U.S. Steel Group - Fairless Works - Executive Summary

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U.S. Steel owns and operates a carbon steel finishing mill and associated support operations in Fairless Hills, Pennsylvania which is subject to U.S. EPA regulations governing Accidental Release Prevention (ARP) Requirements: Risk Management Programs under Section 112(r) of the Clean Air Act (40 CFR Part 68).  This Risk Management Plan (RMP) has been developed in accordance with the requirements specified under 40 CFR Part 68, Subpart G.  The RMP certifies that U.S. Steel has instituted a Risk Management Program for anhydrous sulfur dioxide at the Fairless Works that is in compliance with U.S. EPA ARP requirements.  
The RMP includes an Executive Summary and Data Elements following the format published by U.S. EPA.  In addition to identifying the applicable corporate policies and risk management systems, the RMP identifies a set of worst case and alternative release scenarios, the potential off-site consequences of those releases, and the facility's five-year accidental r 
elease history.  This RMP certifies that prevention and emergency response programs are in place so as to minimize risks to both workers and the potentially affected public. 
Accident Release Prevention Program and Emergency Response Policy 
It is the policy of U.S. Steel Fairless Works management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68.  The objective is to minimize the risk of a release of a hazardous material  and if a release occurs, to minimize the potential impact to USS employees, the public and the environment. 
This objective will be accomplished by utilizing good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers.  U.S. Steel's management is committed to providing the resources necessary to implement this policy.  Further, the Fairless Works recognizes that it has a duty to 
protect its employees and neighbors from the effects of dangerous chemicals.   
The Fairless Works has developed a management system to implement and maintain compliance with the ARP Program and related OSHA Process Safety Management and emergency response programs.  At the Fairless Works, the General Managers have primary responsibility for ensuring overall implementation and compliance with these programs.  Other individual employees such as the Senior Environmental Manager, Safety, Security, Environmental Health and Industrial Hygiene Manager, Realty Utilities Manager, and the Manager of the operating areas are responsible for the technical implementation of individual sections of these programs. 
Facility Description 
The U.S. Steel Fairless Works facility in Bucks County, Pennsylvania is classified by the North American Industrial Classification System (NAICS) as industry number 33111, (Iron and Steel Mills) which includes rolling and finishing mills such as those at the Fairless 
Works.  The Fairless Works receives plain carbon steel coils and performs one of several finishing processes on the coils.  Finishing processes are commonly referred to as secondary steel processes.  At the Fairless Works, the steel coils are prepared for finishing by first removing the scale and rust from the outer surface of the coil in the continuous pickling lines.  The steel coils are then cold rolled to the prescribed thickness.  The finishing process continues at the tempering, annealing, galvanizing, tinplate and tin-free steel lines.  The finishing processes are independent units that are operated based on customer demand for each of the finished product types.  The primary products of the Fairless Works include galvanized, tin plate, and tin-free steel coils for the automotive, durable goods, steel-processing, fabricating, and canning industries.  
The Fairless Works uses a number of hazardous compounds at the site; including both toxics and flammables.  Of these, anhydrous  
sulfur dioxide, which is used in a chrome reduction treatment process at the Finishing Mill Waste Water Treatment Plant exceeds the ARP threshold amount and is therefore considered a regulated substance for the Risk Management Program.  Other hazardous compounds that are used at the site are either not of sufficient quantity to be regulated or are found at such a concentration that they are exempt from the RMP regulations.  
Process Description 
Anhydrous sulfur dioxide is used in the Finishing Mill Waste Water Treatment Plant to reduce hexavalent chromium to trivalent chromium in process waste water streams. The anhydrous sulfur dioxide is delivered by tank truck as a liquid and stored in a 5,000 gallon pressurized tank. The facility maintains an administrative control which limits the maximum amount in the tank to 4,500 gallons (53,820 pounds). Prior to use in the waste water treatment process, the liquefied sulfur dioxide is evaporated to a gas and injected into a mixing chamber wit 
h the waste water from the finishing mill. Process area external sensors and an alarm system are maintained in the storage area to immediately alert facility personnel to a leak.  
Program Level Identification 
The EPA Risk Management Regulation identifies three levels of requirements defined as "programs".  EPA recognizes that some regulated processes would not pose an off-site hazard in the event of an accidental release.  Such processes are classified as Program 1.  Program 1 is applicable to any process for which it can be demonstrated that the public would not be adversely affected by a release.  Thus, to qualify for Program 1, a facility with a regulated toxic chemical needs to meet two criteria. 
* no release over the most recent 5-year period has resulted in off-site injury or environmental damage; and  
* dispersion modeling demonstrates that a worst-case release (as defined by the regulation) will not result in concentrations at public receptors that exceed the toxic endpoint 

The Fairless Works has not had an accident or release involving the anhydrous sulfur dioxide process in the past 5 years.  However, the worst-case release, as defined by the regulation, results in concentrations at public receptors that exceed the toxic endpoint.  Therefore, the anhydrous sulfur dioxide process is not eligible for Program 1. 
