Lobeco products, Inc. - Executive Summary |
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{\rtf1\ansi\ansicpg1252\uc1 \deff0\deflang1033\deflangfe1033{\fonttbl{\f0\froman\fcharset0\fprq2{\*\panose 02020603050405020304}Times New Roman;}{\f16\froman\fcharset238\fprq2 Times New Roman CE;}{\f17\froman\fcharset204\fprq2 Times New Roman Cyr;} {\f19\froman\fcharset161\fprq2 Times New Roman Greek;}{\f20\froman\fcharset162\fprq2 Times New Roman Tur;}{\f21\froman\fcharset186\fprq2 Times New Roman Baltic;}}{\colortbl;\red0\green0\blue0;\red0\green0\blue255;\red0\green255\blue255; \red0\green255\blue0;\red255\green0\blue255;\red255\green0\blue0;\red255\green255\blue0;\red255\green255\blue255;\red0\green0\blue128;\red0\green128\blue128;\red0\green128\blue0;\red128\green0\blue128;\red128\green0\blue0;\red128\green128\blue0; \red128\green128\blue128;\red192\green192\blue192;}{\stylesheet{\nowidctlpar\widctlpar\adjustright \fs20 \snext0 Normal;}{\*\cs10 \additive Default Paragraph Font;}}{\info{\title LOBECO PRODUCTS, INC}{\author Lobeco Products Inc.}{\operator dlawrence} {\creatim\yr2000\mo6\dy8\hr14\min34}{\revtim\yr2000\mo6\dy8\hr14\min34}{\printim\yr1999\mo6\dy3\hr14\min4}{\version2}{\edmins0}{\nofpages6}{\nofwords2342}{\nofchars13355}{\*\company }{\nofcharsws0}{\vern71}}\margl1440\margr1440 \widowctrl\ftnbj\aenddoc\hyphcaps0\formshade\viewkind4\viewscale75 \fet0\sectd \linex0\endnhere\sectdefaultcl {\*\pnseclvl1\pnucrm\pnstart1\pnindent720\pnhang{\pntxta .}}{\*\pnseclvl2\pnucltr\pnstart1\pnindent720\pnhang{\pntxta .}}{\*\pnseclvl3 \pndec\pnstart1\pnindent720\pnhang{\pntxta .}}{\*\pnseclvl4\pnlcltr\pnstart1\pnindent720\pnhang{\pntxta )}}{\*\pnseclvl5\pndec\pnstart1\pnindent720\pnhang{\pntxtb (}{\pntxta )}}{\*\pnseclvl6\pnlcltr\pnstart1\pnindent720\pnhang{\pntxtb (}{\pntxta )}} {\*\pnseclvl7\pnlcrm\pnstart1\pnindent720\pnhang{\pntxtb (}{\pntxta )}}{\*\pnseclvl8\pnlcltr\pnstart1\pnindent720\pnhang{\pntxtb (}{\pntxta )}}{\*\pnseclvl9\pnlcrm\pnstart1\pnindent720\pnhang{\pntxtb (}{\pntxta )}}\pard\plain \qc\nowidctlpar\widctlpar\adjustright \fs20 {\b\fs40 \par LOBECO PRODUCTS, INC.\tab }{\b\fs32 \par }{\b\fs36 Risk Management Program}{\b\fs32 \par }{\b\fs36 Executive Summary for Chemical Facilities}{\fs24 \par }\pard \nowidctlpar\widctlpar\adjustright {\fs24 \par This is an update, as required by 40 CFR 68.190 (Updates) to the RMP submitted by Lobeco Products, Inc. on 06/17/99. The updated submittal contains changes to the threshold quantity and % concentration of the chemical Oleum. Due to upgrades in the pipin g system relating to the 65% Oleum, a PHA was conducted by Lobeco Products, Inc. requiring an updated RMP as per 40 CFR 68.190.(b)(5). \par \par }\pard \qj\fi-360\li360\sa120\nowidctlpar\widctlpar\adjustright {\b\fs28 1.\tab Accidental Release Prevention and Emergency Response Policies \par }\pard \qj\nowidctlpar\widctlpar\adjustright {\fs24 We at Lobeco Products, Inc. are strongly committed to e mployee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental re lease prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with t he processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, we are completely coordinated with the Sheldon Township Fire District wh ich provides highly trained emergency response personnel to control and mitigate the effects of the release. \par \par }\pard \qj\fi-360\li360\sa120\nowidctlpar\widctlpar\adjustright {\b\fs28 2.\tab The Stationary Source and the Regulated Substances Handled \par }\pard \qj\nowidctlpar\widctlpar\adjustright {\fs24 Our facility\rquote s primary activities encompass High Technology Chemical Manufacturing. We have nine (9) regulated substances present at our facility. These substances include Oleum (Fuming Sulfuric acid), Methyl chloroformate, Formaldehyde, Muriatic acid (Hydrochlo ric acid), Monoisopropylamine (Isopropylamine), Dimethylamine, Ethylenediam i ne, Ammonia and Ethyl Chloride. The regulated substances at our facility are involved in several uses. Oleum (65% solution) and Formaldehyde (37% Solution) are used to manufacture a water based additive. Muriatic acid (32% solution) and