Lonza, Inc. - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At this facility, we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as to protect the environment. A brief overview of the comprehensive risk management activities that we have designed and implemented include:
(1) A description of our facility and use of substances regulated by EPA's RMP regulation
(2) A summary of results from our assessment of the potential offsite consequences from accidental chemical releases
(3) An overview of our accidental release prevention programs
(4) A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
(5) An overview of our emergency response program
(6) An overview of planned changes to improve safety
1.0 STATIONARY SOURCE AND REGULA
This facility produces organic chemicals as intermediates for our customers to make dyes, pharmaceutical products, resins, and insecticides. The regulated substances listed in EPA's RMP rule in our facility are Dimethylamine, Isoprene, and 1,3-Pentadiene. They are all flammable substances. We do not handle any material in the toxic substance list of the EPA's RMP rule.
2.0 RELEASE SCENARIOS AND OFFSITE CONSEQUENCE ANALYSES
RMP rule requires that we provide information concerning the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative control and mitigation measures to limit the distances for each reported scenario:
2.1 Worst-case Release Scenarios - Regulated Flammable Substance
We do not have any regulated toxic substance. Two worst-case release scenarios from two regulated flammable substances are analyzed because they
affect different public receptors.
One scenario is the rupture of the Dimethylamine (DMA) storage tank with a maximum capacity of 75,100 pounds in the Tank Farm. This is the largest storage tank of DMA, and the release will be contained in a concrete containment area. This area is equipped with deluge system and fire fighting equipment. Assuming the released DMA has a vapor cloud explosion, the estimated affected endpoint is 0.31 miles according to the EPA's lookup tables. The potential public receptors include employees of plants Calgon, Dianal America, and E. I. DuPont. DMA is used to produce Dimethylacetoacetate (DMAA) in the Arylides unit.
The other scenario is the rupture of the Isoprene storage tank with a maximum capacity of 158,000 pounds in the Tank Farm. This is the largest storage tank of Isoprene, and the release will be contained in a concrete containment area. This area is equipped with deluge system and fire fighting equipment. Assuming the released Isop
rene has a vapor cloud explosion, the estimated affected endpoint is 0.43 miles according to the EPA's lookup tables. The potential public receptors include employees of plants Calgon, Dianal America, E. I. DuPont, and Montgomery Tank Liners. Isoprene is used to produce specialty anhydrides.
2.2 Alternative Release Scenarios - Regulated Flammable Substances
We do not have any regulated toxic substance. Two alternative release scenarios from two regulated flammable substances are analyzed because they affect different public receptors.
One scenario is the overfill of the DMA storage tank for 10 minutes at 65 gallons per minute in the Tank Farm. It releases 5420 pounds of DMA to the concrete dike area. This area is equipped with deluge system and fire fighting equipment. Assuming that the released DMA is ignited and has a flash fire, the estimated affected endpoint is 0.06 miles according to the EPA's lookup tables. The potential public receptor is the employees of Calgon
The other scenario is the overfill of the Isoprene storage tank for 10 minutes at 220 gallons per minutes in the Tank Farm. It releases 12,500 pounds of Isoprene to the concrete dike area. This area is equipped with deluge system and fire fighting equipment. Assuming that the released Isoprene is ignited and has a flash fire, the estimated affected endpoint is 0.06 miles according to the EPA's lookup tables. The potential public receptor is the employees of Montgomery Tank Lines.
3.0 OVERVIEW OF ACCIDENTAL RELEASE PREVENTION PROGRAMS
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including:
- Process safety information
- Process hazard analysis
- Operating procedures
- Mechanical integrity
- Management of change
- Pre-startup reviews
- Compliance audits
- Incident investigation
- Employee participation
Hot work permitting
- Contractor safety
These individual elements of our prevention program work together to prevent accidental chemical releases. Our facility and our employees are committed to safe work procedures defined by the prevention program. We have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.
4.0 FIVE-YEAR ACCIDENT HISTORY
We have not had any accidental releases from covered processes that have resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage during the past five years.
5.0 EMERGENCY RESPONSE PROGRAM
Our program covers various federal, state, and local regulatory requirements for emergency response planning. We have procedures and training for announcing the accidental releases, contacting the emergency responders, notifying the regulatory agencies and comm
unities, maintaining the emergency response equipment, and handling the emergency incidents. We have a trained emergency response team on site, and if needed, we coordinate with Channel Industries Mutual Aid (CIMA) for handling larger emergency incidents. Our emergency response team has training in fire school, rescue training, HAZMAT training, and has conducted joint training and drills with CIMA.
6.0 PLANNED CHANGES TO IMPROVE SAFETY
The Safety Awareness Program is designed and implemented by the plant safety, health and environment committee -
This program includes safety slogan contests, safety questionnaire contests, and celebration of safety milestone completion.