US Steel Clairton Works - Executive Summary |
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U. S. Steel Clairton Works EPA Risk Management Program RMPlan Executive Summary The Clairton Works of the U. S. Steel Group of USX Corporation is located in Clairton, Allegheny County Pennsylvania. The facility is located 20 miles south of Pittsburgh on 392 acres along 3.3 miles of the west bank of the Monongahela River. USXs Clairton Works manufactures metallurgical coke in chemical recovery ovens. The facilitys standard industrial classification (SIC) code is 3312. Coal received from barges or the plant coal storage piles is blended, pulverized and conveyed into storage bunkers in the coke battery area of the plant. In the coke ovens, coal is heated in 12 to 25 ton batches in the absence of air for approximately 18 hours at 2000 degrees F, yielding metallurgical coke, coke oven gases and various coal chemicals. When the coking process is complete in an individual oven, the contents are pushed into a railroad-quenching car. The quench car is moved to one of a number of q uench towers where the coke is cooled with river water. The coke is conveyed to screening stations where it is sized prior to being shipped. During the coking process, coal volatiles exit the ovens through ascension pipes and goosenecks and are collected in overhead mains running the length of each coke oven battery. These hot gases withdrawn under vacuum are initially cooled by spraying with recirculated flushing liquors. Most of the tar in the raw gas drops out with this initial cooling. Condensed tar and flushing liquor flow into decanter tanks where the tar is separated from the water phase. The excess flushing liquor, which is the result of both water and inherent moisture in the coal, is the major single source of contaminated water from the coke plant. The recovered tar is sent to various customers to be processed into various tar products. The partially cooled gas is then passed through direct contact primary coolers, coke oven gas compressors and final coolers. After the final coolers, ammonia is removed from the gas by scrubbing with a recycled solution of ammonium phosphate in the PHOSAM process and fractionated into anhydrous ammonia. Following the PHOSAM system, the coke oven gas is further processed by a computer controlled, cryogenic system, where the gas is cooled to an extremely low temperature, into several specific streams. The separation provides two clean fuel steams used for the coke oven batteries and down river fuel system. Approximately 40 percent of the coke oven gas is used for underfiring the coke ovens and the remainder is used for steam generation and heating purposes at USXs Mon Valley Plants. A third process stream separates out light oil and acid gases. After the light oil is removed, this portion of the coke oven gas is processed for the removal of hydrogen sulfide in a conventional carbonate absorption and vacuum stripping system. The light oil recovered in the cryogenic system is sent to a storage area for shipmen t to refiners. The contaminated process waters from the Clairton complex are collected and sent to a contaminated water treatment system for the removal of contaminates prior to discharge into Monongahela River. This system includes settling tanks, ammonia stills and a biological treatment system. Clairton Works has submitted a CAA Title V application for an operating permit, but has not received an operating permit number from Allegheny County. The following chemicals and their associated processes fall under the requirements of the EPAs Risk Management Program because they contain quantities greater than the thresholds: Anhydrous Ammonia Prevention Program - 3 Coke Oven Gas Prevention Program - 2 Anhydrous Ammonia is a corrosive, colorless gas with a penetrating, suffocating odor of household ammonia. It is lighter than air and non-flammable. The vapors can be irritating and harmful to the eyes, respiratory system and skin. Under pressure, anhydrous ammonia is a colorless liquid and is transported as a liquid. Anhydrous ammonia is used as a household cleaner; fertilizer; refrigerant for cold storage and used in the manufacture of pharmaceuticals. Coke Oven Gas (COG) is a mixture of hydrogen, methane, carbon monoxide and small amounts of other gases that evolve out of coal during its destructive distillation into coke. COG is lighter than air, flammable and toxic. The more hazardous gases are carbon monoxide, methane, hydrogen, ammonia, hydrogen sulfide, hydrogen cyanide, and benzene. Raw COG has an orange to brown color. As the COG is processed, it becomes a colorless gas with a slight sulfide odor. After processing, coke oven gas is used as a fuel on the coke batteries, boilerhouse, blast furnaces and heating purposes in the Mon Valley Plants. Clairton Works developed and implemented the risk management practices associated with OSHAs Process Safety Management regulation, 29 CFR 1910.119. The U. S. Steel Group adopted a Statement of Policy concerning Environmental Management in October of 1991. In the Environmental Management Policy, U. S. Steel