofluoric acid storage tank was designed and constructed following good engineering practices.  A hazard review was conducted for hydrofluoric acid on May 13, 1999 using a hazard review checklist published in Supplemental RMP Guidance for 70% Hydrofluoric Acid Users, December 1998, developed by AlliedSignal Inc. HF Products and all identified potential problems are to be addressed.  Written operating procedures for hydrofluoric acid storage, handling, and transfer are in place.  All persons working with hydrofluoric acid or hydrofluoric acid containing equipment have been trained on the applicable operating and maintenance procedures and the potential hazards of working with hydrofluoric acid.  A preventive maintenance, inspection, and testing program is in place for hydrofluoric acid equi 
pment and operations. 
5.  Five-year Accident History 
One reportable incident involving hydrofluoric acid has occurred within the last five years.  This incident resulted in one worker being exposed to hydrofluoric acid and requiring minor medical treatment.  An incident investigation immediately followed the event and involved all appropriate maintenance, operating and management personnel .  All incident report findings and recommendations were addressed and resolved.  These included recommendations to prevent such occurrences from happening again. 
6.  Emergency Response Program 
Armco Inc. - Butler Operations has trained employees for emergency response and maintains a written emergency response plan.  The plan is coordinated with Butler County (Pennsylvania) Local Emergency Planning Committee (LEPC) and the local Fire Departments.  The Armco response team trains and drills monthly and conduct annual drills for implementation of the emergency response plan at the facility.  The  
emergency response plan includes procedures for notification of local fire department and outside emergency response personnel as needed.  Emergency responders including employees and off-site emergency and fire personnel have copies of the emergency response plan and are familiar with its use.  
7. Planned Changes to Improve Safety 
A comprehensive, above ground storage tank inspection program and review of acid storage tank containment areas is planned during 1999 - 2000 to assure compliance with requirements of the Pennsylvania Above Ground Storage Tank Program Regulations.
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