Ispat Inland Inc. Indiana Harbor Works - Executive Summary

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The Ispat Inland Inc.'s (Ispat) Indiana Harbor Works (IHW) Facility is an iron and steel manufacturer located in Lake County in northwest Indiana on the shore of Lake Michigan.  The Ispat IHW Facility occupies approximately 2,400 acres. 
Operations at the Ispat IHW Facility began on July 21, 1902.  The primary processes include manufacture of iron in blast furnaces and steel by Basic Oxygen Furnace (BOF) production processes and Electric Arc Furnace (EAF) melting. Finishing operations at the facility include the operation of blooming mills, bar mills, several hot strip mill operations, temper mills, annealing furnaces, coating and cutting and shearing operations. Support facilities include power generation plants; recycle and waste recovery operations; and wastewater treatment. 
The facility is bounded to the west by the Indiana Harbor Ship Canal (also referred to as the Indiana Harbor Canal) and Lake Michigan; to the north and east by Lake Michigan; and to the south 
and southeast by industrial property and Highway 912.  Land use in the vicinity of the Ispat is a combination of industrial, commercial, residential, and recreational areas. 
The Ispat IHW Facility operates under the following General Environmental Policy (ENV-001, 12/15/98): 
It is the policy of Ispat Inland Inc., consistent with the Ispat Inland Inc. Mission & Value Statements, to assign responsibilities for compliance with pollution control rules and regulations as applicable from top management on down through middle management to operating supervisors.  It is the function of management to ensure that the company immediately identifies and responds to developing compliance problems consistent with all regulatory requirements.  To accomplish these objectives the specific company is as follows: 
7 Integrate responsible environmental policies, programs and practices into each business unit as an essential element of management. 
7 Plan, install, maintain and operate facilities in comp 
liance with applicable environmental laws and regulations. 
7 Minimize generation of wastes and promote recycling, recovery and resuse of residual materials to the maximum extent practicable, and dispose of any remaining wastes in an environmentally responsible manner. 
7 Encourage research and development related to environmental-control technologies and more efficient utilization of natural resources, materials and energy. 
7 Participate in the development of technologically sound and cost-effective environmental laws and regulations. 
7 Educate, train and motivate employees to conduct themselves in an environmentally responsible and safe manner. 
At the Ispat IHW Facility chlorine is stored in 2,000-pound cylinders and used for water treatment as a: 
7 Biocide for slime control in process equipment 
7 Growth-inhibitor for zebra mussels 
The storage and transfer (metering into the wastewater treatment systems) process is subject to both the Occupational Safety and Health Administrat 
ion (OSHA) Process Safety Management (PSM) and Environmental Protection Agency (EPA) Chemical Accident Prevention (RMP) regulations. 
The PSM and RMP regulations have many common requirements, however, the RMP requires the facility to estimate the off-site consequences of a hypothetical chemical release in two different scenarios, a "worst case release scenario" and an "alternative release scenario."  A worst-case release, as defined by the U.S. EPA, involves the complete release, over a 10-minute period, of the largest amount of a toxic or flammable chemical from a process at the facility during weather conditions that would allow the release to have the greatest distance of impact.  Additionally, U.S. EPA requires that these distances be calculated assuming that none of the active mitigation systems that could minimize the effects of the release would be used and that no emergency actions to stop or minimize the release would be taken. 
Under these stringent and highly unlikely requi 
rements, the worst-case release scenario for Ispat Inland would involve the release of 2,000 lbs. of chlorine from storage.  According to computer modeling, harmful effects from this hypothetical release could reach 2.8 miles.  
A "worst case release" scenario might affect the following receptors: 
Public Receptors include:7 45,000 people,7 Mixed industrial and commercial properties,7 Parks, hospitals, schools, a marina, a hotel/casino, and offices.                                                                                                                                                           Environmental Receptors include: Wolf Lake Park, the wetland located northeast of the intersection of 129th Street and New York Avenue and the wetland located south of the Grand Calumet River, north of the Indiana East-West Toll Road, west of S.R. 912 and east of Indianapolis Boulevard.                                                                  
The alternative release scenario is con 
sidered to be more realistic and of greater use for emergency planning and accident prevention than the worst-case release scenario.  In keeping with the more realistic nature of these scenarios, facilities are allowed to consider how their mitigation systems and emergency response procedures would affect the amount of chemical released.  The area affected under an alternative release scenario was calculated to be within a 0.41-mile radius of the hypothetical chlorine release. 
An "alternative release" scenario might affect the following receptors: 
Public Receptors 
7 1,500 people 
7 Mixed industrial and commercial properties 
7 Some residential areas 
Accident Prevention 
In order to prevent accidents, Ispat has implemented a comprehensive safety program that incorporates multiple layers of safety.  Those layers of safety involve engineering controls, operating practices and management review.  The following table summarizes the layers of safety in place at Ispat. 
ss and Technology  
   ' Rigorous Compliance with Standards (including Process Safety Management) and Codes 
   ' Structured Hazard Analysis 
   ' Comprehensive Preventive Maintenance 
Safety and People  
   ' Documented Operating Procedures 
   ' Ongoing Employee Training 
   ' Strict Contractor Rules 
   ' Employee Participation 
Management and Support Program  
   ' Management of Change 
   ' Incident Investigation 
   ' Periodic Compliance Audits 
Five-Year Accident History 
Ispat Inland has experienced no accidents required to be reported in the Five-Year Accident History. 
The Ispat has developed a sophisticated emergency response capability.  The fundamentals of the emergency response program are early detection, prompt effective communications and source control.  The elements of the emergency response program for chlorine include: 
' Chlorine leak sensors linked to alarms 
' 24-hour monitoring of alarms 
' Documented communication/reporting procedures 
' Trained Emergency Response Team 
' Extensive Emergency Response Equipment maintained on-site
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