LTV Steel Co., Chicago Works - Executive Summary

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The Risk Management Plan (RMP) for LTV Steel's Chicago, Illinois Works was prepared in response to section 112(r) of the Clean Air Act.  The plan addresses the requirements outlined in 40 CFR 68.155 thru 68.185 and appendix A. 
1.  Accidental release prevention and emergency response: 
LTV Steel Company's Chicago Coke Plant produces approximately 600,000 tons of coke annually by the destructive distillation of bituminous coal at its  by-product coking facilities located on the southside of Chicago.  The coke making process at LTV includes a coke battery ( 60 ovens ) and an associated by-product plant to process off-gases generated during the coking cycle.  One ton of coal yields approximately 65% coke and 35% by- products. 
The by-product plant contains a series of vessels which extract various components of the off-gases which are generated during the 18 hour coking cycle per oven at the battery.  The three major components collected from the by-produc 
t operations are coal tar, light oils and ammonium sulfate crystals.  These products are sold commercially and the remaining clean gas is combusted at the battery to provide heat for the ovens. 
Approximately 400 tons of aqua ammonia  solution ( 28% by wt.) is used annually in the desulfurization portion of the by-product plant.  This solution can be hazardous if released to the environment and must be handled safely to reduce the threat of unnecessary exposure  to LTV personnel and to members of the nearby community.  
It is the policy of LTV Steel to comply with all applicable federal, state and local regulations.  LTV Steel helps to ensure the safety of the community and its workforce by properly operating and maintaining its facilities, use of safety devices inherent in the design of the processes, and through proper training of personnel. 
The facility emergency response program is written and includes emergency action plans for various scenarios including chemical spills.  This p 
lan is a part of the off-site response plan on file with the Chicago Fire Department who serves as the representative of the Local Emergency Planning Committee.  These plans include procedures for notifying governmental agencies as well as any potentially affected neighbors. 
2.  The staionary sources and regulated substance: 
The Chicago Works processes the off-gases generated during the coking cycle through a series of vessels in its by-product plant.  Several commercial products are made at the by-product plant including coal tar, light oils and ammonium sulfate.  Aqua ammonia  solution is used in the Hirohax and crystallizer portion of the gas cleaning train. 
Aqua ammonia solution is delivered to the plant via commercial tank trucks and is unloaded into a 14,000 gallon tank near the stills.  The product is metered to the process thru piping, valves, pumps and regulators;  and is a closed system.  The by-product system is monitored continuosly thru its computerized command center a 
nd inspected at least once a day. 
3.  The worst-case and alternate release scenarios: 
Worst case scenario -  Failure of the storage tank resulting in a complete release of 14,000 gallons of aqua ammonia solution ( 28% by wt. ) or approximately 106,000 pounds onto the ground in ten minutes. 
The distance to the toxic end-point of 0.14 mg/l for this scenario is 0.8 miles. 
Alternative scenario - Rupture of a 2 1/2" pipe at the storage tank which would result in a release rate of 2000 pounds/min. for an estimated time of 15 minutes. 
The distance to the toxic end-point of 0.14 mg/l for this scenario is 0.2 miles. 
4.  The general accidental release prevention program and the specific prevention sreps: 
The facility has developed a plan similar to a Process Safety Management Plan for the various operations at the plant.  Frequent inspections are made on all applicable equipment and repairs are made promptly when a condition is found that may create a risk of a release. 
5.  Five year Acc 
ident History: 
There have been no releases from the aqueous ammonia tank in the last five years. 
6.  The emergency response program: 
LTV'S Chicago Works has an emergency response plan which covers the entire facility.  This plan is on file with the Chicago Fire Department which represents the Cook County Local Emergency Planning Committee. 
7.  Planned changes to improve safety: 
The facility constantly reviews its equipment, operating procedures, and personnel training and makes changes necessary to improve safety and decrease risk promptly.  Currently a process change which would result in eliminating the concentrated aqueous ammonia is under evaluation.  Also, changes in the current diking is under consideration.
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