Essroc Cement Corp. - Logansport, IN - Executive Summary |
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RISK MANAGEMENT PLAN - EXECUTIVE SUMMARY ESSROC CEMENT CORP. - LOGANSPORT, IN TRI FACILITY ID: 46947CPLYCSTATE INTRODUCTION Essroc Cement Corporation produces cement at its facility located at 3084 West C.R. 225 South, Logansport, Indiana. The cement kiln operation is fired by a combination of natural gas and an alternative fuel stream consisting of liquid organic wastes from other facilities. The liquid wastes are comprised of mixtures of solvents, other organics, and water. Some of the waste mixtures contain substances currently regulated under U.S. EPAs Risk Management Program (RMP) rule (40 CFR Part 68). The five regulated toxic substances identified are acrylonitrile, allyl alcohol, crotonaldehyde, formaldehyde (solution), and vinyl acetate monomer. The RMP rule regulates storage and use of these substances at the facility. Essroc has an on-going commitment to regularly assess safety and accident prevention measures and actively strives to meet or exceed all applicable USEPA and OSHA rules and regulations. The accident prevention and emergency response procedures implemented are designed to protect Essroc employees, properties, and the general public to the greatest extent possible. Essroc maintains on-site emergency equipment and trained personnel and has integrated its emergency response procedures with the Cass County Local Emergency Planning Committee. The designated representative and contact person for environmental matters and this Risk Management Plan at the Essroc facility is Mr. Brian Graf, Senior Environmental Manager. He can be contacted at the facility at (219) 739-6127. REGULATED SUBSTANCE HANDLED The liquid alternative fuels combusted at the Logansport facility are received in bulk shipping containers from a number of liquid waste blenders and suppliers. Shipping containers are typically either 5,000 gallon tanker trucks or 22,000 gallon rail car tankers. Upon reaching the facility, the material is unloaded to mixed blending ta nks, where liquid wastes are blended to create solutions for efficient combustion in the kiln. Once blended, the liquids are transferred to bulk storage tanks prior to use in the kiln burner. While the liquid wastes received can vary in composition from batch to batch, Essroc has reviewed historical records to determine the highest concentration of the regulated substances anticipated. These worst-case concentrations were utilized to determine the maximum potential quantities of regulated substances present at the facility at any time. Acrylonitrile arrives on site in rail car quantities in a mixture concentration of up to 15 percent. The maximum quantity of acrylonitrile on site is approximately 48,000 pounds. Allyl alcohol arrives on site in rail car quantities in a mixture concentration of up to 15 percent. The maximum quantity of allyl alcohol on site is approximately 47,000 pounds. Crotonaldehyde arrives on site in tanker truck quantities in a mixture concentration of up t o 40 percent. The maximum quantity of crotonaldehyde on site is approximately 43,000 pounds. Formaldehyde arrives on site in rail car quantities in a mixture concentration of up to 40 percent. The maximum quantity of formaldehyde on site is approximately 79,000 pounds. Vinyl acetate arrives on site in rail car and tanker truck quantities in a mixture concentration of up to 40 percent. The maximum quantity of acrylonitrile on site is approximately 210,000 pounds. RELEASE SCENARIOS The worst-case release scenario developed for the facility was the instantaneous release of the largest single quantity of acrylonitrile on site at any time, in this case approximately 24,000 pounds from a 22,000 gallon rail car, and evaporation and the ensuing air dispersion from the puddle formed. This scenario assumed the release occurred in an on-site rail siding storage area, so no administrative or passive controls were available to minimize the impact of the release. The resulting off-site impac t area was estimated using the SLAB atmospheric dispersion model, which resulted in a distance to the toxic endpoint for acrylonitrile of 2.9 miles. The alternative release scenario for each of the five regulated substances at the facility was a pipe release of 500 gallons during liquid fuel transfer activities, due to a piping, flange or pump casing failure. The normal fuel blending and transfer activities at the Logansport facility indicated the selection of this potential release mechanism. Other alternative release scenarios examined, including fuel unloading hose failure and pump seal failure, resulted in much smaller areas of impact due to a release. Alternative release scenarios were modeled with the presence of passive mitigation, in this case a diked secondary containment area, and active mitigation, emergency shutdown systems. Use of the SLAB atmospheric dispersion model resulted in distances to the toxic endpoint for each of the five regulated substances ranging from 0. 03 to 0.16 miles. FIVE YEAR ACCIDENT HISTORY Essroc has had only one accidental release in the past five years, an incident which occurred in February, 1999 and is still currently under investigation. No one off-site was injured, but a number of people were evacuated or sheltered in place as a precautionary measure during the release. Essroc has since discontinued acceptance of the fuel, and the specialized handling and preparation activities which may have been involved in the incident. PREVENTION AND EMERGENCY RESPONSE PROGRAMS The prevention of hazards at Essroc Cement Corp.'s Logansport, IN TSD Facility is achieved through the use of safe operating practices, complete personnel training, proper facility design in accordance with standard state-of-the-art industry practices as well as national building, fire and electrical codes, and daily attention to those areas where preventative measures have the greatest effect. The Hazard Prevention Program describes the features of t he cement kiln and TSD storage systems that contribute to continued safe operation. Components include standard operating guidelines security provisions, inspection requirements, preparedness and prevention requirements, preventative procedures, equipment and structures, and prevention of ignition and reaction of waste. Essroc has developed a written emergency response plan for the facility and is included in the community emergency response plan. The plans include specific actions to be taken in response to accidental releases of regulated substances at the facility. These plans also outline Essroc's coordination with the Cass County emergency planning committee and local emergency responders, and public notification systems. Essroc personnel receive both classroom and on the job training, including competency training, for both operational and emergency situations. |