Group emphasizes its commitment to leadership and stewardship in protecting the environment and the intent to comply with all applicable environmental laws and regulations. The policy also seeks to reduce waste and achieve minimal adverse impact on the air, water and land through programs, which incorporate responsible environmental management. The statement stresses that environmental protection is a primary responsibility of every employee. In May 1998, the USS Clairton Works Environmental Management System became certified to the ISO 14001 standard empathizing this commitment. The safety program of the U. S. Steel Group, H.E.L.P. (Hazard Elimination Loss Prevention) is a management system for loss prevention and control. The H.E.L.P. program is based on three loss prevention and control strategies: 7 Identify threats 7 Determine the causes of threa ts 7 Eliminate the causes of threats A threat is any action or condition that has the potential to result in loss. The H.E.L.P. program is compatible and interrelated with Clairtons risk management principles and objectives. U. S. Steel Clairton Works has three Emergency Response Plans. These Emergency Response Plans provide: 7 a logical, systematic procedure to combat and control minor and major emergency situations. 7 plans to prevent the accidental discharge of hazardous, toxic or polluting substances to the environment and to minimize and abate hazards to human health and the environment from fires, explosions or other releases of substances. Each emergency response program is described in more detail below. The following is a description of the worst-case release scenario(s) and the alternative release scenario(s) including administrative controls and mitigation measures to limit the distances for each reported scenario for anhydrous ammonia and coke oven gas. Anhydrous A mmonia Worst-Case Release Scenario A catastrophic failure of an ammonia rail car would release 75 tons of anhydrous ammonia. The vapor cloud would travel 4.5-mile radius from the plant. Anhydrous Ammonia Alternative Release Scenario A failure of the relief valve on an ammonia rail car would release 6 tons of anhydrous ammonia. The vapor cloud would travel 0.95 mile. Anhydrous Ammonia Administrative Controls and Mitigation Measures Operating personnel associated with the loading and handling of ammonia railcars are DOT trained. Ammonia sensors, with alarms, are located in strategic areas in the PHOSAM process, ammonia loading area and ammonia storage area. An on-site HAZMAT response team is equipped with emergency response apparel and equipment to mitigate a release from an ammonia railcar or piping system. Ammonia railcar connections have fast flow check valves to reduce the flow of ammonia from the railcar in case of a loading line failure. Ammonia railcars being loaded ca n be vented into the coke oven gas suction mains. There is a flare stack at ammonia storage for combusting ammonia liquid or vapors vented from a railcar. Fire hydrants are equipped with turret nozzles that supply a curtain of water to suppress ammonia vapors associated with a release. Coke Oven Gas Worst-Case Release Scenario A catastrophic failure of the COG piping from No. 2 CR to the Wabash Gate would release 1,400 lbs. of COG resulting in a vapor cloud explosion. The 1 psi overpressure wave would travel 0.1 miles from the release location. Coke Oven Gas Alternative Release Scenario A failure of an igniter (flare stack) on one of the coke oven batteries would release 470 pounds of COG per minute. The hydrogen content of Coke Oven Gas results in a rapid dispersion of this type of release. Coke Oven Gas Administrative Controls and Mitigation Measures Operating personnel attend CITE training and CITE II process specific training. All coke oven batteries are equipped with igniters (flare stacks) that combust any coke oven gas releases from the battery collector mains. The oven igniters (flare stacks) are tested weekly for proper operation. The oven igniter pilots are visually observed each turn. A redundant power supply was installed for the coke oven gas compressors and their associated controls. Clairton Works utilizes the risk management practices that were developed to comply with OSHAs Process Safety Management regulation, 29 CFR 1910.119, for complying with the requirements of the EPAs Programs 2 and 3 Prevention Programs. The requirements of each PSM element are described in PSM Administrative Procedures. The PSM system at Clairton Works applies to all covered processes as defined in the applicable OSHA PSM and EPA RMP regulations. Implementing and maintaining the requirements of the PSM Administrative Procedures assist in meeting the requirements of the EPA Risk Management Program (RMP) 40 CFR Part 68, Subpart C Program 2 Prevention Program (Sections 68.48 Safety Information through 68.60 Incident Investigation) and Subpart D - Program 3 Prevention Program (Sections 68.65 - Process safety information through 68.87 - Contractors). The Manager Process Safety has the responsibility for ensuring that Clairton Works has an integrated, effective, and compliant prevention