PILOT CHEMICAL COMPANY OF OHIO LOCKLAND PLANT - Executive Summary |
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The mission of Pilot Chemical is to manufacture chemicals in a safe, efficient and environmentally acceptable manner. Pilot Chemical is committed to the maintenance of a quality management system which meets the requirements of the International Standards Organization ISO 9002. This commitment requires the work force to focus on the production of a quality product through continuous improvement in all phases of its operations. The Pilot Chemical Company of Ohio, Lockland Plant occupies approximately 3 acres in an open, relatively flat, industrial area, north of Cincinnati, Ohio. The original facility was constructed in 1964. The facility produces detergent grade sulfonic acid, synthetic detergents, surfactants and emulsifiers through batch sulfonation and neutralizer systems for use in the industrial and personal care markets. The regulated substances on site exceeding threshold quantities are Sulfur Dioxide and Sulfur Trioxide, both of which are toxics. Sulfur Dioxide is a clea r, water-white liquid at temperatures below its atmospheric-pressure boiling point of 14oF. Sulfur Dioxide is stored on site as a liquefied, compressed gas at a pressure near 100 psi. Sulfur Dioxide vapors are colorless and heavier than air, but are extremely irritating and suffocating at concentrations above 30 ppm. With a distinctive rotten egg smell, Sulfur Dioxide has good warning properties with a odor threshold of 0.5 ppm. Sulfur Dioxide is stable and non-flammable in either the gaseous or liquid state. Sulfur Trioxide is a clear, colorless, oily liquid at temperatures between its freezing and boiling points, which are 90oF and 113oF respectively. Sulfur Trioxide has a strong irritating odor and is very hygroscopic, reacting violently with water. Sulfur Trioxide fumes react with the moisture in the air to form a dense, white cloud of Sulfuric Acid mist. This mist is extremely irritating to the eyes, skin and respiratory system. Residences are at least 600 feet from the m ain building containing the sulfonation processes and from the Sulfur Dioxide and Sulfur Trioxide storage tanks. The worst case toxic substance scenario is failure of a Sulfur Trioxide tank truck containing 35,000 lbs during the unloading process. The Sulfur Trioxide is spilled into a 293 sq ft concrete unloading dike. Since this facility is located in a populated area, the toxic cloud formed by the evaporating Sulfur Trioxide reacting with the moisture in the air would reach offsite endpoints and nearby public receptors. The scenario was modeled using the USEPA Risk Management Program Offsite Consequence Guidance. The alternative release scenario for Sulfur Trioxide is a failure of the tank truck unloading boom from a flange gasket or piping rupture during unloading of a tank truck. The Sulfur Trioxide is released at a flow rate of 50 gallons per minute into a 293 concrete unloading dike for two minutes before the Emergency Shutdown system is activated. The toxic cloud formed by the evaporating Sulfur Trioxide reacting with the moisture in the air would reach offsite endpoints and nearby public receptors. The scenario was modeled using the USEPA Risk Management Program Offsite Consequence Guidance. The alternative release scenario for Sulfur Dioxide is a failure of a pipe or flange gasket at the Sulfur Dioxide condenser located on the roof of the process building. The liquid Sulfur Dioxide (under pressure) is released at a rate of 30 gallons per minute for 3 minutes before the Emergency Shutdown system is activated. The Sulfur Dioxide is assumed to form a pool with a depth of 1 cm which completely vaporizes within 10 minutes. The toxic cloud formed by the evaporating Sulfur Dioxide would reach offsite endpoints and nearby public receptors. The scenario was modeled using the USEPA Risk Management Program Offsite Consequence Guidance. This facility has in place an accidental release prevention program that complies with all of the requirements of the O SHA Process Safety Management standard. In addition: 7 Sensitive Sulfur Dioxide and Sulfur Trioxide vapor detection systems are installed with monitors located in strategic locations throughout the processing areas to alert plant personnel of leaks. 7 The facility undergoes safety inspections by the Lockland Fire Department and our insurance company. 7 Before beginning any maintenance operation involving hot work, a Hot Work permit must be completed and signed by both production and engineering. 7 The computer controlled processes are "Fail safe" and include emergency shutdown capability that close isolation valves and stop chemical transfers to effectively limit the extent of a release. Instruments continuously monitor pressure, temperature and level in critical process vessels and automatically alarm if a parameter exceeds acceptable ranges. Equipment interlocking is utilized to prevent operation under unsafe conditions. 7 An extensive operator training program is in place that ut ilizes a combination of classroom training and demonstration of competency with evaluation by written test and observation. Operators receive training on new and revised operating procedures as well as personal and process safety. 7 All incidents are investigated, including very small drips and leaks, and actions are taken to prevent recurrence. 7 An extensive mechanical integrity program is in place which includes equipment preventive maintenance schedules, vessel thickness testing, relief system inspections and instrumentation calibration. 7 Pre-startup reviews are held prior to starting new or modified equipment per OSHA standards. 7 Routine audits of operating procedures and work instructions are conducted to assure that safe practices are followed. This facility has had no reportable accidents with off site consequences within the past 5 years. Because we believe that in the event of a chemical accident quick response is necessary to minimize the likelihood of onsite or offsite injuries, an extensive emergency response plan has been developed. In addition to the written plan: 7 All employees receive annual training on the use of the emergency response and evacuation plans, use of personal protective equipment, operation of fire extinguishers and spill mitigation techniques. 7 Currently, 8 plant personnel are trained at the 40 hour industrial emergency responder Technician level. Each technician receives annual refresher training. 7 The facility has a working relationship with the Lockland Fire Department. 7 Emergency response drills are performed regularly. 7 Emergency response equipment is on site. 7 A plant wide emergency notification system is in place. As a part of our commitment to continuous improvement planned changes to improve safety at the facility include: 7 Updating the control system software to be Y2K compliant. This update will be completed by September 30, 1999. The new system will also include advanced security features and more sophistic ated process upset alarming. 7 All mechanics and lead operators will receive industrial emergency responder Technician level training within the next two years. |