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Nalco Company - Garyville, LA facility

Parent Companies:
Nalco Company
EPA Facility ID:
100000032582
Other ID:
70051NLCCHRIVER
Facility DUNS:
50901669
Parent Company DUNS:
4962403

Location:

Address:
3628 Hwy 44
Garyville, LA 70051
County:
ST. JOHN THE BAPTIST
Lat / Long:
30.044, -90.631 (Get map)
Method:
Interpolation - Map
Description:
Plant Entrance (Personnel)
Horizonal accuracy:
100 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
15

Owner/Operator:

Name:
Nalco Company
Phone:
(985) 535-2221
Address:
3628 Hwy 44
Garyville, LA 70051
Foreign Address:

Person responsible for RMP implementation:

Name:
Sammy A. Edwards
Title:
SH&E Superintendent

Emergency contact:

Name:
Rafael Pons
Title:
Plant Manager
Phone:
(985) 535-2221
24-hour phone:
(985) 535-2221
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(985) 535-2221
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. John The Baptist Parish LE
Full-Time Equivalent Employees:
170
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:
May 20, 2015
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

EPI-DMA Polymer Productio
RMP ID:
1000073396
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Dimethylamine [Methanamine, N-methyl-]
124-40-3
163,768
No
Epichlorohydrin [Oxirane, (chloromethyl)-]
106-89-8
206,220
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Acrylamide Monomer Produc
RMP ID:
1000073397
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Acrylonitrile [2-Propenenitrile]
107-13-1
344,307
No
Public OCA Chemical
0
No
Ammonium Acrylate Monomer
RMP ID:
1000073398
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
56,814
No
Public OCA Chemical
0
No
DADMAC Manufacture
RMP ID:
1000073399
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Dimethylamine [Methanamine, N-methyl-]
124-40-3
163,768
No
Public OCA Chemical
0
No
Amine Blends
RMP ID:
1000073400
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Dimethylamine [Methanamine, N-methyl-]
124-40-3
163,768
No
Public OCA Chemical
0
No
Prism Polymer Manufacture
RMP ID:
1000073401
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Formaldehyde (solution)
50-00-0
108,720
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Aug. 31, 2016
Type:
Resubmission
Reason:
Revised OCA due to change (40 CFR 68.190(b)(6))
Registered:
Yes
RMP ID:
1000058803

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: 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 Prism Polymer Manufacture)
CBI claimed:
No
Percent weight:
37.0
Physical state:
Liquid
Model used:
AUTOMATED RESOURCE FOR CHEMICAL HAZARD INCIDENT EVALUATION
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: 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 EPI-DMA Polymer Productio)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Drains
  • Sumps
not considered:
  • Enclosures
  • Berms
Active mitigation
considered:
  • Deluge systems
  • Water curtain
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Acrylamide Monomer Produc)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Drains
  • Sumps
not considered:
  • Enclosures
  • Berms
Active mitigation
considered:
  • Deluge systems
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Ammonium Acrylate Monomer)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Deluge systems
  • Excess flow valve
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers
Public OCA Chemical (in Prism Polymer Manufacture)
CBI claimed:
No
Percent weight:
37.0
Physical state:
Liquid
Model used:
AUTOMATED RESOURCE FOR CHEMICAL HAZARD INCIDENT EVALUATION
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Drains
  • Sumps
not considered:
  • Enclosures
  • Berms
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

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 DADMAC Manufacture)
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 DADMAC Manufacture)
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