programs that meet the EPAs RMP rule Subpart C Program 2 Prevention Program (Sections 68.48 Safety Information through 68.60 Incident Investig ation) and Subpart D - Program 3 Prevention Program (Sections 68.65 - Process safety information through 68.87 - Contractors) and Department of Labor (OSHA) 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals (PSM). Although the Manager Process Safety has some specific individual responsibilities within the PSM Compliance Plan, many of the responsibilities for specific program elements are assigned to other Clairton Works members as defined in the individual PSM Administrative Procedures. In the past five years, Clairton Works has had no accidental release of coke oven gas and two accidental releases of anhydrous ammonia as defined by the RMP rule. None of the releases had any impact on the community. On December 12, 1996, approximately 120 lbs. of anhydrous ammonia were released over a 1.5 minute time frame from an ammonia loading hose. On August 8, 1998, an ammonia railcar relief valve malfunctioned releasing 4.5 tons of ammonia over a 37 minute time fram e. U. S. Steel Clairton Works has three Emergency Response Plans. Each emergency response program is described below. The Major Emergency Plan provides a logical, systematic procedure to combat and control minor and major emergency situations. The plan establishes step by step procedures to be taken in the event of an emergency. It includes: 7 Pre-emergency planning and coordination with outside parties; 7 Personnel roles, lines of authority, training and communications; 7 Emergency recognition and prevention; 7 Safe distances and places of refuge; 7 Site security and control; 7 Evacuation routes and procedures; 7 Emergency medical treatment and first aid. The Environmental Emergency Response Plan (EERP) incorporates several emergency response plans required by various regulatory requirements. Many of these plans are similar in purpose and organizations and have therefore been incorporated into one comprehensive structured plan. The EERP is a consolidation of: 1. The Prepare dness, Prevention and Contingency (PPC) Plan; 2. Community Emergency Response Plan; 3. Spill Prevention, Control and Countermeasure (SPCC) Plan; 4. Spill Prevention and Response (SPR) Plan and; 5. Early Warning Plan required by the Benzene Consent Order and Agreement. In addition, the PM-10 Emergency Action Plan is included in the EERP. The overall purpose of the EERP is to prevent the accidental discharge of hazardous, toxic or polluting substances to the environment and to minimize and abate hazards to human health and the environment from fires, explosions or other releases of substances. The EERP addresses hazards caused by leaks, spills, floods, fires, power failures, mechanical failure and human error. It also includes such items as preventive maintenance, housekeeping, security, inspections, training, communication systems and evacuation plans. The provisions of this plan are to be carried out immediately whenever there is a fire, explosion, emission or discharge, which w ould threaten human health or the environment. The Off-Site Response Plan was developed in accordance with the provisions of the Superfund Amendments and Reauthorization Act of 1986 (SARA) Title III; the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA) and the Hazardous Material Emergency Planning Committee for the Emergency Planning District of Allegheny. It was written in conjunction with the emergency planners at the Clairton Works facility and represents the cooperative efforts of both the community and industrial planners in response to hazardous material emergency at the facility. The Off-Site Response Plan consists of the following: 1. Situation 2. Release Response Procedures 3. Evacuation Procedures 4. Training Exercises 5. Plan Maintenance/Review The following Attachments are included in the Off-Site Response Plan: 7 Emergency Release Notification 7 Tier Two Emergency and Hazardous Chemical Inventory 7 Emergency Notification List 7 E mergency Alert System (EAS) Message 7 Facility Site Maps 7 Evacuation Shelter Routes 7 Evacuation Map 7 Facility Hazardous Materials Location 7 Municipal Equipment Resources 7 Facility Equipment Resources Clairton Works has conducted a Process Hazard Analysis for each regulated substance. Continuous improvement efforts will be realized by addressing and implementing the recommendations for the PHAs, such as installing remote controlled shut-off valves on the anhydrous ammonia transfer and loading pipeline. Clairton Works will continue to direct its risk management efforts through the PSM Steering Team. This body has assumed the responsibilities for addressing the risk management requirements of the EPAs Risk Management Program. Workforce employees and management personnel attend the CITE (Continuous Improvement to the Environment) process overview training programs. CITE II training modules were developed that provides operators with detailed process specific training. Additi onal training such as RCRA and Industrial Hygiene training will continue on a yearly basis. |