Ethylenediami n e (99% solution) are used for Dye & Pigment manufacturing. Monoisopropylamine (70% solution) and Methyl chloroformate (97% solution) are used for manufacturing Herbicides. Dimethylamine (40% solution) is used in manufacturing an intermediate chemical for sale to other manufacturers. Ammonia (29% solution) is used for both Herbicide and Dye & Pigment manufacturing. Ethyl Chloride (30%) is a recycle stream generated by one of the Herbicide processes. \par \par The maximum inventory of Oleum (65%) that is expected to be present at our facility is 46,155\~ lb., while Formaldehyde (37%) is 50,000, Muriatic acid (32%) is 55,000, Monoisopropylam ine (70%) is 55,000, Methyl chloroformate (97%) is 40,800, Dimethylamine (40%) is 38,200, Ethylenediamine (99%) is 35,700, Eth yl Chloride (30%) is 65,000 and Ammonia (29%), which has two locations Tk# 8414 with 33,900 and Tk# T-17 with 55,000 are present at our facility. \par \par }\pard \qj\fi-360\li360\sa120\nowidctlpar\widctlpar\adjustright {\b\fs28 3.\tab The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative contr ols and mitigation measures to limit the distances for each reported scenario \par }\pard \qj\nowidctlpar\widctlpar\adjustright {\fs24 To evaluate the worst case scenarios, we have used the look-up tables and equations provided by the EPA in the }{\i\fs24 RMP Offsite Consequence Analysis Guidance}{\fs24 as well as Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance. For alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the }{\i\f s24 RMP Offsite Consequence Analysis Guidance}{\fs24 . The following paragraphs provide details of the chosen scenarios. \par \par The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Oleum Storage Tank T-8404. The scenario involves the release of 46,155\~lb. of Oleum (65% solution). Toxic liquid is assumed to be immediately released from which evaporation takes place, with a temperature of 102 degrees F and average ambient relative humidity of 72%. The entire pool is estimated to have evaporated over 2379.14 minutes. P assive mitigation controls such as a dike are also taken into account to calculate the scenario. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 0.55 miles is obtained corresponding to a toxic endpoint of 0.01000 mg/L. \par \par One alternative release scenario has been submitted for each toxic substance present in Program 2 and Program 3 process es cumulatively. \par \par The alternative release scenario for Oleum (65%) involves a release from a ruptured transfer hose between the Oleum Stor age Tank T-8404 and the delivery Tanker Truck with a release of 500 lb. of Oleum. Toxic liquid is assumed to be immediately released to form a pool of heigth 1 cm, from which evaporation takes place. The entire pool is estimated to evaporate over 35.50 minutes. Under neutral weather conditions, the maximum distance to the toxic end point of 0.01000 mg/L of Oleum (65%) is 0.09 miles. \par \par The alternative release scenario for Methyl chloroformate (97%) involves a ruptured transfer hose between the MCF Storage Tank #T-22 and the delivery Tanker Truck resulting in a release of 125\~ lb. of Methyl chloroformate. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 40.81 minutes. Under neutral weather con ditions, the maximum distance to the toxic endpoint of 0.0019 mg/L of Methyl chloroformate is 0.25 miles. \par \par The alternative release scenario for Ammonia (29%) involves a release of Ammonia from a ruptured transfer hose between the Ammonia Storage Tank #8414 and the delivery Tanker Truck resulting in the release of 340\~ lb. of Ammonia. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place . The entire pool is estimated to have evaporated over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.19 miles. \par \par \par \par \par \par \par The second alternative release scenario for Ammonia (29%) involves a release of Ammonia from a ruptured transfer hose between the Ammonia Storage Tank T-17 and the delivery Tanker Truck resulting in the release of 340\~ lb. of Ammonia. Toxic liquid is assumed to be immediately released to fo rm a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.19 miles. \par \par The alt ernative release scenario for Formaldehyde (37%) involves a release from a ruptured transfer hose between Formaldehyde Storage tank T-8413 and the delivery Tanker truck with a release of 500 lb. of Formaldehyde. Toxic liquid is assumed to be immediately released to form a pool heigth 1 cm, from which evaporation takes place. The entire pool is estimated to evaporate over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic end point of 0.012 mg/L of Formaldehyde is 0.11 miles . \par \par The worst case scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release of Monoisopropylamine from Storage Tank T-16. The scenario involves the release o f 55,000 lb. of Monoisopropylamine (97%). Passive mit igation systems such as dikes have been considered when evaluating this scenario. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10% of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.29 miles is obtained corresponding to an end point of 1 psi overpressure. \par \par The alternative release scenario submitted for program 2 and 3 flammable substances involves a release of Monoisopropy lamine from a ruptured transfer hose between Storage Tank T- 16 and the delivery Tanker truck which results in a vapor cloud explosion. The scenario involves the release of 560 lb. of Monoisopropylamine (97%) in 10 minutes. Under neutral weather conditi ons, the maximum distance to the flammable end point of 1 psi overpressure is 0.19 miles. \par \par Ethylenediamine (99%) classifies as a Program 1 process. The worst case scenario considered for this process involves a toxic substance, namely Ethylenediamine (99%). The quantity released in the scenario is assumed to be 35,700\~ lb.. Passive mitigation considered in the scenario includes dikes. Under worst case weather conditions, the maximum distance to the toxic endpoint of 0.49 mg/L is 0.24 miles. This distance is less than the distance to the nearest public receptor. \par \par Muriatic acid (32%), Dimethylamine (40%) and Ethyl Chloride (30%) were determined by the program as not meeting the requirements for any of the Program 1-2-3 reporting. \par \par \par \par \par \par \par }\pard \qj\fi-360\li360\sa120\nowidctlpar\widctlpar\adjustright {\b\fs28 4.\tab The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps \par }\pard \qj\nowidctlpar\widctlpar\adjustright {\fs24 Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed a nd constructed in accordance with NFPA-58 Standard, 1967 Edition. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements and has been issued an Air Operating Permit ID under Title V of the Clean Air Act. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. \par \par }{\fs24\ul Process Safety Information}{\fs24 \par Lobeco Products, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. \par \par }{\fs24\ul Process Hazard Analysis}{\fs24 \par Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology u sed to carry out these analyses are the \ldblquote HAZOP\rdblquote and \ldblquote What If Check Lists\rdblquote . The studies are undert aken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of three (3) years, or sooner if any changes to the process or system occur. Any findings related to the hazard analysis are addressed in a timely manner. \par \par }{\fs24\ul Operating Procedures}{\fs24 \par For the purposes of safely conducting activities within our covered processes, Lobeco Products, Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, and normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processe s. \par \par }{\fs24\ul Training}{\fs24 \pa r Lobeco Products, Inc. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every t hree (3) years and more frequently as needed. \par }{\fs24\ul \par Mechanical Integrity}{\fs24 \par Lobeco Products, Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these p ersonnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. \par \par }{\fs24\ul \par \par M anagement of Change}{\fs24 \par Written procedures are in place at Lobeco Products, Inc. to manage chang es in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal wit h the modification. \par \par }{\fs24\ul Pre-startup Reviews}{\fs24 \par Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Lobeco Products, Inc.. These reviews are conducted to confirm that constructi on, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. \par \par }{\fs24\ul Compliance Audits}{\fs24 \par Lobeco Products, Inc. conducts audits on a regular basis to determine whether the provisions set out under the R MP rule are being implemented. These audits are carried out at least every three (3) years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. \par \par }{\fs24\ul Incident Investigation}{\fs24 \par Lobeco Products, Inc. promptly inv estigates any incident that has resulted in, or could reasonably result in a release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of five (5) years. \par \par }{\fs24\ul Employee Participation}{\fs24 \par Lobeco Products, Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility\rquote s imple mentation of the RMP rule, including information resulting from process hazard analyses in particular. \par \par }{\fs24\ul Contractors}{\fs24 \par On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Lobeco Products, Inc. has a strict policy of informing the contractors of known potential hazards related to the contractor\rquote s work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. All c ontractors are required to attend a Lobeco Products, Inc. Safety Indoctrination prior to commencing any work within the plant limits and are given a written evaluated on their Safety Performance if their work involves areas associated with RMP processes. \par \par }\pard \qj\fi-360\li360\sa120\nowidctlpar\widctlpar \adjustright {\b\fs28 5.\tab Five-year Accident History \par }\pard \qj\nowidctlpar\widctlpar\adjustright {\fs24 Lobeco Products, Inc. has an excellent record of preventing accidental releases over the last five (5) years. Due to our stringent release prevention policies, there has been no accidental release during this period. \par \par }\pard \qj\fi-360\li360\sa120\nowidctlpar\widctlpar\adjustright {\b\fs28 6.\tab Emergency Response Plan \par }\pard \qj\nowidctlpar\widctlpar\adjustright {\fs24 Lobeco Products, Inc. carries a written emergency response plan to deal with accidental releases of hazardous materials. As part of the Beaufort County Local Emergency Response Committee (LEPC) actions, the plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. \par \par To ensure proper functioni ng, our emergenc y response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modification to our emergency response. \par }{\b\fs28 \par }\pard \qj\fi-360\li360\sa120\nowidctlpar\widctlpar\adjustright {\b\fs28 7.\tab Planned Changes to Improve Safety \par }\pard \qj\nowidctlpar\widctlpar\adjustright {\fs24 Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Existing dike systems have been modified and some new dikes constructed around those chemicals that ar e affected by the RMP Program. We have also constructed an enclosure around our Methyl chloroformate Storage Tank T-#22 as an added passive mitigation system. Also as part of our Methyl chloroformate modifications, we have initiated a semi-annual preven t ive maintenance program that verifies the integri ty of the associated pump for off-loading the chemical from the tank truck. These changes have already taken place, but Lobeco Products, Inc. is committed to continuously striving to provide safety feature s to prevent any accidental release of a hazardous chemical substance. \par \par }\pard \qj\sa120\nowidctlpar\widctlpar\tx360\adjustright {\b\fs28 8.\tab Certification Statement \par }\pard \qj\nowidctlpar\widctlpar\adjustright {\fs24 The designated representative below certifies that to the best of their knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. \par ( A signed Certification Letter has been included with the Electronic Submittal Package for Lobeco Products, Inc. ) \par \par Name: Greg Crawford \par Title: President, Lobeco Products, Inc. \par \par \par }} |