Table Of ContentMite 8. Ross
Plant Manager
Sse a 1.5, Stel Bion Valloy Works.
ws7t Ciaisan Plat
anon 4 19028
Te a2 238 102
Em: mead
January 7, 2019
Ms. Jaymo Graham
Air Quality Program Manager
‘Allegheny County Heath Departinent
30°38" Stree, Biag. No. 7
Pittsburgh, PA 15201-1881
Vin email and hard oa
jear Ms, Graham:
RE: United Staies Stee! Corporation = Mon Valley Works Clairton Plant
Adkltional iniornation Regarding Breakdown Reporis #21250, 2157, anv 2458
No, 2 Cantrol Ror No, § Gorltal Room, and Ballery Slacks
United States Steel is folowing up to our Friday, January 4" teleconference with the Allegreny
County Heeler Departirent (CHD) with regards to our Mitigation Plan to reduco any potential
‘environmental impact regarding tho aaove-roforonced broakcowns,
As you are avare, 21 Decenber 24, 2018, al approximately 4:30 AM, U. 8, Sica’s Claton plan
experienced a significant fre which required the mrmed ate shutdown of the No. 2 Contrel Room
and No. § Control Room ‘or the salety of employees and equipment. While the fe was
ttuseasuly extinguished, as we disuuseed, he oatse of the fie and damage it caused te
processes aro equipment retrains under investigation. The emergency shutdown of the Nos. 2
and 5 contol rooms requires the by-pass of coke even gas to the downriver system. The affeced
buildings and related infratructure are bing svalusted for strucsural safety. Once the evalalion
is completo; and any necessary measures employed based upon tne evaluation, the buildings
can he accessed to determine impacts and damage io the systems: and what actons il b=
needed to bring the Facility bcs to narmal operation,
U. 8. Stee! is emelaying eignticent resouroes around tne elook to investigate the incident. While
the investigation Is being completed, we heve expended and cortinue to expand substantial
resources ard costs to employ mitigation offerts to recuco any potontial impacts For the
incident. We renrain commitied to employing actioas only when such actions can be done in
manner that is safe for our emp ayes, centactors, and public and potential imascts to the
ferviranmental are minimized. “42 we discusses on Friday, we would be pleased to have the
ACHD visi the site to observe the area carmaged by the fre and our mtigation stor
Todate, among other aforts, we have utlized natural gas (disolacing
practicable
‘0 oven gas} tothe extent
MMs. Jayme Gvahani (ACHD}
January 7, 2019
Page?
BACKGROUND INFORMATION REGARDING COKE OVEN GAS PROCESS
To better uncierstand the breakdows ans fis impact of operations, a brief explanation of the coke
vor gas process is e-ovided, Coke oven gas le proceseed through a seres cf unt operations
atthe U. S. Stoel Clairton slant to recever various ty-prestue's, and clear tre coe oven gas [or
daanstream fue gas use. A simplifies block “ow clagram of the coke even gas few through
these unt operations, and byproduct recavery at each unt operation is shawn Selon:
*
fee] [iat]
“The #2 conitol room process is 9 cryogerie gas separation facilty, and ligt oll rocavory facity
It eonsis's of 24 man regenerator vessels wh ch ocerate al vey low temperatures (.258 F), which
coal the coke oven gas and saparale te gas rto variaus streams for dawnetrsam fuel
‘consumption and further sy-ofoduct recovery. 16, two-stage, 1609 horsepower ax’al
ccompaassors, w 64 grovide vacuum and compression for the main regenerator unit operation,
aang light cil recovery process. ard a lish: oll recovery plant, which isa series af haat exchangers,
sand another small ctyogea'e unk eperation, consisting of 4 light ol rogonorators that rocovor te
lignt al fram the coke aver gas,
uring rormal oceration, 100 aeroent of the coke aven gee mus: pass trough tne entire procese
up to #2 control room. At #2 cantiol oom, ts coke even gas stream is spt into different gae
streams, including 1} clean cownrivor ccko avon gas, (2) cloan uncer eaKe oven gas, and (3)
ccarbonale feed gas, The clean downrver gas. goes to consumers troughout the Mon. Valle
Works. The cean under tre gas is Lsed heat the batteries at Clairton, The carhonats feed gas
represents apsroximalely 15% of the to‘al gas volume {~20 MMSCFD of yas Tew for 11,7
tansiday of cake roductior). This carbonate feed gas stream is gent o7 to the #5 control roam
for sufur romaval. Onco tho sulfur has cen rernaved from the carbonate feed gas, this gas le
‘combined with the clean down-ver gas, far downstream corsumption.