EPI-DMA Polymer Productio, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000061582
Safety Review Date
May 3, 2016, since latest RMP submission
PHA Update Date
April 20, 2015, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Increased Inventory
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
May 3, 2016, since latest RMP submission
Training Review Date
Dec. 2, 2014, since latest RMP submission
Maintenance Review Date
March 31, 2016, since latest RMP submission
Maintenance Inspection Date
Sept. 22, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 6, 2016
Management of Change Review Date
June 20, 2016
Pre-startup Review Date
June 6, 2016
Compliance Audit Date
Oct. 13, 2015
Compliance Audit Change Completion Date
Oct. 31, 2016
Incident Investigation Date
May 28, 2016
Incident Invest. Change Completion Date
May 28, 2016
Participation Plan Review Date
Aug. 10, 2015
Hot Work Review Date
June 8, 2016
Contractor Safety Review Date
Nov. 3, 2015, since latest RMP submission
Contractor Safety Eval. Date
June 6, 2016, since latest RMP submission
Acrylamide Monomer Produc, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000061583
Safety Review Date
Oct. 12, 2015, since latest RMP submission
PHA Update Date
April 9, 2015, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
June 21, 2016, since latest RMP submission
Training Review Date
Dec. 2, 2014, since latest RMP submission
Maintenance Review Date
March 31, 2016, since latest RMP submission
Maintenance Inspection Date
April 26, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 21, 2016
Management of Change Review Date
June 20, 2016
Pre-startup Review Date
June 21, 2016
Compliance Audit Date
Oct. 13, 2015
Compliance Audit Change Completion Date
Oct. 31, 2016
Incident Investigation Date
June 21, 2016
Incident Invest. Change Completion Date
Sept. 1, 2016
Participation Plan Review Date
Aug. 10, 2015
Hot Work Review Date
June 8, 2016
Contractor Safety Review Date
Nov. 3, 2015, since latest RMP submission
Contractor Safety Eval. Date
June 6, 2016, since latest RMP submission
Ammonium Acrylate Monomer, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000061584
Safety Review Date
March 18, 2016, since latest RMP submission
PHA Update Date
May 18, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Enclosure
Monitoring Systems
  • None
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
May 26, 2016, since latest RMP submission
Training Review Date
Dec. 2, 2014, since latest RMP submission
Maintenance Review Date
March 31, 2016, since latest RMP submission
Maintenance Inspection Date
Jan. 21, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 26, 2016
Management of Change Review Date
June 20, 2016
Pre-startup Review Date
May 26, 2016
Compliance Audit Date
Oct. 13, 2015
Compliance Audit Change Completion Date
Oct. 31, 2016
Incident Investigation Date
July 26, 2012
Incident Invest. Change Completion Date
Aug. 31, 2012
Participation Plan Review Date
Aug. 10, 2015
Hot Work Review Date
June 8, 2016
Contractor Safety Review Date
Nov. 3, 2015, since latest RMP submission
Contractor Safety Eval. Date
June 6, 2016, since latest RMP submission
DADMAC Manufacture, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000061585
Safety Review Date
March 15, 2016, since latest RMP submission
PHA Update Date
April 20, 2015, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Enclosure
Monitoring Systems
  • None
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
May 31, 2016, since latest RMP submission
Training Review Date
Dec. 2, 2014, since latest RMP submission
Maintenance Review Date
March 31, 2016, since latest RMP submission
Maintenance Inspection Date
May 17, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 23, 2016
Management of Change Review Date
June 20, 2016
Pre-startup Review Date
March 23, 2016
Compliance Audit Date
Oct. 13, 2015
Compliance Audit Change Completion Date
Oct. 31, 2016
Incident Investigation Date
April 20, 2016
Incident Invest. Change Completion Date
April 20, 2016
Participation Plan Review Date
Aug. 10, 2015
Hot Work Review Date
June 8, 2016
Contractor Safety Review Date
Nov. 3, 2015, since latest RMP submission
Contractor Safety Eval. Date
June 6, 2016, since latest RMP submission
Amine Blends, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000061586
Safety Review Date
Feb. 4, 2015, since latest RMP submission
PHA Update Date
April 20, 2015, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Process Parameters
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
March 31, 2016, since latest RMP submission
Training Review Date
Dec. 2, 2014, since latest RMP submission
Maintenance Review Date
March 31, 2016, since latest RMP submission
Maintenance Inspection Date
Oct. 30, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 6, 2016
Management of Change Review Date
June 20, 2016
Pre-startup Review Date
June 6, 2016
Compliance Audit Date
Oct. 13, 2015
Compliance Audit Change Completion Date
Oct. 31, 2016
Incident Investigation Date
May 28, 2016
Incident Invest. Change Completion Date
May 28, 2016
Participation Plan Review Date
Aug. 10, 2015
Hot Work Review Date
June 8, 2016
Contractor Safety Review Date
Nov. 3, 2015, since latest RMP submission
Contractor Safety Eval. Date
June 6, 2016, since latest RMP submission
Prism Polymer Manufacture, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000061587
Safety Review Date
April 14, 2016, since latest RMP submission
PHA Update Date
April 14, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
Training Type
  • Classrom
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
March 15, 2016, since latest RMP submission
Training Review Date
Dec. 12, 2014, since latest RMP submission
Maintenance Review Date
March 31, 2016, since latest RMP submission
Maintenance Inspection Date
May 4, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 6, 2016
Management of Change Review Date
June 20, 2016
Pre-startup Review Date
May 4, 2016
Compliance Audit Date
Oct. 13, 2015
Compliance Audit Change Completion Date
Oct. 31, 2016
Incident Investigation Date
April 25, 2012
Incident Invest. Change Completion Date
May 11, 2012
Participation Plan Review Date
Aug. 10, 2015
Hot Work Review Date
June 8, 2016
Contractor Safety Review Date
Nov. 3, 2015, since latest RMP submission
Contractor Safety Eval. Date
June 6, 2016, 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:
May 17, 2016
Local Response Agency:
Local Response Agency Phone:
(985) 652-2222
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

Risk Management Plan (40 CFR 68)

Executive Summary

Nalco Company

Garyville, LA





1.0 Accidental Release Prevention and Emergency Response Policies



At Nalco Company's Garyville facility, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:



? A description of our facility and use of substances regulated by EPA's RMP regulation

? A summary of results from our assessment of the potential off site consequences from accidental chemical releases

? An overview of our accidental release prevention programs

? A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule

? An overview of our emergency response program

? The certifications that EPA's RMP rule requires us to provide



2.0 Stationary Source and Regulated Substances



Our facility produces a wide variety of specialty chemicals using a variety of chemicals and processing operations. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant off-site consequences in the event of a substantial accidental release:



Toxics



Acrylonitrile

Ammonia

Epichlorohydrin

Formaldehyde (solution)



Flammables



Dimethylamine



Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.



