LTV Steel Co., Hennepin Works - Executive Summary

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The Risk Management Plan (RMP) for LTV Steel's Hennepin, 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: 
The Hennepin Works uses approximately 24 tons of liquefied chlorine annually for water treatment purposes.  The chlorine is contained in one ton cylinders which are stored at three locations.  Chlorine gas can be hazardous under various conditions 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 ( including al 
arms ), and through proper training of personnel. 
The facility emergency response program is written and includes an emergency action plan for chlorine releases.  This plan is a part of the off-site response plan on file with the Local Emergency Planning Committee and the Hennepin Fire Department in accordance with the provisions of the "Superfund Ammendments and Reauthorization Act of 1986" (SARA Title III).  These plans include procedures for notifying local emergency response agencies. 
2. The stationary sources and regulated substance: 
The Hennepin Works processes hot rolled steel coils thru several operations including a temper mill, tandem mill, pickle line, batch annealing, and a galvanize line.  Some of the auxillary services which support the main operations are the roll shop, garage, and utility departments. 
Illinois river water is used at the plant for both contact and non-contact applications.  Chlorine is used  to treat water at three different locations within the Henn 
epin Works: 
       LOCATION                                                     STORAGE CAPACITY 
River Pump House                                        Four cylinders          (4000 pounds) 
Water Treatment Plant                                Four cylinders          (8000 pounds)  
Recirculating Water Station                  Four cylinders          (4000 pounds) 
The cylinders are connected into the process through a manifold system, valves and pressure regulators.  Each of the three processes is checked at least once on daily basis and each system has an alarm system which activates when chlorine levels exceed five parts per million near the process area. 
3. The worst-case and alternate release scenarios: 
Worst case scenario -  Failure of a full one-ton cylinder of chlorine which would result in a release of  
2000 pounds of chlorine over a ten minute time period. 
The distance to the toxic end-point 0.0087 mg/L for this scenario is 3.0 miles. 
Alternative scenario -  Rupture of  the 3/8" tubing leading from the chl 
orine cylinder to the manifold which     would result in a release rate of eightteen and one-half pounds per minute over fifteen minutes. 
The distance to the toxic end-point of 0.0087 mg/L for this scenario is 0.2 miles. 
4. The general accidental release prevention program and the specific prevention steps: 
The facility has developed a Process Safety Management Plan for its chlorine processes as required by 29 CFR 1910.119 of the OSHA standards.  Facility personnel are trained to respond in accordance with the provisions of the plan. 
5. Five year Accident History: 
There have been no releases from any of the chlorine processes within the last five years. 
6. The emergency response program: 
LTV's Hennepin Works has established and implemented an emergency action plan for the entire facility.  This plan is the Hennepin Plant Emergency Response Plan and is on file with the Hennepin Fire Department  and the Putnam County Local Emergency Planning Committee. 
7. Planned changes to impr 
ove safety: 
The facility constantly reviews its equipment, operating procedures, and personnel training and makes any changes necessary to improve safety and decrease risk promptly.
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