‘Without the #2 Control room operation, the faclity eannial operate the #8 control reo prazesss,
because the operation of #2 coniral reom is er'sa to secarate and concentrate the acid gas
componente in the ccke oven gas etresm into a small fracton of the coke over gas {15% of te
{otal volume}. The pping dees rot cxis: to go from #* contol room directly to #5 contro! room.
In adetion, #8 control oom is rot sized to handle tis ful flow of coke oven gas
om. The specie ates af damage
mmpvessors. Witain chs,
The area offre damage at the C'sirian plants the #2 control
Is the bulding thst houses the 15 ~ two-stage, 1500 harsecower axial
His, Jayme Granam (ACHD}
January 7, 2019
Page 3
building, thera are 4 lube cl cellars, each oi cellar provides lubrzalien sll to 4 of the 16
compressors. There isan ovethead eran inthis building. that rovidosIing capabilty to perform
rmarntenance on the 18 axia. compressors housed Ia the building. There fsa large amour o' lage
‘ameter piping that dree:s the gases into ano out of the compressor buizing, and sigafican
rity infrasuture that supports this portion ofthe proes
IGATION PLAN
As we discuss an Friday, we have mplamanted the following wark as part of our glan to miigate
{he poienlia| “o- environmental imcacts and te bring the faclity back ts nomal operation. While
sve are providing the Miligation P'sn in good falth and remain commited te emoloying sounc
practices end efforts to mitigato any potenti) mpacts from the breakdown, inivermencaton of
these actions and any future actons are subjec: to change nased upon ‘ha invest gation and
information that becomes avaliable. In any ever’, we will Keep the ACHD up-to-date on our
Major Work Completed Since December 24, 2018 (as of 1/4/2019]:
Safety, Fite Protection, and Process Stabilization:
4. "PSM incident investigation started
2. Asbestos abatement seumil has seen obtained,
5. Bulding Gas Monieving System evaluation completed ans repair plan being
develapec.
4, Hazardous Job Procedure compisted ‘o” craro actos.
5. Bulding fre system inepection cameleted ans repair plan being Hoveloped.
5. Undergroune fre eysiem pining breas has beer rezairad
7. Keystone Fire Purp repairs completed,
8. Main raganoraters tomperatures are in control and spare deriming blower repairs aro
comaleted,
‘Structural and roofing demo:
1. Approximately 80% cf structural inerections hws boon complales.
‘Approximately 50% of roof sheeting hae boon remmaved.
‘Approximately 50% af Wost wall chesting has been removed
Appraximately 80% of roof structural members have been rermove
‘Truss fabrication bil package PO has been awarded,
Building Crane inseestion is completed — there are 20 structural concerns but all
