LTV Steel, Aliquippa Works - Executive Summary |
|
EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies: This facility uses hydrogen in its manufacturing processes and chlorine in water treatment. Both of these materials are considered hazardous by the Environmental Protection Agency. The materials are considered hazardous because hydrogen is a flammable liquid/gas and chlorine is a toxic liquid/gas. As these materials are hazardous, it is necessary to observe certain safety precautions in handling them to prevent unnecessary human exposure, to reduce the threat to our personnel, and to reduce the threat to nearby members of the community. It is the policy of LTV Steel to adhere to all applicable federal and state rules and regulations. LTV Steel will help ensure safety through proper operation and maintenance of the facility, use of safety devices inherent in the design of the processes, and through proper training of personnel. The facility emergency response program consists of a written emergency response plan, which includes emergency action plans for both hydrogen and chlorine. This plan is the Preparedness, Prevention and Contingency (PPC)/Spill Prevention Control and Countermeasure (SPCC) Plan/Spill Prevention and Response (SPR) Plan. In addition, LTV Steel has an Off-Site Response Plan developed in cooperation with the Local Emergency Planning Committee of Beaver County. This plan was developed in accordance with the provisions of "Superfund Amendments and Reauthorization Act of 1986", (SARA Title III). These plans include procedures for notification of the local emergency response agencies as well as any potentially affected neighbors. 2. The stationary source and regulated substances handled: LTV Steel, Aliquippa Works, manufactures tin plate from carbon steel coils. The facility consists of Cleaning, Continuous Annealing, Batch Hydrogen Annealing, Cold Rolling, and Electroplating. There is also Process water treatment and Process wastewater treatmen t. Hydrogen is used as a pure gas in the Batch Hydrogen Annealing process and as a hydrogen-nitrogen mixed gas in the Continuous Annealing process. Chlorine is used to treat incoming process water. The regulated substances handled at this facility are hydrogen and chlorine. Hydrogen is stored as a liquid in two 9,800 gallon tanks, interconnected and in one storage area. The quantity stored in each tank is limited to 280 inches of liquid which corresponds to 6592.68 gallons or 3955.56 pounds. The maximum amount of hydrogen on-site is 7911.12 pounds. Chlorine is stored in one-ton cylinders in two locations. There is storage capacity for 18 cylinders. The maximum amount on-site is 36,000 pounds. 3. The worst-case release scenarios and the alternative release scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario. Hydrogen Worst-case Scenario - Failure of one hydrogen tank when each tank is filled to t he greatest amount. This failure could be expected to create an explosion resulting in the failure the second hydrogen tank. This scenario would result in the release of 7911.12 pounds of hydrogen. It is assumed that the entire contents of the tanks are released as vapor which finds an ignition source. 10% of the released quantity is assumed to participate in the resulting explosion. The distance to the endpoint of 1 psi over pressure for the worst-case scenario is 0.20 miles based on the TNT-equivalency method. Alternative Scenario - Rupture of the one inch hydrogen feed line from the storage area results in a vapor cloud explosion. The line is regulated to 100 psi and should be considered to be at 70.0 F. The distance to the endpoint of 1 psi over pressure is 0.05 miles. Chlorine Worst-case Scenario - Failure of a full one-ton cylinder of chlorine. This scenario would result in the release of 2000 pounds of chlorine. It is assumed that the release takes place over a 10 minute period. The distance to the toxic end-point of 0.0087 mg/L for this worst-case scenario is 1.3 miles. Alternative Scenario - Rupture of the < inch chlorine feed line leading from a cylinder to the chlorinator. The release takes place at an air temperature of 800 F. The release rate would be 7.06 pounds per minute. It is assumed that the release takes place over a 30 minute period. The distance to the toxic end-point of 0.0087 mg/L for this scenario is 0.10 miles. 4. The general accidental release prevention program and the specific prevention steps. This facility has developed Process Safety Management Plans for both the hydrogen systems and the chlorine systems and is in compliance with Process Safety Management requirements as found in 29 CFR 1910.119. Facility personnel are trained in emergency response to chlorine releases. The facility is in the process of upgrading area monitoring and automatic shut-off systems for the hydrogen system. 5. Five year accident history. There have been no accidental releases from the hydrogen system or the chlorine system as defined by this regulation. 6. The emergency response program. LTV Steel has established and implemented an emergency action plan for the entire facility. This plan is the Preparedness, Prevention and Contingency (PPC) Plan / Spill Prevention Control and Countermeasure (SPCC) Plan / Spill Prevention and Response (SPR) Plan. The plans are located in Environmental Control. In addition, an Off-Site Response Plan has been developed in accordance with SARA Title III. This plan was developed in coordination with the Local Emergency Planning Committee of Beaver County. The plans are located in Environmental Control. In accordance with the Off-Site Response Plan, annual table top exercises for all responders and agencies involved in hazardous materials operations have been conducted. Public notification of accidental releases which may impact off-site popula tions are provided for through Emergency Broadcast System announcements over local radio stations. 7. Planned changes to improve safety. This facility has planned improvements to the release monitoring and alerting system for the hydrogen and automatic cut-off system for the hydrogen. |