Libbey Glass Inc., Shreveport, LA Plant - Executive Summary |
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2694 LDEQ Facility ID Number EXECUTIVE SUMMARY Accident Release Prevention Program and Emergency Response Policy It is the policy of the Libbey Glass Inc., Shreveport, Louisiana, facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under 29 CFR 1910.119, OSHA's Process Safety Management (PSM) program. 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 Libbey's employees, the public and the environment. This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Libbey's management is committed to providing the resources necessary to implement this policy. Facility Description The Libbey Glass, Shreveport, Louisiana, facility combines raw materials to produce glassware. The raw materials used in the processes include various dry ingredients that are melted in a furnace and then pressed or blown into various shapes of ware. Support operations include a Flammable Mixture (Thomas Gas C-53) gas system, limited quantities of hydrogen and acetylene and administrative offices. One chemical is utilized at the facility, in sufficient quantities to be subject to the requirements of 40 CFR Part 68, RMP and 29 CFR 1910.119, PSM. The chemical, Flammable Mixture (Thomas Gas C-53) is used to lubricate molds in the forming department. The gas is burned and the resulting residue (soot) is deposited on the mold and acts as a lubricant to keep the hot glass from adhering to the mold. Thomas Industrial Gasses, Inc. performs all transport unloading operations and supplies the Thomas Gas C-53. This system includes one (1) 30,000 gallon tank filled to a maximum of 91% of capacity. One (1) a dditional 30,000 gallon tank is also onsite, however, it has been emptied and disconnected and is no longer a part of the operating system. For the purposes of this Plan, the tables and information provided in the EPA, "Risk Management Program Guidance for Propane Storage Facilities," is used as a conservative approach, since Thomas Gas C-53 is slightly heavier and less flammable than propane. A 4,675 gallon hydrogen tank at the facility holds about 2,200 pounds when kept at 86% full. Portable acetylene tanks used for torch cutting are stored in a rack or distributed as needed throughout the facility. Worst-Case and Alternative-Release Scenarios Flammable Mixture (Thomas Gas C-53) The worst-case release scenario for a Flammable Mixture (Thomas Gas C-53) gas release included a release of all the liquid contents of one the 30,000 gallon (91% filled, specific gravity 0.585 at 20o C) Thomas Gas C-53 tanks and subsequent detonation of the resulting vapors (per EPA guidelines). This c alculates to a release of 130,000 pounds (2 significant figures) of Thomas Gas C-53. Other assumptions included in the worst-case assessment are: the Flammable Mixture (Thomas Gas C-53) is a liquefied gas; the liquid completely vaporizes; the tank is not diked; the release does not take place indoors; the nearfield dispersion environment is characterized as urban; the wind speed is 1.5 meters/sec, and the atmospheric stability is classified as F (stable). The results of the worst-case assessment for Thomas Gas C-53 show that the greatest distance for offsite impact is 0.4 miles. The distance to endpoint is defined as the distance over which a minimum of one (1) pound per square inch (psi) occurs from the pressure wave formed by the detonation of the vapor cloud. A 10 percent yield factor is used for the TNT-equivalent model. Table 3 from the RMP Program Guidance document was utilized to determine the endpoint. Two alternative-release scenarios for the Thomas Gas C-53 system were selected, including a release resulting from a truck pull away and breakage of a Thomas Gas C-53 transfer hose. The longest hose is 25', with an inside diameter of 3". The alternative-release rate was derived from the following equations, which are based on the hose size and the properties of Thomas Gas C-53. The distance is calculated for an explosion endpoint exceeding 1 psi overpressure. Volume of Hose = p (3 in/2)2 x 1 ft2/144 in2 x 25 ft = 1.227 ft3 Wf = 1.227 ft3 x .585 x 62.37 lb/ft3 = 44.77 lb. of Flammable Mixture (Thomas Gas C-53) Pull-away Explosion D = 17 (0.1 x Wf x HCf/HCTNT)1/3 D = 17 (0.1 x 1.227 x 44.77/2.0246 x 46333/4680)1/3 = 50.9 meters = 167.0 feet where: Wf is the weight of Flammable Mixture (Thomas Gas C-53) in kilograms in the vapor cloud HCf is the heat of combustion of Flammable Mixture (Thomas Gas C-53) from Appendix C of EPA's OCA HCTNT is the heat of combustion of TNT from Appendix C of EPA's OCA D is the distance in meters from the explosion where overpressure exceeds 1 psi Process Piping Breaks An additional alternate release scenario was calculated based on a ten minute process piping release of 17,056 pounds/minute from a 3" diameter pipe. The distance to endpoint for a 1 psi overpressure is 0.4 miles, utilizing Table 4 of EPA's RMP Program Guidance Document. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The Shreveport facility is governed by a set of OSHA and USEPA 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: 7 40 CFR Part 68, Accidental Release Prevention 7 40 CFR Part 112, Spill Prevention, Control and Countermeasure 7 40 CFR Part 264, Hazardous Waste Contingency Plan 7 29 CFR Part 119, Process Safety Management The ke y concepts in Libbeys' release prevention program are employee participation, appropriate design and maintenance of equipment, use of outside contractors for Flammable Mixture (Thomas Gas C-53) process system operation, maintenance and emergency response and appropriate training of all employees. Employee participation in the release prevention program is encouraged and supported by Libbey management. Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the Flammable Mixture (Thomas Gas C-53) system. Libbey employees are not trained to be members of the facility emergency response team for Thomas Gas C-53. Libbey policy is to construct all new equipment, systems, and facilities in accordance with applicable building and safety codes. This ensures the appropriate safety and release prevention systems are included from the beginning of each project. Libbey is committed to providing appropriate training to all employ ees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, Libbey conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Five Year Accident History Libbey has not had a release of Flammable Mixture (Thomas Gas C-53) from this facility that has affected the public or the environment. Emergency Response Program Libbey has contract personnel, Ever Safe Response (ESR) trained in emergency response available to the facility 24 hours per day, seven days per week. These personnel receive training on emergency procedures and response techniques. In addition, the Caddo Local Emergency Planning Committee (LEPC), Caddo/Bossier Office of Emergency Preparedness, will respond to an offsite emergency. Planned Changes to Improve Safety Libbey, Inc. completes a thorough revi ew of the Flammable Mixture (Thomas Gas C-53) systems each time a design change is implemented. The system is also evaluated each time the PHA is revised. Libbey is committed to using these methods to identify and implement ways to improve the safety of these systems. |