lectical carnzenents are damages ancl nees to he raplaced, Waiting for
Confirmation on delivery dates
#2. CR Equipment
Three axial compressors ate tuioing (appear to Ge operational once repairs to
pumps, seals, and molors are complete}
2. Lube oi pump celiveries coniirmes and orders placed
3. Lube of equipment in 593 ol cellars is boing romoves.
a
Axial eamrassa” couplings on she macaines has been removed for rebuild,
‘Ackitional two 409 series axial cor-pressor have been sent aut for repair
8, Orders placed for adit onal blanks ‘” fabrication of axial rotor,
Ms. Jayrne Graharn (ACHD}
Sanwary 7, 20°8
Page 4
Work Planned Moving Forward ~- Repairs planned for wook of 1/6/2018:
1. We wil continie fo remave eectione of the vacuum buldag raat, sheeting anel
structural members as required. We are tindirg adkltional damage as we Yerove
roof shecting te tho roof structural members. tral gould not ae seen trom preliminary
inspections, Bulking nspoctions aro agcvoximataly 60% completed at Lis line,
2. Indeperident fire specror wil be on site on Tuesday to begin inspection, Antcfpare
this will be comaleted by end of ihe wok
8, We are pullrg the frst three motors off the cass (C530, C592, C590), We will
continuo sotking to de-wire and uncocple matorsicompressor9 for eventual
removal. As the hvostigaton contiiuss, we wll dleassernble and remove addtional
esuiement
4. Ganlinue wark on 892, 888, and 595 cil cellars (cump reclacement and sormplete re=
6, Continue work on ientifietion of electical scapetelect‘ical inspec’ an inthe
corprasser bu din:
18, Continue work on vacuum
jiding (B} crars inspeciiontrepa rs
Long-term evaluations! work planned:
41, $83 Lube Oil Gellar ~ needs te be completely 10.
(was completely flocced}
59¢ Lube Oil Collar — needs to be completely r
(was completely looeed)
598 | ube Oil Cellar ~ needs to be completely rewires, purnps need fo be changes
(w9s completely fecalod)
4, 598 Luce Oil Cellar ~ needs to be completely rewired, purips need to he changed
(was completely Hlecaes)
5. 14- Axial campressers nes:
samages compressors
or OBA5 (sub2) 2a8es, a8 these maccinas were in process of bell
ofthe event
rod, purips noad ta ho changord
fed, purips need to be
changes
Ipess0rs aro all pising), and the
There were not compressa’ on C500
rabull atthe tine
Al minimum, we know we have damage tothe ‘ollowiing axial sorpiessors
> C506 thoth stages)
B12 foth stagen)
515 iboth stages)
C518 {both staves)
521 fboth stazax)
(0524 (both stazes)
‘82 tboth stages)
(0820 {is not luring ~ rend fa inszeeitest seal funet orality if ne oan get tee)
(©523 {ie not turning ~ need fo inssecstes: seal funci orally i we ear get ec)
‘S820 (both stages)
(6548 s4b2 (bath stages)
vy yyy
(Me. Jayme Granam (ACHD)
dlanwary 7, 2019
Pages
6. Need to inspect seals on C503, C508, C842, [these seals are intact — i appoars that
these compressors ara viable to aporate
7. We need a minimum of 6 functional compressors for partial re-start of the #2. CR.
‘gas separation facility. To mitigate, we plan to employ a pattial re-start of tho #2
‘CR when conditions allow.
A. AIG - 1500 horsepowe” mols’s must be removed from the bulting, sert out to &
rehabilitation shop (IPS) and ingpectec and ciel out/"epated as needed.
Inspect and recair all piningiexcansion joirts on East and West sides of bo vacuure
builsina, ars p ping outside the west wall (including main sub valves and associated!
