Southern Ionics Incorporated's Lake Charles Plant - Executive Summary |
|
14108 LDEQ Facility ID Number Executive Summary This Risk Management Plan (RMP) has been prepared by Southern Ionics Incorporated's, Lake Charles site to satisfy the requirements of the Clean Air Act Amendments (CAAA) Section 112 (r) mandated by the U.S. Environmental Protection Agency (40 CFR-part 68). The Southern Ionics Incorporated's site is located on Davison Road in Carlyss, Calcasieu Parish, Louisiana. The site occupies approximately 22 acres and has 16 full time employees on site. Currently the site produces 3 products which are additives used in the catalyst, water treatment and paper industries. With this being a new facility, we are starting with a clean safety record and have implemented the necessary safety programs to ensure a safe environment. Out of the three products manufactured at the Lake Charles site, only one of the raw materials used in the process falls under RMP requirements. That raw material is anhydrous ammonia. Anhydrous ammonia is used in the north section of the facility. Below is a brief description of the process area at the site. The aqua ammonia area is designed to produce various grades of ammonia solutions. These solutions are used in catalyst manufacturing and in wastewater treatment. In this area, raw materials are fed to a reactor. The reaction mass undergoes additional processing steps such as blending and cooling. The product is then transferred to storage areas. One RMP-regulated substance exceeding the threshold quantity was identified in the aqua ammonia area: Anhydrous ammonia at a maximum quantity of 153, 965 lbs. The first key element in the RMP regulations is that a facility must identify all processes that contain any RMP-regulated substances above their designated threshold quantities. Anhydrous Ammonia at a maximum quantity of 153, 965 lbs. The second key element in the RMP regulations, is to determine program levels for the RMP-regulated processes. These levels range from a Program 1 that imposes minimal requirements on a process to a Program 2 or 3 which require a much greater deal of effort. The Lake Charles site subject to the OSHA Process Safety Management (PSM) standard, 29 CFR 1910.119. The site's processes are also included in the nine SIC codes specified by the RMP rule. Therefore, the facility has designated its processes to be in the Program 3 level of the RMP. The third key element in the RMP regulations is that Program 3 facilities must conduct an offsite consequence analysis. Southern Ionics opted to use the EPA's guidance manual to establish toxic endpoint concentrations as well as the circle of influence. Using extremely conservative estimates of weather and release conditions, Lake Charles' offsite consequence analysis indicated that a worse-case toxic release scenario could have an impact area within a 6.9 mile radius from the site (see attached map). This scenario was based on the failure of a pressure vessel containing 153,965 lbs. of anhydrous ammonia, which has a toxic end point concentration of 0.14 mg/l. The 6.9 mile radius should not be considered a public danger zone but is instead an estimate of the maximum possible area that might be affected under extreme, unlikely, catastrophic conditions. The toxic end points specified for the regulated toxic substances are intended to be protective of the general public. These end points are concentrations below which it is believed nearly all individuals could be exposed for one-half to one hour without serious health effects. To prevent such a catastrophe from occurring, the following items have been installed on the anhydrous ammonia storage tank: pressure relief valves, excess flow valves, hydrostatic relief valves, fixed level indicators (50% and 85%), mechanical and electronic level indicators, and a pressure gauge. The pressure relief valves are piped via hard piping to the ammonia scrubber in case of a over pressurization of the anhydrous ammonia storage ta nk. A water fog system has also been installed to minimize a possible release of anhydrous ammonia. Utilizing the same EPA guidance manual, an alternative (more realistic) release scenario for anhydrous ammonia had an impact distance of 0.1 miles for the same toxic endpoint concentration. The alternative release scenario was based on a pipe break. A rigorous maintenance and inspection program minimizes the chance of even such accidents from occurring. Another key element of the RMP regulations is to develop and submit a five-year accident history involving RMP-regulated substances. Since this is a new facility, there is no prior accident history. In order to deal with potential accidents and emergencies, Southern Ionics has an Emergency Action- and Response Plan in place. In addition, Southern Ionics is in the process of applying for membership in mutual aid which is an organization that provides emergency response assistance during an accident. |