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Texas Butylene Chemical Corporation-Lake Charles

Parent Companies:
TPC Group LLC
EPA Facility ID:
100000030511
Other ID:
Facility DUNS:
102647005
Parent Company DUNS:
0

Location:

Address:
3501 Cities Service Highway
West Lake, LA 70669
County:
CALCASIEU
Lat / Long:
30.202, -93.325 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
TPC Group LLC
Phone:
(409) 724-4857
Address:
2102 Spur 136
Port Neches, TX 77651
Foreign Address:

Person responsible for RMP implementation:

Name:
Kevin Harren
Title:
Environmental Manager

Emergency contact:

Name:
Bill Morris
Title:
Head Operator
Phone:
(337) 882-1380
24-hour phone:
(337) 882-1380
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
3
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
March 21, 2017
Inspecting Agency:
USCG
Using Predictive Filing:
No

Processes:

Lake Charles Terminal
RMP ID:
1000086094
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Bulk Stations and Terminals (42471)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
6,000,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
March 19, 2018
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000068633

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Lake Charles Terminal)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Lake Charles Terminal)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Lake Charles Terminal, Petroleum Bulk Stations and Terminals (42471)
Prevention Program ID:
1000072726
Safety Review Date
March 12, 2017, since latest RMP submission
PHA Update Date
March 13, 2018, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Polymerization
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Floods
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
Jan. 4, 2018, since latest RMP submission
Training Review Date
Oct. 24, 2017, since latest RMP submission
Maintenance Review Date
July 31, 2016, since latest RMP submission
Maintenance Inspection Date
Jan. 4, 2018, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 13, 2017
Management of Change Review Date
March 12, 2015
Pre-startup Review Date
None
Compliance Audit Date
April 13, 2015
Compliance Audit Change Completion Date
Sept. 15, 2017
Incident Investigation Date
Sept. 15, 2013
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Aug. 31, 2016
Hot Work Review Date
Dec. 15, 2017
Contractor Safety Review Date
Feb. 19, 2018, since latest RMP submission
Contractor Safety Eval. Date
Jan. 25, 2018, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Feb. 12, 2018
Local Response Agency:
Local Response Agency Phone:
(337) 583-2365
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

This Risk Management Plan is for the Texas Butylene Chemical Corporation (TBCC) facility near Lake Charles, Louisiana. TBCC is owned and operated by TPC Group, LLC (TPC). The operation of the TBCC facility falls under the management systems of TPC Group, Port Neches, Texas Facility (PNO) as of May of 2007.





1. Accidental release prevention and emergency response policies. The TBCC facility is committed to providing a safe, healthy and environmentally conscious work place for its employees and neighbors. The PNO Facility, which includes TBCC, maintains a working OSHA Process Safety Management (PSM) program, which implements a series of steps to prevent potential hazards associated with the process and assures a well-trained work force. The PSM program further implements its policies with onsite procedures and manuals. The EPA Risk Management Program (RMP) has been built upon this existing PSM program. TBCC participates with the Calcasieu Parish Local Emergency Planning Committee (LEPC) and the Carlyss Fire Department in assisting local officials in the development of emergency response plans and participates in cooperative training with them. TBCC is also an associate member of the Mutual Aid Organization in the Westlake area. The facility complies with all applicable codes and standards regarding operating and equipment safety. The PNO Plant Manager is responsible for implementation of the Risk Management Program (RMP) at the TBCC Facility.



2. The stationary source and regulated substances handled. The TBCC Facility is located on the south side of Bayou D'Inde immediately east of Louisiana Highway 108. The facility consists of two spheres, two compressors, five pumps, two fire pumps, a small flare, and dock facilities. There is only one product handled at this site, finished/high purity Butadiene. Butadiene is a monomer used in the production of butadiene rubber and various butadiene co-polymers. The TBCC Facility receives stores and trans
fers finished butadiene.



3. General accidental release prevention program and chemical specific prevention steps. The following is a brief summary of the elements that have been implemented to comply with the accidental release prevention requirements outlined by the EPA in the RMP Rule, as well as, with the OSHA PSM standard.



Process Safety Information

The PNO Facility maintains a compilation of written safety information for the TBCC facility. This includes information pertaining to hazards of regulated substances, the technology of the covered process and the equipment in the covered process.



Process Hazard Analysis (PHA)

The PNO Facility has performed the revalidation of the PHA for the TBCC Facility to comply with 29 CFR 1910.119(e) and these hazard analysis apply to processes covered by RMP. The HAZOP methodology was utilized, a recognized and generally accepted method, for identifying, evaluating, and addressing hazards in the process. Checklists are also utilized to provide a review of potential human factors and facility siting concerns. Employees from the TBCC site participated in the revalidation study. The team developed recommendations to reduce the potential hazards which are further evaluated and implemented where beneficial. Recommendations are tracked until they are completed. The hazards imposed by hurricanes and inclement weather are minimally discussed during PHA's since this issue is well-covered by our Hurricane Preparedness Plan and Corporate Standards require designing equipment/structures to withstand high winds.



