Lobeco Products, Inc. - Executive Summary |
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LOBECO PRODUCTS, INC. Risk Management Program Executive Summary for Chemical Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Lobeco Products, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with the Sheldon Township Fire District which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass High Technology Chemical Manufacturing. We have nine (9) regulated substances present at our facility. These substances include Oleum (Fuming Sulfuric acid), Methyl chloroformate, Formaldehyde, Muriatic acid (Hydrochloric acid), Monoisopropylamine (Isopropylamine), Dimethylamine, Ethylenediamine, Ammonia and Ethyl Chloride. The regulated substances at our facility are involved in several uses. Oleum (24% solution) and Formaldehyde (30% Solution) are used to manufacture a water based additive. Muriatic acid (32% solution) and Ethylenediamine (99% solution) are used for Dye & Pigment manufacturing. Monoisopropylamine (70% solution) and Methyl chloroformate (97% solution) are used for manufacturing Herbicides. Dimethylamine (40% solution) is used in manufacturing an intermediate chemical for sale to other manufacturers. Ammonia (29% solution) is used for both Herbicide and Dye & Pigment manufacturing. Ethyl Chloride (30%) is a recycle stream generated by one of the Herbicide processes. The maximum inventory of Oleum (24%)that is expected to be present at our facility is 38,400 lb., while Formaldehyde (37%) is 50,000, Muriatic acid (32%) is 55,000, Monoisopropylamine (70%) is 55,000, Methyl chloroformate (97%) is 40,800, Dimethylamine (40%) is 38,200, Ethylenediamine (99%) is 35,700, Ethyl Chloride (30%) is 65,000 and Ammonia (29%), which has two locations Tk# 8414 with 33,900 and TK# T-17 with 55,000 are present at our facility. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To evaluate the worst case scenarios, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance. For alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance . The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Oleum Storage Tank T-8404. The scenario involves the release of 38,400 lb. of Oleum (24% solution). Toxic liquid is assumed to be immediately released from which evaporation takes place, with a temperature of 102 degrees F and average ambient relative humidity of 72%. The entire pool is estimated to have evaporated over 2379.14 minutes. Passive mitigation controls such as a dike are also taken into account to calculate the scenario. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 0.55 miles is obtained corresponding to a toxic endpoint of 0.01000 mg/L. One alternative release scenario has been submitted for each toxic substance present in Program 2 and Program 3 processes cumulatively. The alternative release scenario for Oleum (24%) involves a releas e from a ruptured transfer hose between the Oleum Storage Tank T-8404 and the delivery Tanker Truck with a release of 500 lb. of Oleum. Toxic liquid is assumed to be immediately released to form a pool of heigth 1 cm, from which evaporation takes place. The entire pool is estimated to evaporate over 35.50 minutes. Under neutral weather conditions, the maximum distance to the toxic end point of 0.01000 mg/L of Oleum (24%) is 0.09 miles. The alternative release scenario for Methyl chloroformate (97%) involves a ruptured transfer hose between the MCF Storage Tank #T-22 and the delivery Tanker Truck resulting in a release of 125 lb. of Methyl chloroformate. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 40.81 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0019 mg/L of Methyl chloroformate is 0.25 miles. The alterna tive release scenario for Ammonia (29%) involves a release of Ammonia from a ruptured transfer hose between the Ammonia Storage Tank #8414 and the delivery Tanker Truck resulting in the release of 340 lb. of Ammonia. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.19 miles. The second alternative release scenario for Ammonia (29%) involves a release of Ammonia from a ruptured transfer hose between the Ammonia Storage Tank T-17 and the delivery Tanker Truck resulting in the release of 340 lb. of Ammonia. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.19 miles. The alternative release scenario for Formaldehyde (37%) involves a release from a ruptured transfer hose between Formaldehyde Storage tank T-8413 and the delivery Tanker truck with a release of 500 lb. of Formaldehyde. Toxic liquid is assumed to be immediately released to form a pool heigth 1 cm, from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic end point of 0.012 mg/L of Formaldehyde is 0.11 miles. The worst case scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release of Monoisopropylamine from Storage Tank T-16. The scenario involves the release of 55,000 lb. of Monoisopropylamine (97%). Passive mitigation systems such as dikes have been considered when evaluating this scenario. It is assumed that the entire quantity is released as a vapor, which finds an ignit ion source, with 10% of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.29 miles is obtained corresponding to an end point of 1 psi overpressure. The alternative release scenario submitted for program 2 and 3 flammable substances involves a release of Monoisopropylamine from a ruptured transfer hose between Storage Tank T- 16 and the delivery Tanker truck which results in a vapor cloud explosion. The scenario involves the release of 560 lb. of Monoisopropylamine (97%) in 10 minutes. Under neutral weather conditions, the maximum distance to the flammable end point of 1 psi overpressure is 0.19 miles. Ethylenediamine (99%) classifies as a Program 1 process. The worst case scenario considered for this process involves a toxic substance, namely Ethylenediamine (99%). The quantity released in the scenario is assumed to be 35,700 lb.. Passive mitigation considered in the scenario includes dikes. Under wor st case weather conditions, the maximum distance to the toxic endpoint of 0.49 mg/L is 0.24 miles. This distance is less than the distance to the nearest public receptor. Muriatic acid (32%), Dimethylamine (40%) and Ethyl Chloride (30%) were determined by the program as not meeting the requirements for any of the Program 1-2-3 reporting. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements and has been issued an Air Operating Permit ID under Title V of the Clean Air Act. The following sections briefly describe the element s of the release prevention program that is in place at our stationary source. Process Safety Information Lobeco Products, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses are the "HAZOP" and "What If Check Lists". The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of three (3) years, or sooner if any changes to the process or system occur. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Lobeco Products, Inc. maintains writte n operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, and normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Lobeco Products, Inc. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three (3) years and more frequently as needed. Mechanical Integrity Lobeco Products, Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations ar e carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Lobeco Products, Inc. to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Lobeco Products, Inc.. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Lobeco Products, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three (3) years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Lobeco Products, Inc. promptly investigates any incident that has resulted in, or could reasonably result in a release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of five (5) years. Employee Participation Lobeco Products, Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Lobeco Products, Inc. has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. All contractors are required to attend a Lobeco Products, Inc. Safety Indoctrination prior to commencing any work within the plant limits and are given a written evaluated on their Safety Performance if their work involves areas associated with RMP processes. 5. Five-year Accident History Lobeco Products, Inc. has an excellent record of preventing accidental releases over the last five (5) years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Lobeco Products, Inc. carries a written emergency response plan to deal with accidental releases of hazardous materials. As part of the Beaufort County Local Emergency Response Committee (LEPC) actions, the plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modification to our emergency response. 7. Planned Changes to Improve Sa fety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Existing dike systems have been modified and some new dikes constructed around those chemicals that are affected by the RMP Program. We have also constructed an enclosure around our Methyl chloroformate Storage Tank T-#22 as an added passive mitigation system. Also as part of our Methyl chloroformate modifications, we have initiated a semi-annual preventive maintenance program that verifies the integrity of the associated pump for off-loading the chemical from the tank truck. These changes have already taken place, but Lobeco Products, Inc. is committed to continuously striving to provide safety features to prevent any accidental release of a hazardous chemical substance. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. ( A signed Certification Letter has been included with the Electronic Submittal Package for Lobeco Products, Inc. ) Name: Signature: Title: Date signed: |