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MG Industries - West Lake

Parent Companies:
MG Industries
Messer
EPA Facility ID:
100000042955
Other ID:
Facility DUNS:
2233088
Parent Company #1 DUNS:
2233088
Parent Company #2 DUNS:
0

Location:

Address:
2745 Houston River Road
West Lake, LA 70669
County:
CALCASIEU
Lat / Long:
30.255, -93.278 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Center of Facility
Horizonal accuracy:
m
Horizontal reference datum:
Source map scale:

Owner/Operator:

Name:
MG Industries
Phone:
(318) 439-6544
Address:
2745 Houston River Road
West Lake, LA 70669
Foreign Address:

Person responsible for RMP implementation:

Name:
Lou Neiman
Title:
Plant Manager
Email:

Emergency contact:

Name:
Lou Neiman
Title:
Plant Manager
Phone:
(318) 439-6544
24-hour phone:
(800) 641-4357
Ext or PIN:
Email:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
18
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:
April 11, 1997
Inspecting Agency:
Fire Department
Using Predictive Filing:
No

Processes:

ASU Plant
RMP ID:
13241
CBI claimed:
No
Program Level:
3
NAICS:
Industrial Gas Manufacturing (32512)
Chemical name
CAS#
Quantity (lbs.)
CBI
Methane
74-82-8
40,126
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 16, 1999
Type:
First-time submission
Reason:
Registered:
No
RMP ID:
10465

Deregistration:

Date:
Effective Date:
Reason:
Other
Other Reason:
Not indicated

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 ASU Plant)
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 ASU Plant)
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

March 31, 1998 at 11:15
ID:
1117
NAICS:
Industrial Gas Manufacturing (32512)
Duration:
40 minutes
Chemicals involved:
  • Ammonia (anhydrous)
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None meters/second
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised training

7. Prevention: Program level 3

ASU Plant, Industrial Gas Manufacturing (32512)
Prevention Program ID:
6318
Safety Review Date
April 23, 1999, since latest RMP submission
PHA Update Date
March 13, 1998, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Fire
  • Overpressurization
  • Equipment failure
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Interlocks
  • Alarms
  • Rupture Disks
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • On the Job
Competency Testing
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
May 1, 1997, since latest RMP submission
Training Review Date
March 15, 1999, since latest RMP submission
Maintenance Review Date
May 27, 1999, since latest RMP submission
Maintenance Inspection Date
May 27, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
May 26, 1999
Pre-startup Review Date
April 3, 1999
Compliance Audit Date
March 13, 1998
Compliance Audit Change Completion Date
Sept. 15, 1999
Incident Investigation Date
March 31, 1998
Incident Invest. Change Completion Date
March 31, 1998
Participation Plan Review Date
March 13, 1998
Hot Work Review Date
March 13, 1998
Contractor Safety Review Date
March 13, 1998, since latest RMP submission
Contractor Safety Eval. Date
None, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
No
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:
Nov. 9, 1998
Local Response Agency:
Local Response Agency Phone:
(318) 436-7417
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

MESSER - MG INDUSTRIES - WEST LAKE AIR SEPARATION UNIT PRODUCTION FACILITY
RMP EXECUTIVE SUMMARY


INTRODUCTION - MESSER AMERICA'S LOSS PREVENTION PROGRAM

Loss Prevention management refers to the prevention of potential losses to Messer through an effectively designed, administered and implemented Environmental, Health, Safety and Regulatory Compliance program.

Incorporating an effective loss prevention program requires developing and integrating programs that will assist in reducing losses resulting from accidents. Messer GmbH has developed Safety, Health, and Environmental guidelines. These guidelines have been further refined and developed into a comprehensive program defined as Loss Prevention Policies (LPP) and are contained in this manual. These policies are the minimal standards for Messer America's (Central, North, South America and AGS) operations.

The objective of this program is to achieve an acceptable level of performance in the prevention of losses to the organization, which include but are not limited to; accidents, injuries, illnesses, product liabilities, regulatory non-conformities, etc. To be effective, this management system must be totally integrated in which all levels of employment are involved and held accountable.

The ultimate authority for instituting an effective Loss Prevention Program rests with the senior management of each operating Group. Through their words and more importantly through their actions, senior management sets the tone for loss prevention throughout Messer Americas. While senior management sets the tone, middle management must create the uniform support and nurture the desired culture to influence the Loss Prevention program. This strong management commitment culminates with the day to day responsibility of implementing and managing the Loss Prevention program by "line management" (supervisor and lead personnel). Local management is accountable for the effective management of this program through their organization
's performance as related to loss prevention and regulatory compliance (which includes company policies).