3.0 Key Offsite Consequence Analysis Scenarios



EPA's RMP rule requires that we provide information about release scenarios for our facility
. Scenarios modelled for each chemical included:



? One inch hole in storage tank with passive mitigation

? One inch hole in transportation vessel with minimal mitigation

? Two inch hose or pipe failure with minimal mitigation

? One or two inch pipe/hose failure inside building with minimal mitigation.



The following are brief summaries of the scenario for each chemical with farthest impact distance:



Release Scenarios - Regulated Toxic Chemicals



Ammonia



The release scenario involves failure of a 2 inch hose or pipe while transferring ammonia. Using typical weather conditions specified by USEPA (Class D stability, 25 degrees C, 3.0 meters per second wind), RMP*Comp estimates that the ammonia could travel 0.5 miles before dispersing enough to no longer pose a significant hazard to the public. Within the potentially affected area are portions of the communities of Mt. Airy and Garyville, and one industrial facility. Active mitigation measures were used during this scenario.



Acrylonitrile



The release scenario involves failure of a 2 inch hose or pipe while transferring acrylonitrile. Using typical weather conditions specified by USEPA (Class D stability, 25 degrees C, 3.0 meters per second wind), RMP*Comp estimates that the acrylonitrile could travel 1.2 miles before dispersing enough to no longer pose a significant hazard to the public. Within the potentially affected area are portions of the communities of Mt. Airy and Garyville, and one industrial facility. Active and passive mitigation measures were used during this scenario.



Epichlorohydrin



The release scenario involves failure of a 2 inch hose or pipe while transferring epichlorohydrin. Using typical weather conditions specified by USEPA (Class D stability, 25 degrees C, 3.0 meters per second wind), RMP*Comp estimates that the epichlorohydrin could travel 0.8 miles before dispersing enough to no longer pose a significant hazard to the public. Within the potentially affected ar
ea are portions of the communities of Mt. Airy and Garyville, and one industrial facility. Active and passive mitigation measures were used during this scenario.



Formaldehyde



The release scenario involves failure of a 2 inch hose or pipe while transferring a formaldehyde solution. Using typical weather conditions specified by USEPA (Class D stability, 25 degrees C, 3.0 meters per second wind), the OCA Guidance estimates that the formaldehyde could travel 1.6 miles before dispersing enough to no longer pose a significant hazard to the public. Within the potentially affected area are portions of the communities of Mt. Airy and Garyville, and one industrial facility. Active and passive mitigation measures were used during this scenario.



Release Scenario - Regulated Flammable Chemicals



Dimethylamine



The release scenario involves failure of a 2 inch hose or pipe while transferring dimethylamine. RMP*Comp estimates that, if the release were to result in a vapor cloud explosion, it would affect an area within 0.1 miles of the tank. This area would be contained within the confines of the Nalco facility. Active mitigation measures were used during this scenario.



We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases.





4.0 General Accidental Release Prevention Program and Chemical-Specific Steps



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

? Training

? Mechanical integrity

? Management of change

? Pre-startup review

? Compliance audits

? Incident investigation

? Employee participation

? Hot work permit

? Contractors



As part of our prevention efforts, we have implemented the following chemi
cal-specific prevention steps:



Installation of deluge systems around storage tanks containing acrylonitrile, ammonia, epichlorohydrin, and dimethylamine;



Installation of deluge systems around unloading areas handling acrylonitrile, epichlorohydrin and dimethylamine;



Installation of chemical specific sensors controlling automatic shutoff valves in the acrylonitrile, dimethylamine and epichlorohydrin unloading areas;



A preventive maintenance program to inspect all chemical hoses used in the plant. These inspections include the transfer hoses used for unloading acrylonitrile, ammonia, dimethylamine, epichlorohydrin, and formaldehyde.



Written procedures to address unloading, leak detection and spill reporting in the acrylonitrile, ammonia, dimethylamine, epichlorohydrin, and formaldehyde unloading and storage areas.



Specific emergency instructions have been included in the D/3 computer "notebook" used to control production processes.



Drain covers have been purchased to improve spill control within the plant drainage system.





These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.





5.0 Five-year Accident History



We keep records for all accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years (2011 - present):



There has been one accidental chemical release involving ammonia above its Reportable Quantity (RQ) at our facility in the last five years. A small hole in the unloading hose released an estimated 135 pounds of anhydrous ammonia. There have also been small releases of acrylonitrile, ammonia
, and dimethylamine. None of these releases resulted in injuries to employees, nor did any of these releases affect the community or environment. After each of these incidents, we conducted formal incident investigations to identify and correct the root causes of the event. None of these incidents met the requirements to be reported under EPA's RMP.





6.0 Emergency Response Plan



We maintain a contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan.





7.0 Certifications



For all covered processes, the undersigned also certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted in this RMPlan is true, accurate, and complete.



Rafael Pons

Plant Manager

July 15, 2016











































Nalco Garyville RMP executive summary 7-2016.doc