Programs 2 and 3 are applicable to processes that do not qualify for Program 1.  Program 2 applies to any process that is ineligible for Program 1 and is not subject to Program 3.  Program 3 applies to all processes  that are subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM).  Standard. The anhydrous sulfur dioxide process at the Fairless Works is subject to the OSHA PSM Standard and therefore Program 3.  The Fairless Works Accident Prevention Program elements are adopted directly from the compliance program for the PSM standard, consistent with the Program Level 3 RMP Program requirements under 
40 CFR Part 68.  Program 3 related information is included in the Data Elements section of the Risk Management Plan. 
Worst-Case and Alternative-Release Scenarios 
The RMP regulations require that each facility identify worst-case and alternative case release scenarios.  For the purposes of developing and maintaining adequate Risk Management Plans, the EPA has defined in its governing rules and guidance a series of modeling methods and assumptions, which are to be used as administrative guides for planning purposes.  In order to standardize and simplify the many factors that can potentially occur in an accidental release situation, some of these assumptions may not take into account the available preventive measures or mitigation methods that could diminish or even eliminate the implied risks that are suggested by "worst-case" analyses.  For that reason, both the results for the standardized "worse-cases" defined by the EPA methods and a set of alternative cases which are believed by  
the Fairless Works to more realistically represent situations that may possibly, but rarely, occur within the lifetime of the facility are also presented. 
EPA has defined a worst-case release as the instantaneous release of the entire contents of the largest vessel or connected piping that contains a regulated substance.  For toxic gases such as sulfur dioxide stored under pressure at ambient temperatures, it is assumed that the release occurs over a 10-minute period. 
The release event is then evaluated using modeling techniques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure).  The distance to the endpoint is affected by several factors including molecular weight, volatility, heat of combustion, and physical setting (urban or rural). 
EPA has established "toxic endpoints" for various chemicals based on the American Industrial Hygiene Association (ACGIH) Emergency Response Planning Guideline, Level 2 (ERPG-2), which protects indiv 
iduals from health-threatening or escape-impairing injury.  The ERPG-2 is defined as: 
    "the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hr without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action." 
Given that the worst-case release scenario is a 10-minute release duration with a 10-minute concentration averaging time, the actual hazard zone is typically overestimated by the ERPG-2.  Within such a time period, there are a number of emergency measures that can reduce or eliminate exposures to levels this high for an interval much shorter than an hour. 
Under Section 68.22 (e), the RMP rule identifies "surface roughness" as a parameter to be specified in the hazard assessment.  The surface roughness affects the amount of dispersion that occurs within a released plume and influences the distance to toxic endpoin 
t.  The surface roughness used in determining the distance to toxic endpoint should be characteristic of the transport path of the plume from the release point to the endpoint distance.  'Urban' surface roughness indicates areas where there are many obstacles, such as buildings or trees.  'Rural' indicates that there are no buildings in the immediate vicinity of a facility and that the terrain is generally flat and unobstructed. 
In the immediate vicinity of the Fairless Works, the aerodynamic surface roughness is 'urban' in nature, due to the many large buildings, tanks and other structures at the site.  At greater distances, the surface roughness is a mixture of both urban and rural.  For the worst-case scenario analysis, which used the DEGADIS model, a 50 cm surface roughness was assumed. For the alternative release analysis, which used EPA RMP*COMP(tm) model, urban surface roughness was used. 
Worst-Case Release Scenario 
The DEGADIS (Dense Gas Dispersion) model was used to simulat 
e the worst-case release scenario.  The DEGADIS model is a publicly available model that simulates contaminant movement for heavier-than-air gases such as sulfur dioxide for instantaneous and continuous ground level releases.  
The worst-case scenario for the Fairless Works consists of a 10-minute gaseous ground-level release of 53,820 lbs. (4,500 gal) of stored sulfur dioxide, dispersed under stable atmospheric conditions (stability class F) and light wind speeds (1.5 m/sec).  A gaseous release of this magnitude over such a short time-span is physically impossible because the amount of heat energy required to rapidly vaporize the liquid sulfur dioxide would not be available.  Even if the storage tank were to breach, liquid sulfur dioxide would spill to the ground in a boiling pool.  If a hole were to form in the vapor space of the storage tank, the flashing vapor in the tank would cause the tank to auto-refrigerate, thereby gradually reducing the release rate with time.  The selection 
of the worst-case release for sulfur dioxide should, therefore, be viewed as a regulatory assumption, rather than a realistic representation of a worst-case release event. 
The modeling results for the regulatory defined worst-case release indicate that the distance to the toxic endpoint is approximately 5.5 miles. The resident population within this zone was based on the 1990 Federal Census, and estimated by applying EPA's Landview III program.  Public receptors were identified using 1:24,000 scale U.S.G.S maps, supplemented with comprehensive maps of the local area (DeLorme Street Atlas USA, Version 5.) 
Alternate Release Scenario 
Alternative releases are intended to represent release scenarios that have a greater likelihood of occurrence than a worst-case release.  Alternative releases do not necessarily represent the types of releases that the PSM hazards analysis and/or accident history indicate would be most frequent, but rather a release that is somewhat more likely than the w 
orst-case release and that generally still has the potential to affect off-site receptors.  In accordance with the EPA's Offsite Consequence Analysis Guidance (OCAG), a single alternative release scenario is reported. 