In a healthy loss prevention culture, each member of the company participates fully in the program. Loss prevention is no longer an activity that someone else is in charge of. Each manager, supervisor, driver, and line worker is personally responsible for insuring "safe working conditions, safe product for all customers and a safe environment for the citizens of the communities in which Messer operates".


SIMPLIFIED PROCESS DESCRIPTION

The MG Industries West Lake facility is an air separation manufacturing plant. The natural gas portion of the plant process falls within the RMP requirements. Air is filtered and compressed in a centrifugal compressor to 90 psig. After compression, heat is removed from the air with the aid of a cooling medium. The process air is subsequently passed through a vessel containing molecular sieve material to remove carbon dioxide and water. There are multiple vessels that are automatically sequenced that facilitates regeneration of sieve material with the use of dry nitrogen/air by-products gas. Throughout each step of production the process air is analyzed for impurities, and monitored for control limits, thereby maintaining product quality standards. The next stage of production involves cryogenic separation and purification. After leaving the compression/filtration stage, the process air enters a network of heat exchangers and distillation columns, housed in an insulated structure. Initially heat must be removed from the incoming process air. This is accomplished via a mult-pass counter current heat exchanger designed to bring the air temperature down to cryogenic conditions, by way of passing outgoing gaseous products through adjacent heat exchanger fins. The cold air now enters a double rectification column due to pressure and temperature differences between the components of air. The separation process begins to oc
cur. Oxygen and Nitrogen are circulated through both distillation columns which contain perforated trays stacked horizontally within the column. As the molecules filter through these trays, they become purer and concentrate at different levels in the column. Process control is accomplished through a series of detection points. Each component of air can be withdrawn at various standards of purity throughout the column.

The final step in this process involves liquefaction of the separated gases. Inside the rectification column, a portion of pure gaseous nitrogen is continuously withdrawn and sent to an externally located liquefier section. This gaseous nitrogen is routed through several loops before arriving at its final destination, as liquid back into the distillation column. The first loop sends gaseous nitrogen through a series of heat exchangers and compression equipment in order to provide a heat balance and volume to the system. The second loop draws a portion of compressed nitrogen and feeds this stream to an expansion turbine to achieve cryogenic temperatures in the liquifier section. The remaining unexpanded gas is liquefied by heat exchange with a turbine discharge streams and expanded back into the rectification column. This liquid nitrogen entering the column provides sufficient cooling to liquify the remaining gases. As liquid level are established and purity analysis is taken, quantities of liquid oxygen and nitrogen can be withdrawn for storage.

The aforementioned part of the process that involves a RMP regulated substance is the regeneration of the mole sieve material. Natural gas (methane) is used as a fuel to heat the regeneration gas for the vessel. The methane exists in quantities large enough for RMP submission. The safety-related equipment/devices are described later in this summary report.


WORST CASE RELEASE SCENARIO

The first step in the worst-case release analysis was to determine the total amount of natural gas onsite. It
was determined that there are 40,126 lbs of natural gas on-site. While there are safety devices and process controls on the equipment to prevent accidental releases, a large natural disturbance such as a tornado could rip through the facility and create a worst-case release of all of the natural gas. The determination of the affected distance to endpoint was made using the RMP*Comp software. The distance to endpoint was found to be 0.3 miles. The Landview III software package was used to determine the general environmental and community impact within this radius. There are approximately 60 people living within this radius. There is also one other business in the immediate area. There are no environmental receptors in the endpoint radius area.


ALTERNATIVE RELEASE SCENARIO

The best alternative scenario that could be developed that would have an offsite impact was modeling rupture in a 1" safety relief valve header resulting in natural gas escaping. A ten-minute time period was used for the release calculations. This is an estimate on the maximum amount of time required to close the upstream valve manually. The amount of natural gas released was calculated at 615 pounds using the RMP*Comp software. The distance to endpoint was found to be 0.1 miles. The Landview III software package was used to determine the general environmental and community impact within this radius. There are approximately 3 people living within this radius. There is also one business within the radius. There are no environmental receptors in the endpoint radius area.


GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS - LOSS PREVENTION WRITTEN POLICY

SUMMARY

The objective of the Messer Loss Prevention Program is to achieve an acceptable level of performance in the prevention of losses to the organization. The paramount importance of our Loss Prevention Program is assuring safe working conditions for our employees, safe product for our custom
ers, and a safe environment for the citizens of the communities in which we operate. This program is integrated with a series of Loss Prevention Policies that are the cornerstone of Messer Loss Prevention efforts. These policies form our Loss Prevention Policies Manuals. These manuals are maintained by local management and are available for review by any employee upon request during normal business hours. In addition, compliance with local and federal regulations such as OSHA, DOT, EPA are required.


AUTHORITY AND RESPONSIBILITY FOR PROGRAM IMPLEMENTATION

Plant Manager has the overall site authority for implementation of the Loss Prevention Program. He or she is responsible for the day to day management of the Loss Prevention Policies as they directly relate to all operational activities.
Terminal Manager is responsible for the day to day management of the Loss Prevention Policies as they directly related to distribution activities.
Site Safety Advisor is responsible for conducting periodic inspections, serving as the facility spokesperson (on Loss Prevention issues) and participation on the Safety Committee.
Regional Manager oversees the Loss Prevention activities of their region, conducts audits, introduces new and/or revised Loss Prevention Policies, participates in "Group" accident/incident investigations and assures that hazards are abated in a timely manner.


SYSTEM FOR IDENTIFYING, EVALUATING, AND PREVENTING OCCUPATIONAL SAFETY AND HEALTH HAZARDS HAS BEEN DEFINED THROUGHOUT THE LOSS PREVENTION MANUAL WHICH INCLUDE, BUT ARE NOT LIMITED TO:

() Review of applicable standards to the industry.
() Review and availability of Material Safety Data Sheets.
() Assure the proper labeling of potentially hazardous materials.
() Safety work permitting systems.
() Investigation of accidents/ incidents.
() Periodic and scheduled inspections of the general work areas.


EMPLOYEE COMMUNICATIONS AND TRAINING ARE ALSO DEFINED THROUGHOUT THE LOSS PREVENTION MANUAL WHICH I
NCLUDE, BUT ARE NOT LIMITED TO:

() Monthly poster program service by the National Safety Counsel on a variety of safety and health topics.
() Site specific Safety Bulletin Board for the posting of all environmental, health and safety related information i.e. Loss Prevention Policy, Injury/Illness Logs, safety posters, etc.
() Site specific Safety Committee made up of representative functional positions within the operation.
() Monthly Safety Meetings are held on various environmental, health, and safety related topics.
() Safety Orientation for all new hires and personnel transferred into new positions.
() Regulation Compliance training as it may apply to specific operations and/ or exposures i.e. Hearing Conservation, HAZCOM, Respiratory Protection, Fire Extinguishers, etc.


RECORDKEEPING

Loss Prevention records are maintained in the facilities Loss Prevention and Regulatory files. Access to these files is controlled by the respective manager. Distribution of these records requires authorization.


PROCESS SAFETY FEATURES

The MG West Lake facility has a Loss Prevention Program at both the local and corporate levels. The part of the process that is affected by RMP is natural gas. The natural gas system is protected by both safety relief valves and rupture disks. A manual emergency isolation shut off device is incorporated in the system. The facility is manned 24 hours a day with routine in-house inspections. In addition to the interlock systems, the entire process is equipped with emergency E-stops located throughout the entire facility.


FIVE-YEAR ACCIDENT HISTORY

In the past five years there was one reported accidental release at this facility. The substance released was anhydrous ammonia which is not part of this facility RMP because it is used and stored at below threshold levels. The release was the result of human error and involved the removal of a safety relief that was still under pressure. About 600 pounds of ammonia was released. The prop
er emergency response groups were notified and the release was controlled shortly thereafter. Additional information is found under Section 6 of this report.

EMERGENCY RESPONSE PROGRAM

The local fire department performs periodic visits to the facility and is a part of the facility emergency action plan. The fire department plays a critical role in this plan. MG relies on the fire department to assist in the control and mitigation of an incident at this site, wheras MG provides the technical expertise with respect to the equipment and product. A comprehensive Loss Control Program exists at the facility that is managed both locally and at the MG corporate level.


PLANNED CHANGES TO IMPROVE SAFETY

Opportunities are continually reviewed to improve the safety and reliability of the facility.