LOMAC LLC - Executive Summary

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Company Policy 
Lomac LLC is dedicated to a three-fold safety and environmental protection philosophy in the operation of its manufacturing facilities. Our company is committed to safety with respect to protection of the environment and the community, to safety in the production, handling and disposal of chemicals, and to safety in the workplace. In pursuing this philosophy, we will continue our efforts to consider community concerns, to comply with all applicable environmental and occupational safety and health laws, to inform our employees of any physical and health hazards associated with the chemicals they handle, and to cooperate with governments and others in formulating industry standards in safety and environmentally-related areas. 
 
Facility Description 
Primary Activities -  
Lomac LLC employs over 150 employees who live and work in the Muskegon, Michigan area. Lomac has been in the community since 1987, and is a quality producer of synthetic organic and agricultural chemicals. O 
ur products are used locally and nationwide by the agricultural sector and industry. Our synthetic organic chemicals are used to produce specialty rubber products and pigments for paint and ink. 
 
Use of Regulated Substances -  
Lomac's operations include six processes that use substances above the threshold quantities that are listed at 40 CFR 68.130. These substances, the processes in which they are used, and quanities stored are shown in Table 1.1. The Chemical Accident Prevention rules encourage users of listed substances to either find a substitute substance or revise its purchasing/inventory policy to reduce to below EPA's threshold quantities, the quantity of the substance on-site at any given time. 
 
Accidental Release Scenarios 
Worst-case Release Scenario -  
The worst-case scenario is defined as a rapid and complete release of the largest container of the chemical under conditions that would maximize the potential impact. It assumes that none of the site's control systems requiri 
ng energy or human intervention are operational, but passive, administrative controls may be considered. 
 
For Lomac, the worst-case scenario is the instantaneous failure of the anhydrous ammonia storage tank wherein the entire contents are released without restraint over a ten-minute period. The company's release prevention storage policy limits storage of this material to 50 percent of tank capacity, or 75,000 lb, however, and this limits the potential impact area to 4 miles from the point of release. 
 
Alternative Release Scenarios -  
The likelihood of a complete storage tank rupture is extremely remote, however, and a more realistic alternative worst-case release scenario is a release resulting from the failure of a transfer hose or coupling during an off-loading (material delivery) operation. Each of the substances used in covered processes are delivered by a tanker truck and off-loaded with pumps. At all times during the off-loading process, the truck driver and a Lomac employee ar 
e present to shut off the pump in the event of a hose failure, coupling malfunction, or the like. 
 
Table 1.2 - Summary of Alternative Release Scenarios 
Chemical    Accident Prevention  
In-Place    Scenario    Distance of Concern 
Anhydrous Ammonia    7 Maximum quantity stored reduced to half tank capacity 
7 Tank is located inside a dedicated concrete dike 
7 Automatic excess flow shutoff valves on inlet pipe and pressure equalization line to limit releases 
7 Deluge spray system with remote actuation switch    7 Failure of 1= " hose connection during off-loading 
7 Average weather conditions 
7 Total release of 90 lb    0.12 miles 
Ammonium Hydroxide (Aqueous Ammonia)    7 Tank is located inside a concrete dike 
7 Remote pump shut-off switches 
7 Constant surveillance during off-loading operation    7 Failure of hose connection during off-loading 
7 Average weather conditions 
7 Total release to atmosphere of 48 lb    0.14 miles 
Nitric Acid    7 Maximum quantity stored limited to less than half tank capacity 
7 Tank is locate 
d inside a concrete dike 
7 Remote pump shut-off switches 
7 Constant surveillance during off-loading operation    7 Failure of hose connection during off-loading 
7 Average weather conditions 
7 Total release to atmosphere of 345 lb    0.5 miles 
Oleum    7 Tank is located inside a concrete dike 
7 Remote pump shut-off switches 
7 Constant surveillance during off-loading operation    7 Failure of hose connection during off-loading 
7 Average weather conditions 
7 Total release to atmosphere of 205 lb    0.19 miles 
Phosphorus Oxychloride    7 Maximum quantity stored limited to 60% of tank capacity 
7 Tank is located inside a dedicated building and a concrete dike 
7 Remote pump shut-off switches 
7 Constant surveillance during off-loading operation    7 Failure of hose connection during off-loading 
7 Average weather conditions 
7 Total release to atmosphere of 145 lb    0.81 miles 
 
Release Prevention Program 
Limited Storage -  
EPA encourages the use of smaller storage vessels to limit potential impacts and possibly avoid  
the application of the 40 CFR, Part 68 rules. Accordingly, Lomac has initiated administrative procedures to limit maximum storage quantities as much as possible, without unduly increasing delivery traffic. Storage of anhydrous ammonia, nitric acid, and phosphorus oxychloride are limited to 50, 40, and 60 percent of tank capacity, respectively. 
 
Other Release Mitigation Programs -  
A study of each chemical indicates that if a release is likely to occur, it will result from the failure of the delivery hose system during off-loading of chemicals. Accordingly, Lomac has employed remote shut-off systems for each of its five regulated chemicals. The anhydrous ammonia system utilizes excess flow valves that snap shut immediately upon sudden increases in gas flow owing to a sudden pressure drop that accompanies a hose failure. 
 
The other four chemicals are liquids pumped at atmospheric pressure. Remote pump deactivation switches have been installed to permit the chemical operator attendant to  
deactivate the pump immediately in the event of a hose failure. All these systems are designed so that no liquid can flow unless the pump is operating. 
 
All of the storage tanks are located inside diked areas to limit potential releases in the event of leakage from a tank system component. 
 
Additional measures have been taken regarding phosphorus oxychloride and anhydrous ammonia. The phosphorus oxychloride storage tank is housed inside a building to keep the dike dry, because phosphorus oxychloride will react with rainwater and snow. Ammonia, on the other hand, is highly soluble in water. Therefore, a remotely activated water deluge system has been installed at the anhydrous ammonia tank. In the event of a leak from the tank system, the water sprays will be turned on to absorb the fumes and prevent the release to the air. 
 
Process Safety Management Program -  
The design and operation of these storage activities are subject to Lomac's process hazard analysis and prestartup safety revie 
w programs.  Lomac has all elements of the PSM program in place. 
 
Operator Training -    
Operators reveive extensive training before they are released to work in the plant.  3-5 dyas of classroom training is rpovided before any time is spent in the plant.  Once in the plant, the operators work with other lead operators and supervisors for a period of 4-8 weeks.  Only after they have been fully trained and have demonstrated knowledge of the process can they be released to work in the plant un-supervised. 
Five-Year Accident History 
 
During the past five years, Lomac has not had any releases of covered chemical processes that have resulted in deaths, injuries, or significant property damage on-site. 
 
Emergency Response Program 
 
Lomac has an emergency response plan in place that is coordinated with local fire departments.  Lomac has many employees that are trained to the Hazardous Materials Technician Level and are able to aggressively respond to on-site emergencies.  Lomac maintains appro 
priate emergency response equipment such as PPE, vacuum trucks and tank trucks to be able to effectively, quickly and safely respond to emergency situations. 
 
 
Planned Changes to Improve Safety - Lomac's accidental release prevention program has incorporated a number of capital projects, training programs, and administrative changes to reduce the potential for chemical releases. This program is an on-going process however, and not only will new installations meet these program standards, but the program itself will be revised as periodic inspections and audits determine the need for improvement.
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