The Fairless Works performed a thorough review of the facility utilizing engineering plans, operational experience, and maintenance records, and the results of the OSHA PSM review in order to determine potential alternative release scenarios that would result in the greatest toxic endpoint distance.  Each scenario was evaluated and those most likely to occur and result in off-site impacts were selected for modeling.  In order to determine the most conservative off-site consequence estimates, the Fairless Works has chosen to include in the Risk Management Plan the alternative release scenarios that resulted in the greatest toxic endpoint distance. 
In accordance with the RMP rule, alternative releases are modeled under typical (rather than worst-case) dispersion condition 
s.  The EPA OCAG default dispersion conditions are neutral atmosphere, with dispersion neither enhanced nor limited (D stability and 3 m/sec wind speed).  Unlike the worst-case release (for which an instantaneous spill or 10-minute ground-level gas release is assumed), alternative scenarios can account for the actual release configuration, and account for both active and passive mitigation. 
The alternative release scenario that resulted in the greatest toxic endpoint distance was a break in the 1-inch diameter pipe leading to the external level gauge indicator.  While the Fairless Works estimates that facility personnel would be able to respond and stop the flow prior to emptying the tank (the facility maintains an external sensor and alarm system that would alert facility personnel to a tank leak), it was conservatively assumed that the tank would completely empty and that the tank was full at the time of the incident.  
The EPA RMP*COMP(tm) software was used to estimate the distance 
to the toxic endpoint for the alternate release scenario.  The model estimated release rate for this scenario was 1,690 lbs/min.  The resulting toxic endpoint distance for this alternative release scenario is 0.6 miles.  This distance is completely within the Fairless Works property boundary.  The Fairless Works however does lease property to other industrial entities.  Therefore, there are potential industrial/commercial type public receptors within this endpoint distance.  The population within this endpoint distance is zero and there are no schools, residences, etc. within this distance. 
Accidental Release Prevention Program 
The Fairless Works is governed by a set of OSHA, USEPA, and Pennsylvania regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and to the environment.  These regulations include: 
    * 40 CFR 355 Emergency Planning and Notification 
    * 40 CFR 370 Hazardous Chemical Reporting: Community Right to Know 
    * 40 CFR Part 68, Accidental Release Prevention 
    * 40 CFR Part 112, Spill Prevention, Control and Countermeasure 
    * 40 CFR Part 264, Hazardous Waste Contingency Plan 
    * 29 CFR Part 119, Process Safety Management 
    * 25 Chapter 245, Pennsylvania Storage Tank and Spill Prevention Program 
    * 25 Chapter 261, Pennsylvania Preparedness Prevention and Contingency Plans 
The sulfur dioxide process subject to the Risk Management Regulation is also subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard.  The Fairless Works Accident Prevention Program elements are adopted directly from the compliance program for the PSM standard, consistent with the Program Level 3 requirements under 40 CFR Part 68.  The Program 3 Prevention Program elements are: 
    * Employee Participation 
    * Process Saf 
ety Information 
    * Process Hazard Analysis (PHA) 
    * Standard Operating Procedures 
    * Training 
    * Contractors 
    * Management of Change (MOC) 
    * Pre-Startup Safety Reviews (PSSR) 
    * Mechanical Integrity 
    * Safe Work Practices 
    * Incident Investigation 
    * Compliance Audits 
Five Year Accident History 
The Fairless Works has not had an incident in the past five years involving the sulfur dioxide system that has caused any of the following: 
    * On-site deaths, injuries, significant property damage, or 
    * Offsite deaths, injuries, property damage, environmental damage, evacuations or sheltering in place. 
Emergency Response Program 
Fairless Works has personnel trained in emergency response at the facility 24 hours per day, seven days per week.  These personnel receive annual training on emergency procedures and response techniques.  Response activities are coordinated with the local off-site fire department to ensure the appropriate level of re 
Planned Changes to Improve Safety 
The Fairless Works, under the recent RMP program, as well as its existing PSM and earlier SARA Title III Community Right-to-Know Act compliance programs, has organized its management system to effectively address all hazards and potential risks.  Both the advanced planning aspects of process design, operating procedures, and emergency preparedness, and the operational elements of system maintenance, safe operating practices and ongoing personnel training are necessary to support a continual improvement in facility safety.  These programs are thoroughly documented so that information about the safe handling of chemicals present at the facility is available to all employees, and can be readily interpreted by emergency response team staff and the Incident Commander.  This is especially important when questions arise from public safety officials regarding potential risks to the community.  All of these features of the RMP and the PSM program at t 
he Fairless Works lead to operations that are safe today, but will be even safer tomorrow. 
The Fairless Works safety program incorporates continuous improvement through use of audits, inspections, and on-going evaluations of in-plant safety and program effectiveness.  The information gathered is evaluated and improvements that are identified are incorporated into the program.
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