Bethlehem Steel Corp. - Sparrows Point Division - Executive Summary

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The Bethlehem Steel Corporation - Sparrows Point Division (the Division) is a vertically integrated iron and steel production complex that has operated at the site since 1889.  The facility occupies approximately 2,300 acres of the Sparrows Point Peninsula in Baltimore County Maryland.  The site consists of both steel making and finishing operations. 
The Division is required under Title 40 of the Code of Federal Regulations (CFR) Part 68 and the United States Environmental Protection Agency (EPA) to develop and implement a Risk Management Plan for applicable processes operated by the facility.   Under 40 CFR 68, facilities are required to comply with the RMP regulations by June 21, 1999.  Compliance with this rule includes an electronic submittal to EPA of required data elements using EPA's Risk Management Plan SubmitTM Software.  The Risk Management Plan and the data elements required in the Division's submittal were developed based on EPA's guidance documents including: General Risk  
Management Program Guidance (July 1998) and Risk Management Plan Off-Site Consequence Analysis Guidance (April 1999).  
Based on the Division's applicability assessment of toxic and flammable chemical usage at the facility, sulfur dioxide (SO2) storage at the Chrome Recovery Plant is a process that requires a Risk Management Plan.  The Chrome Recovery Plant processes chrome-bearing wastewaters from the steel finishing operations.  This recovery technique uses a sulfur dioxide and water mixture along with a lime slurry to neutralize and precipitate metals from the wastewater.  The sulfur dioxide is fed into the chrome recovery process as a gas dissolved in water (sulfurous acid).  This is accomplished through a sulfonator system, which consists of a 39-ton liquid storage tank, an evaporator, and a flow regulator.  Several 1-ton SO2 storage cylinders are also kept in the area as a back up to the main storage tank.  
The Division's RMP for the SO2 process can be divided into five main categ 
ories, as described below: 
1) Regulatory Applicability 
The Division reviewed all toxic and flammable chemicals regulated by 40 CFR 68 used at the facility.  It was determined that the RMP requirements are applicable due to the maximum storage capacity of sulfur dioxide at the Chrome Recovery Plant. After performing the initial off-site worst-case hazard assessment (as described in #2 below), the process falls under the Program 3 requirements as specified in the regulations. 
2) Hazard Assessment (Off-Site Consequence Analyses) 
The Division performed a hazard assessment to evaluate off-site consequences for both a worst-case and an alternative-case accidental release of SO2 from the process.  This assessment was completed as required for Program 3 applicable processes.   
The worst-case release scenario is an extremely unlikely scenario, which analyzes the off-site consequences resulting from a maximum release of SO2 during meteorological conditions that give the least dispersion.  Acco 
rding to the rule, the worst case release is defined as the maximum release of the largest quantity of SO2 from a vessel or process line failure that results in the greatest distance to a toxic endpoint.  EPA has defined chemical-specific toxic endpoints as the maximum concentration that has no human health effects from a one-hour exposure.  For SO2, the toxic endpoint is 0.0078 milligrams per liter.  The worst-case release from the process is defined in the Risk Management Plan regulation to be 82,500 pounds of SO2 being emitted over a ten-minute period.  Again, based on the Division's engineering expertise with the process, this type of release is highly improbable.  To calculate the greatest distance to the toxic endpoint resulting from this worst-case SO2 emission rate, the Division utilized a publicly available dense gas dispersion model (DEGADIS).  The Division modeled the release under worst-case meteorological conditions and calculated a distance of approximately 3.6 miles to t 
he toxic endpoint with an affected population of 54,888 including numerous public and environmental receptors. 
For the alternative release scenario, the Division reviewed the process to determine a scenario that was more likely to occur than the worst case scenario.  Based on this review, the Division selected a catastrophic gasket failure between the flanges of a fitting to be the alternative release scenario.  An emission rate of 97.9 pounds of SO2 per minute was calculated based on the tank temperature and pressure and on the estimated size of the opening that would be created from a blown gasket, using EPA's Offsite Consequence Analysis Guidance.  Using this emission rate along with typical site-specific meteorological conditions, the Division again used DEGADIS to calculate a distance of 0.65 miles to a toxic endpoint.  Under the alternative scenario, the leak will not affect public or environmental receptors off-site. 
Since the Chrome Recovery process began in 1987, no accidental 
releases of SO2 have occurred that resulted in death, injury, property damage, off-site evacuations or sheltering, or environmental damage. 
3) Accident Prevention Program 
To minimize the risks associated with an accidental release of SO2 from the Chrome Recovery Plant, the Division has developed and implemented various programs and procedures to provide a structured management system for operators, supervisors, contractors, and other staff.  The Division has previously implemented many of these process safety management programs as required by the Occupational, Health and Safety Administration (OSHA) and 29 CFR 1910.119.  These programs include (1) certification of specific operating procedures with hands-on employee training; (2) implementation of safe work practices; (3) periodic review and analysis of potential process hazards; (4) routine inspections of process equipment by experienced contractors; (5) integration of employee safety teams; and (6) routine internal compliance audi 
4) Emergency Response Plan 
The Division has been conscious of the hazards associated with the SO2 process; consequently the facility previously developed an emergency response plan for the process.  This plan complies with the requirements of both 40 CFR 68 (EPA's RMP) and 29 CFR 1910 (OSHA's Hazardous Substance Emergency Actions and Department Emergency Organization). 
In the event of a SO2 release emergency, the Chrome Recovery Plant Operator or Humphrey's Creek Assistant Station Operator is instructed to perform three key functions:  
7 Close the emergency shut-off valve; 
7 Notify crew leader; and  
7 Notify and provide specific information about the release to the Baltimore County Fire Department.   
The crew leader is then responsible for notifying designated emergency response personnel.  The emergency responders work with the Baltimore County Fire Department to secure the release and minimize further damage.  Division employees are instructed not to take an active role in the  
actual stopping, containing, or cleaning of the release.  The Divisions feels that the Baltimore County Fire Department's emergency response teams are better equipped to handle this type of emergency.  
5) Risk Management Plan 
The Division has completed a Risk Management Plan specifically to address a potential release of SO2 from the Chrome Recovery Facility.  The purpose of the plan is to ensure that hazards are identified, appropriate steps are taken to prevent accidental releases and minimize risk, and emergency response is communicated.
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