Lambent Technologies Corporation - Executive Summary |
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Lambent Technologies Corporation RMP Executive Summary Corporate Safety Policies Lambent Technologies Corporation (LTC) and its parent company Petroferm Inc. have and will continue to commit resources to continue improving the safety of its operation and reducing the risk of hazardous chemical accidents/incidents/releases. As described below, LTC's focus is to develop accident prevention strategies and to prepare for accidents through emergency response planning, practice and training. Facility Description LTC manufactures various types of surfactants, including detergents, emulsifiers, wetting agents, and esters used as raw materials in cosmetics, foods, industrial lubricants, and agricultural products. The manufacturing processes utilized by LTC consist primarily of chemical blending and reactions. The primary raw materials at this facility are agricultural seed oils such as soybean oil and canola oil. The operations conducted at this site have remained essentially the same, ex cept for expansion, since Hodag began manufacturing operations here in 1948. More information about Petroferm Inc. and Lambent Technologies is available on the Internet at www.petroferm.com. Regulated Substances Handled Regulated substances handled at LTC are ethylene oxide (EO) and propylene oxide (PO). Both materials are toxic, flammable gases that are delivered to the site as liquefied gases by railcar (EO) and tank truck (PO). These compounds are used as raw materials to convert hydrocarbons such as canola oil into surfactants. Soaps and detergents are classic examples of surfactants. The products manufactured from EO and PO are present in many household products such as baby shampoo, skin care lotions, salad dressings and pickles. EO is also widely used in smaller quantities in hospitals. More information about EO is available at www.ethyleneoxide.com. Worst Case Scenario LTC utilized the gas dispersion modeling software provided by EPA (RMPComp) to evaluate the worst case sc enarios for EO and PO. The worst case scenario for EO involves the complete release of a full rail car of EO within 10 minutes under stable atmospheric conditions. This scenario would have offsite consequences. The worst case scenario for PO involves the complete release of the full PO storage tank within 10 minutes under stable atmospheric conditions. This scenario would have offsite consequences. Specialized software (Safer Real-Time) was use to evaluate the alternative scenario for EO. RMPComp was used to evaluate the PO alternative scenarios. The alternative scenarios also have off-site consequences. The alternative scenario analyzed for PO was the overfilling of a tank that PO is transferred to prior to being fed to a chemical reactor. The alternative scenario for EO is the over pressurization of the storage tank resulting in a release from a pressure relief valve. The following mitigating measures reduce the area potentially affected by the worst case scenario: 7 Releases o f EO and PO are more likely to result in fire or explosion with much smaller radii of impact than in drifting vapor clouds (this is a mitigating factor and not an intentional measure). This statement is based on the case histories of EO incidents reported in the EO manual (published by EO manufacturers and available at www.ethyleneoxide.com), not on experience at the LTC site. 7 Pressure relief valves on the EO and PO tanks at the facility are directed vertically upward to cause better mixing and dilution if gases are released to the atmosphere. Computer based gas dispersion modeling indicates that the off site impact of a gas release is significantly reduced by directing of the discharge upward. The following administrative controls reduce the probability of an EO or PO release: 7 Routine inspections of storage tanks, rail cars, tank trucks and safety equipment; 7 EO and PO storage tanks are only connected to other containers during transfer operations to reduce the risk of leaks; they are securely closed at all other times; 7 Access to the EO and PO processes is restricted to specially trained operators who are issued keys required to transfer these materials; 7 Storage tanks are partially bunkered and protected by a secondary containment wall; 7 A nitrogen blanket is maintained in the storage tanks to inert the vapor in the tanks. Prevention Program LTC's prevention program is founded upon OSHA's Process Safety Management (PSM) regulation, 29 CFR 1910.119. LTC's program includes 13 management practices that are designed to reduce the risk of releasing hazardous chemicals in the workplace and subsequently to the environment. The practical aspects of the PSM program address the prevention of: 7 Human error - through well developed operating procedures and employee training; 7 Mechanical failure - through a preventive maintenance program that provides for annual inspection and maintenance of process equipment; 7 Heat exposure - through control of hot work th rough an internal permitting procedure; 7 Careless Process Modifications - through management of change and pre-start up safety review procedures; and 7 Contractor error - through a contractor screening and management procedure. The PSM program also includes the following procedures that generate feedback for the effectiveness of the program and its implementation as another means of risk reduction: 7 Process hazard analyses - identify potential incident scenarios and prevention measures; 7 Self audits of program compliance ensure that the prevention plan is properly implemented; and 7 Incident investigation procedure - analyze causes to identify additional prevention measures needed. Accident History LTC has not had a reportable release within the past 5 years. Emergency Response Program LTC is working in cooperation with the Skokie Fire Department and the Villages of Skokie and Lincolnwood, IL to integrate the facility-specific emergency response plan into the community emerge ncy response plan. The cooperative effort started soon after the facility was acquired by Petroferm in 1998. LTC's emergency response plan assigns specific responsibilities to its staff to: 7 Provide critical information to emergency responders; 7 Notify local agencies of any emergency; and 7 Notify local authorities of the danger, if any, to areas surrounding the facility. Planned changes to improve safety Petroferm Inc. acquired the LTC facility in March 1998. Petroferm is planning and has already accomplished several facility improvements to reduce the risk of a chemical release, such as: 7 Improved security; 7 Better isolation of the EO handling system; 7 Installation of a water deluge system for the EO railcar; and 7 Redundant safety valves to prevent over pressurization of the EO rail car. LTC is planning the following additional improvements for the EO/PO processes: 7 Installation of a dedicated nitrogen system for the EO process; 7 Installation of temperature sensors and alarms for the EO railcar and transfer pump; 7 Automation of the chemical reactors where EO/PO are used; 7 Modernization of the facility including the replacement of aging equipment; 7 Gas detectors, for early leak detection, have been purchased and will be installed; and 7 A meteorological station together with state-of-the-art gas dispersion modeling software has been purchased and will be immediately available to predict potential off-site consequences should a release occur, based on then-current weather conditions. |