Protein Technologies International - Louisville - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies Protein Technologies International, Inc., a wholly owned subsidiary of E.I. DuPont de Nemours & Co., owns and operates a soybean isolate facility in Louisville, Kentucky. It is the policy of Protein Technologies International, Inc. to comply with all applicable federal, state and local environmental and safety laws and regulations, and to conduct its business in an environmentally sound manner that avoids any unreasonable adverse impact on the environment or its neighboring community. In keeping with this policy, Protein Technologies International, Inc. has developed and implemented a risk management program to ensure the safety of its employees and the neighboring community. The risk management program includes procedures to (1) identify potentially hazardous chemicals at the facility, (2) for maintaining a safe working environment and, thereby, help prevent the release of hazardous chemicals, and (3) for minimizing the consequences of a release should one occur. Stationary Source and Regulated Substances Handled Protein Technologies International, Inc.'s Louisville facility produces soy protein isolate, polymers for paper coating ingredients and adhesives, and co-products feed and polysoy flour. The major processes at the Louisville facility include storage of soybean flakes, protein extraction, protein modification, de-watering, drying, grinding, and packaging. Raw materials are delivered to this facility by both tank trucks and railcars. The only RMP regulated chemical handled by Protein Technologies International, Inc.'s Louisville facility is sulfur dioxide. Sulfur dioxide is used at this facility in the manufacture of several products. Sulfur dioxide is used in the process to bleach products to improve their color, help promote stability in the drying process and to quench the process by lowering the pH. The sulfur dioxide is delivered to the facility by supplier tank cars as ordered . The sulfur dioxide is unloaded into an above ground storage tank, surrounded by a containment dike, and used at the facility as required. The facility has administrative controls to limit the amount of sulfur dioxide in the tank to 80% of the storage capacity. Sulfur dioxide is also subject to OSHA's Process Safety Management (PSM) regulations, therefore this chemical is subject to the RMP Program 3 requirements. Worst-Case and Alternate-Case Release Scenarios Worst-Case The worst-case release scenario for toxic substances, by definition, is the maximum amount of sulfur dioxide that could be released from the storage tank and the ancillary piping, taking into consideration administrative controls to limit the storage quantity, over a period of 10 minutes. The maximum amount of sulfur dioxide estimated to be released in this scenario is 80% of the storage tank capacity. It is assumed that the sulfur dioxide, which is stored as a liquid under pressure, would immediately volatil ize into the gas phase upon release into the atmosphere and that passive mitigating measures like the containment dike would be ineffective to control the release. The specific distance to the toxic endpoint, using EPA's RMP Comp model, is provided in the risk management plan. This release has the possibility of extending beyond the facility's plant boundary. Alternate-Case The alternate-case release scenario is defined as a break in a transfer line from the sulfur dioxide storage tank to the process. The sulfur dioxide release rate is estimated as a typical sulfur dioxide usage rate for a product produced at the facility. The release duration for this scenario is estimated using the default value of 60 minutes even though excess flow valves would likely stop the release sooner. The specific distance to the toxic endpoint, using EPA's RMP Comp model, is provided in the risk management plan. This release has the possibility of extending beyond the facility's plant boundary. Gen eral Accidental Release Prevention Program and Specific Prevention Steps Protein Technologies International, Inc.'s Louisville facility is subject to both EPA's Accidental Release Prevention program and OSHA's Process Safety Management (PSM) program. Under both of these programs, the facility has outlined specific procedures that it follows to prevent or minimize the release of sulfur dioxide to the environment. Specifically, the facility has performed a process hazard analysis (PHA) of the sulfur dioxide system and will repeat this process at least every 5 years. The purpose of the PHA is to provide a systematic approach for identifying, evaluating, and controlling potential hazards associated with the sulfur dioxide system. In addition, the facility performs regular training of its employees to ensure that the procedures developed for the safe use and handling of the sulfur dioxide system are adhered to at all times. Finally, the facility has a regular inspection and maintenanc e program to ensure that the sulfur dioxide system is operating according to specific safety standards. Five Year Accident History Protein Technologies International, Inc.'s Louisville facility has not had an accidental release of sulfur dioxide within the last 5 years. If a release would occur, Protein Technologies International, Inc. would conduct a formal incident investigation to identify and correct the causes leading up to the accident. Emergency Response Program Protein Technologies International, Inc.'s Louisville facility has an emergency response program, cited as TAB Q-7, a document that has been developed in coordination with the Jefferson County Local Emergency Planning Committee (LEPC) and has been incorporated into the LEPC's emergency planning and response procedures. This facility does not have an in-house emergency response team, therefore, all emergencies other then incidental releases will be handled by the local emergency responders through the 911 system. S ince the facility does not have an in-house emergency response team, it is not required to have an emergency response plan. However, the facility has confirmed that local responders do have the equipment and training necessary to respond effectively to an accidental release of sulfur dioxide from this facility. Planned Changes to Improve Safety Protein Technologies International, Inc.'s Louisville facility has no plans to make any changes to the sulfur dioxide system for safety or other reasons at this time. Since the sulfur dioxide system is regulated under OSHA's Process Safety Management Program, however, it will be subjected to regular process hazard analyses reviews for the purpose of identifying and implementing potential improvements. |