Louisiana Pigment Company, L.P. - Executive Summary |
|
Executive Summary 11496 LDEQ Facility ID Number Louisiana Pigment Company, L.P. (Louisiana Pigment) is one of the world's newest titanium dioxide manufacturing plants, beginning production in April 1992. The facility, located near Lake Charles, Louisiana, is comprised of a 40-acre "state-of-the-art" plantsite with an additional 100 acres used for parking, administrative offices, and storage of equipment and by-products. Product Utilization Louisiana Pigment manufactures in excess of 100,000 metric tons per year of titanium dioxide by utilizing the chloride process. Titanium dioxide is used in industry for generating brilliantly hued paints, in the manufacturing of primers and base coats, in automotive finishes, and in coatings for the exterior of buildings. Beyond this , titanium dioxide can also be found in many additional types of materials such as high-quality papers, color plastics, furniture panels, textile fibers, glass, ink, porcelain, toothpaste, cosmetics, candy, food coloring, PVC, white side wall tires, and a growing list of others. Most appliances and plastic packaging contain large quantities of titanium dioxide. Plastics are transparent and acquire their gleaming whites and opacities through the addition of titanium dioxide. Titanium dioxide also improves the physical properties of many plastics. It absorbs ultraviolet light, making the material more resistant to weathering. Manufacturing Process The chloride process at Louisiana Pigment uses high grade titanium ores (natural rutile, titanium ores, or synthetic rutile) to recover the titanium dioxide (TiO2 ). This is done by first producing titanium tetrachloride (TiCl4 ) as an intermediate product, oxidizing it to form TiO2 particles, and then washing the TiO2 particles to the purity required for further processing and finishing treatment. The two steps which most characterize the chloride process are the continuous chlorination of ore in the fluidized bed and the continuous oxidation of titanium tetrachloride in the gas phase to titanium dioxide using a burner. These two steps are completely dependent upon each other since the chlorine released by oxidation is recycled to the chlorinator. Through the use of analytical measurement and computer control technology, it is possible to optimize essential production variables, reduce down time to a minimum, and operate machinery at maximum safety standards. On the premise that operating conditions are kept at an optimum for every step of the chloride process, 90-95% of the titanium dioxide contained in the original ore can be recovered and used in the end product. Accidental Release Prevention Program The Federal Clean Air Act (CAA) Amendments of 1990 added Section 112(r) to the CAA, which mandated the U.S. Environmental Protection Agency (EPA) to establish a regulatory program to prevent serious chemical accidents that may potentially affect public health and the environment. The resulting regulations referred to a s EPA's Accident Prevention Program (Risk Management Planning), required certain companies, municipalities, and industries to provide information about potential risks associated with their operations. Louisiana Pigment assessed it operation and determined that titanium tetrachloride is stored at the facility in excess of the threshold quantity. Louisiana Pigment has made a commitment to our employees and community that we will endeavor to provide a safe workplace for our employees and to conduct our business as a responsible member of our surrounding community. In keeping with this policy established at the inception of the facility, Louisiana Pigment has designed our "Risk Management Program" to address Process Safety and to extend this attention to risk management "beyond our fence line". In accordance with OSHA 1910.119 (Process Safety Management), EPA's Accident Prevention (Risk Management Planning), and The Chemical Manufacturers Association's Responsible Care Initiative, the Louisiana Pigment's Risk Management Program comprises a series of management practices that support the goal of preventing fires, explosions and accidental chemical releases. Louisiana Pigment is committed to the Responsible Care Guiding Principles: To recognize and respond to community concerns about chemicals and our operations. To make health, safety, and environmental considerations a priority in our planning for all existing and new plants and processes. To operate our plants and processes in a manner that protects the environment and health and safety of our employees and the public. Risk Management is an interdisciplinary effort composed of Management Practices divided into four elements: Management Leadership Technology Facilities Personnel Collectively, these Practices encompass process safety from the design stage through operation, maintenance, and training. Louisiana Pigment believes that adherence to the Management Practices provides for a continuou s evaluation of our safety and environmental systems. Louisiana Pigment utilizes the elements of OSHA's PSM standard as the basis of our accidental release prevention program. Underscoring the belief that all prevention activities begin with management leadership and are effectively conducted via employee participation, we have built and improved upon an incident prevention program that has resulted in continuous improvement of our overall incident rate. Starting with sound incident investigation training, we have added a corrective action tracking data base that follows assignments of responsibility to insure completion of required actions. Furthermore, we have increased emphasis on near miss reporting via an employee incentive program and began conducting cross-functional Job Task Observations that review the employee's task as well as the written procedure and the required safety precautions. All integral activities to employee participation, we compliment the incident preventi on program with internal auditing of our area safety systems. Louisiana Pigment's Risk Management Program is complemented by workplace health and safety programs as well as waste and release reduction programs which address and minimize releases and waste generation. All of these programs, combined with our commitment to our employees and our community, provide a strong system to minimize the potential for chemical accidents that would have a detrimental impact. Emergency Response Program At Louisiana Pigment we work hard to ensure the best operating conditions, but we make sure we're prepared for the worst. Our emergency preparedness and response plans are well supported and thoroughly tested. There are five key components for a quality emergency preparedness and response plan: personnel, resources, planning, communications, and