‘equ pment,
20, Replace gae nazerd detection’alarm system ~ which was damages sui the fe
event,
11, Repair the compressor building EOT crane — which sustained significant electrical
‘damage curing the fre event
Mitigation Methods Currently Implemented for S02 Gontrol
41, Weare currently operating & stabi ized natura’ gas e's lo offset 39 AINSCED of coxo
‘oven gas equivalent (o Clallar Uncertire systam. This is maximurn make uo with
‘xsting installed equiomant
2. We ars currently flaring as much coke oven gas as possiele, given surrant syste
demands at the paach ts and Irvin ground flares — ara making this gas up ‘ith
purehases natural gas
3. We extencled coking tines on 13-18, 19-20, ans BiG Halleries due to gas cually
4. On Friday 1142019, we re-ccrfgured the Ciairlon taller fuel supply ~ to operate both
high aressure bollers on A line suoaly. A line's mixed gas {natural gas ~ coke oven
gas} from the Mixing Staton, prior configuration, one seller as on & line mixed gas,
the othe: was on B line - 100% coke oven cae. This is tho normal practice, in the
‘evant of a fu! supply ine d euuption, eo you dont risk tring both high pressur
callers
Consideration of Possible Additional Mitigation Stops:
‘As we discusued, we understand ACHD's expectation that U. 8, Stool considor adsttional
mitigation steps inthe evart data indicato that such moaeures ave warranies. Currently we ars
installing an aetna’ natural gas jet to redirect additiorel natural gas (te cisplace ccke oven
88) to ine underfre system at Clairton, This is expected to offset an acltional 20 MMACT of
oko oven gas.
(We are investigating other miigation steps to be taken inelusing
41. Feastbity of increased natural gas flow ‘0 Cleon boilers
2 Continue to evaluste processes and oparations ts idenify ways to minimize
environmental impact and ensure oatiery integrity and stack compliance.
IMs. Jayme Graham {ACHD}
Jsruary 7, 7018
Page 6
Operating Data Summary
During the call on Friday, we agreed to provide ACHD with a summary of our operating
data,
Table 1. Summary of cokdng thes, normal vs. current operations.
Normal | Current
Coking | Coking Time
| Battery Time (hts) | (hrs)
2 |
2 22
3 2
is ar
“4 “8 2
15 18 ar
18 a
2 18 22
| B [1 igs
Jc 18 185
“eokrg tmesadused o1 1720" 99 Daeies 1945.
Table 2. Summary of fuel percentages, normal vs. current operations.
Emission Units | Normal Operating Fuel Usage | Current Operating Fuel Usage
Coke | Best Siast
watwat | Gvon | Fumace | wana | coe | Panna
|_ Ges | Ges Gas | oven Gas | "Gas
isiton Uncertre Gas_| =| soos a0% | 80% 2
Caton No. + Bae 738_| or soso | soon | -
Ciniton No.2 Bo 00% ao-s0% | 020% |
ET Boiers a zou | zo | oossw
ET Blast Furnaces som | soe [| tom |
ET Ne.‘ Stove 12% | s6.100% | 1%
No. 3 Stove s2% | ve-room | 1%
Indn No.1 Baler Som | SOSH so-gs% | 5.19 =
Tein Hot Strip na 25% 40-50% |
ind No.2 Boiler 310% 20.95%
(vin No.9 Boier 5.10% 0-9
rip No. « Boi 510% 20.95%
rir HPH Areaing | 5.10% | o-05%
is, aye Graham (8
January 7, 2013
v}
Page?
Ini OC Anreating soos | | soos
Irvin Continuous
Annealing so.05% | so.oste |
livin Na. 1 Gavanice = 100%
Invin No.2 Gavanize “00%
tile we are expediting our offots io Boing tha facity back to normal ooeration, we remit
committed io employing actions enly when such actions cart be dove ji 2 canes tals safe for
‘our employees, contractors, ane! guble: and potential empacts to tho amvioneten zee mibanizos
‘Also, as we discusses on Friday, we remain committed in openly sommuricating with the ACHD
regarding this matter, an ws oeloome ACHD to visi the Ciaitan plant ta ebsarve the aroa
lmpactad by the fre and mitigation affors to data, Pease contact Mike Dzurnnko at 412) 2:
{1457 to schedule a meeting. In the interim, ifyou have any questions regarding hs
‘corresponcence, please cortact Mice Daurirke or me.
sincerely
Bbboics
Michas! S. Rhoaes
cc: Jim Kelly (ACH
Jason Willis. Esq, (ACHD)
Hilke Durie (USS)
Chis Babst, Ess, (Babs: Galland)
ice Winel, Ese, abst Calan
David Hacker, Ese, (USS)
