Commercial Steel Treating Corporation - Executive Summary |
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RISK MANAGEMENT PLAN - EXECUTIVE SUMMARY COMMERCIAL STEEL TREATING CORPORATION MADISON HEIGHTS, MICHIGAN INTRODUCTION Commercial Steel Treating Corporation (Commercial Steel) heat treats metal at its facility located at 31440 Stephenson Highway, Madison Heights, Michigan. An integral part of some of the heat treating process involves the injection of anhydrous ammonia into heat treating furnaces. Anhydrous ammonia is a substance currently regulated under the 40 CFR Part 68, the Risk Management Program (RMP) rule. Commercial Steel has an on-going commitment to regularly assess safety and accident prevention measures and actively strives to meet or exceed all applicable USEPA and OSHA rules and regulations. The accident prevention and emergency response procedures implemented are designed to protect Commercial Steel employees, properties, and the general public to the greatest extent possible. Commercial Steel maintains on-site emergency equipment and trained personnel and has integrated its emergency response procedures with the Oakland County Local Emergency Planning Committee. The designated representative and contact person for environmental matters and this Risk Management Plan at the Commercial Steel facility is Mr. Mark Hoensheid, Emergency Coordinator. He can be contacted at the facility at (248) 588-3300. REGULATED SUBSTANCE HANDLED Anhydrous ammonia in stored at the facility in a single outdoor vessel with a capacity of 10,000 water gallons. In accordance with an air permit issued by the Air Quality Division of the Michigan Department of Environmental Quality, the storage vessel is never filled to greater than 85 percent water capacity (8,500 gallons). The anhydrous ammonia is stored as a liquid under pressure and is used as a vapor. RELEASE SCENARIOS The worst-case release scenario developed for the facility consists of a hypothetical release of the largest quantity of anhydrous ammonia that can be held in the storage vessel at any given time, which is 8,500 gallons (42,000 pounds). In accordance with the requirements of the RMP rule, the release was assumed to occur at a constant rate over a ten minute period, during conservative meteorological conditions. The resulting off-site impact area was estimated using the U.S. EPA's RMP*Comp software system, which predicted the distance to the anhydrous ammonia endpoint to be 2.3 miles. The alternative release scenario developed for the facility consists of a release of 8,000 pounds of anhydrous ammonia, caused by the accidental shearing of a pipe leading from the storage vessel and the subsequent unlikely failure of a safety excess flow valve. It was conservatively assumed that responders would take up to 20 minutes to shut off the flow from the vessel; however, based on the odor threshold for ammonia and emergency response procedures developed for the facility, response to the developed release scenario is anticipated to occur much more quickly. The resulting off-site impact area was estimated using the SLAB model, which was developed by Lawrence Livermore National Laboratory. Under the developed alternative release scenario, the SLAB model predicted the distance to the anhydrous ammonia endpoint to be 2.3 miles. It is important to note that the developed worst-case and alternative release scenarios have never occurred at the facility. FIVE YEAR ACCIDENT HISTORY Commercial Steel has an exemplary record of safety at its facility. Since it began using anhydrous ammonia in 1960 Commercial Steel has never had an accidental release that resulted in deaths, injuries, or significant property damage on site, or off-site deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage. PREVENTION AND EMERGENCY RESPONSE PROGRAMS The prevention of hazards at the facility is achieved through the use of safe operating practices, personnel training, proper facility design in accordance with standard industry practices as well as national building, fire and electrical codes, and daily attention to those areas where preventative measures have the greatest effect. The hazard prevention program describes the features of the storage and distribution system that contribute to continued safe operation. Commercial Steel has developed a written emergency response plan for the facility. The plan includes specific actions to be taken in response to an accidental release at the facility. These plans also outline Commercial Steel's coordination with the Oakland County Emergency Planning Committee and the Madison Heights Fire Department. Commercial Steel personnel receive both classroom and on-the-job training, for both operational and emergency situations. |