alliances. The program includes many methods and activities such as: Extensive training in our operational processes, maintenance activities, and sp ecific job safety training. Providing workplace monitoring to control and identify areas where appropriate personal protective equipment may be necessary. Providing state-of-the-art personal protective equipment, available to all personnel working at our facility. Utilizing employee input through our employee safety suggestion program. Conducting weekly safety meetings to discuss and provide resolutions to safety concerns. Maintaining an Executive Safety Committee which in itself promotes safety awareness through the use of employee involvement and various award programs. Providing an onsite medical department which conducts annual physicals and provides immediate care for employees in need. Louisiana Pigment maintains a voluntary onsite emergency response team. This team is comprised of chemical response, fire brigade, structural rescue, and emergency medical members. Each member is initially trained in specific functions within the team and then cross-trained in other functions. Onsite quarterly drills provide the team opportunities to maintain and enhance their skills. Community awareness plays a major role in our safety program. We are an active member of the Local Emergency Planning Committee (LEPC), the Southwest Mutual Aid Organization and participates in the Community Awareness Emergency Response (CAER) program. We also interact and provide a means for communication to our local community with programs such as neighborhood visits and an open house at which local residents are welcome to discuss their concerns. Louisiana Pigment is a member of the Louisiana Chemical Manufacturers Association (LCA), the Chemical Manufacturers Association (CMA) and actively supports the CMA's Responsible Care Initiative -- a public commitment by chemical manufacturers to improve industry performance in health, safety, and environmental quality. Maintaining this commitment to our employees and community is an ongoing effort. Continually pursuing opportuniti es for improvements in our safety programs and community interactions help us to be a responsible member of our surrounding community. Worst-Case Release Scenario and the Alternative Release Scenario Titanium Tetrachloride is the only chemical utilized at Louisiana Pigment that exceeds the threshold quantity established in EPA's Chemical Accident Release Program. Titanium Tetrachloride is produced as an intermediate product in the chloride process. The chemical is stored and process in the unit referred to as CPI. In assessing the off-site impact of the worst-case release and alternative release scenarios, Louisiana Pigment used the OCA Guidance Document. Worst-Case Scenario The worst-case scenario for Louisiana Pigment would be the catastrophic failure of our largest titanium tetrachloride vessel, Crude Titanium Tetrachloride Tank. Crude titanium tetrachloride is manufactured following the chlorination of titanium-bearing ore. The resulting crude titanium tetrachloride is se parated from the other metal chlorides and condensed. This crude titanium tetrachloride is then routed to an intermediate storage tank, Crude Titanium Tetrachloride Tank, prior to purification. The volume of this tank is 68 cubic meters or 245,639 pounds of crude titanium tetrachloride when at full capacity. This vessel is inside a building with a floor area of 16,136 square feet. If this vessel failed, the contents of the vessel would be released and fill the floor of the building. The release rate inside the building would be 4.744 pounds/minute (lbs/min) with a release rate out of the building of 474 lb/min. This release would last 51.8 minutes and the toxic endpoint would be 9.3 miles. This area would incorporate residences, industries, schools, a hospital, and recreational parks. Louisiana Pigment is a new facility built with "state-of-the-art" equipment. The instrumentation on the piping to and from the tank fail in a closed position. The titanium tetrachloride proce ss in the CPI unit is monitored with camera tied to the control room that is manned 24-hours a day. In addition, the building has a deluge system inside to control the vapors generated from the release, an emergency scrubbing system with vacuum hoses that can be used to intake vapors generated from the release to a pollution control device. Once vapors our outside of the building, they are controlled by the Emergency Response Team (ERT) members by putting up a water curtain around the building and monitoring any potential off-site impact. Alternative Release Scenario The alternative release scenario at the Louisiana Pigment would involve the failure of any piping or equipment in titanium tetrachloride service. At maximum rate, 22 metric tons per hour of titanium tetrachloride is produced/consumed in the chloride process. Upon failure of any piping or equipment, the plant can be automatically shutdown within a maximum of three (3) minutes. At 22 metric tons per hour (808.5 lb/ min), a three minute release would result in 2,425.5 lbs of titanium tetrachloride being released. The toxic endpoint is estimated to be 0.2 miles. This would encompass industry and some residences. The equipment and piping is primarily inside a building structure and is at elevated temperatures. In addition to the enclosure, the building contains a deluge system and vacuum hoses to an emergency scrubber to control the vapors from leaving the building. Once outside the building, the ERT would put up a water curtain around the building. Five-Year Accident History Since Louisiana Pigment began operation in 1992, we have incurred two incidents involving titanium tetrachloride which are included in the five-year accident history. On June 9, 1999, an estimated 2204 pounds of titanium tetrachloride was released. A shelter-in-place for the area was issued for less than one hour. On June 15, 1999, an injury occurred when a small amount of titanium tetrachloride was released in the un it during maintenance activities. Summary Louisiana Pigment is one of the world's newest titanium dioxide manufacturing plants, beginning production in 1992. The facility was designed and constructed using state-of-the-art technology for process control and employed environmental technology that meets and/or exceeds the regulatory requirements. We have established internal systems to evaluate and improve our manufacturing process, environmental controls, and safety programs that provide for ownership and accountability. These policies and procedures, including the Risk Management Plan, is in place to ensure that we will continue to operate a facility while maintaining our commitment to our employees and community of an environmental and safe workplace |