Operating Procedures

The TBCC Facility maintains written operating procedures, that were developed by operations, and provide clear instructions for safely operating the facility. These operating procedures are available to all employees who work in the processes. The procedures are reviewed at least annually and modified whenever needed to accommodate operational and process changes.



Training

The TB
CC Facility provides initial training as well as refresher training to employees who operate the processes to assure that the required level of skills and knowledge are maintained. Training documentation provides records of when training was received and whether or not the training was understood. All operators receive annual refresher training.





Mechanical Integrity

The PNO and TBCC Facilities have developed written procedures for maintaining the mechanical integrity of equipment in the covered process, including pressure vessels, storage tanks, piping systems, relief systems, emergency shutdown system controls, and pumps. The program is comprised of well-trained personnel who follow maintenance, testing and inspection procedures that ensure proper function of process equipment. This program includes the periodic inspection and testing of process equipment, as well as, the documentation of the results of these activities.



Management of Change

TPC has established and implemented written procedures to manage changes to process chemicals, technology, equipment, procedures, and any changes to the facility that affect a covered process. The procedures assure that, prior to any change, the following issues are considered: the technical basis for the proposed change, its impact on safety and health, any modifications to operating procedures, the necessary time period for the change, and any authorization requirements. Employees involved in operating a process, as well as maintenance and contract employees whose job will be affected, are informed of and trained in the change. If necessary, the process safety information and operating procedures are updated.



Pre-Startup Review

The TBCC Facility performs pre-startup reviews for major changes in a process that require modification to process safety information.



Compliance Audit

TPC performs audits of its compliance with the provisions of 29CFR1910.119 (PSM) and 40 CFR part 68 (RMP). Audits are con
ducted every three years to verify that the procedures and practices developed are adequate and being followed. The findings of the audit team are reviewed and tracked until completed. Appropriate corrective actions are implemented.



Incident Investigation

The PNO Facility, including TBCC, conducts an incident investigation for every incident that resulted in, or could reasonably have resulted in, a catastrophic release of a covered chemical. The investigation is promptly conducted. It is performed by a team consisting of persons with the appropriate knowledge and experience to thoroughly investigate and analyze the incident. A report is prepared at the conclusion of the incident investigation that addresses the incident, the factors that contributed to it, and recommendations resulting from the incident investigation. The recommendations are then tracked to completion.



Employee Participation

The PNO Facility, including TBCC, has a written employee participation plan that allows input from employees on the development and analysis of process safety management. PHA's and all other RMP information are available to all employees.



Hot Work Permit

The PNO Facility, including TBCC, has a procedure for the issuance of hot work permits for hot work conducted on or near a covered process (hot work generally involves electric or gas welding, cutting, brazing or similar spark-producing operations). If any hot work is performed near a covered process, a permit is issued that documents the fire prevention and protection requirements for the operation, the date authorized for hot work, and the object on which the work is performed.



Contractors

TBCC has processes for selecting and ensuring that contractors are competent and knowledgeable and can safely perform their work. Information is provided to contractors about the hazards that may be present in the work area and has developed appropriate safe work practices.



4. 5 Year Accident History. The
TBCC Facility has had no incidents in the last five years that have resulted in an off site impact.



5. Emergency Response Program. The Lake Charles TBCC Emergency Response Program is based on mutual aid and is strictly classified as a "defensive" program until mutual aid is summoned and arrives on site. In case of an emergency, Security personnel will be notified to contact the LEPC personnel.



All Operations personnel are trained and qualified in exterior fire fighting within one year of when they start working at the site. Due to the one to two man operations, the Operators can only feasibly open fire water monitor or use a fire extinguisher if the fire is in the incipient stage, thus the term "defensive".



Types of emergencies would include but is not limited to a fire, medical emergency, breach of security, terrorist threat or chemical spill on land or water.



TPC Emergency Response plans are reviewed and updated as needed. Likewise, the emergency equipment is inspected on a routine basis.



TPC Group / TBCC is actively involved with informing local officials concerning hazardous substances stored and processed on site. TBCC coordinates efforts with Calcasieu Parish LEPC and Carlyss Fire Department in assisting local officials in the development of emergency procedures and planning.



The Lead Operator is the main contact for the TBCC facility. The PNO Emergency Response Coordinator is the designated alternative contact. Initial response will be provided by the Carlyss Fire Department.



6. Planned changes to improve safety. Projects are being implemented as a result of HAZOP recommendations, employee suggestions, incident investigations, and other continuous improvement efforts. There is an ongoing commitment to implement changes, when identified, that will improve the safety and protection of employees and neighbors from accidental releases of hazardous chemicals.