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BetzDearborn - RESERVE Plant

Parent Companies:
Hercules Incorporated
EPA Facility ID:
100000072725
Other ID:
70084BTZLB500RO
Facility DUNS:
123903148
Parent Company DUNS:
1315647

Location:

Address:
334 Rosenwald Street
Reserve, LA 70084
County:
ST. JOHN THE BAPTIST
Lat / Long:
30.070, -90.574 (Get map)
Method:
Interpolation - Map
Description:
Center of Facility
Horizonal accuracy:
m
Horizontal reference datum:
Source map scale:

Owner/Operator:

Name:
BetzDearborn Inc.
Phone:
(504) 536-4135
Address:
P. O. Drawer AS
Reserve, LA 70084 -0556
Foreign Address:

Person responsible for RMP implementation:

Name:
Clark J. Dyson
Title:
Plant Manager
Email:

Emergency contact:

Name:
Clark J. Dyson
Title:
Plant Manager
Phone:
(504) 536-4135
24-hour phone:
(800) 877-1940
Ext or PIN:
Email:

Other contacts:

Facility (or company) email:
Facility phone:
(504) 536-4135
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. John The Baptist Parish LE
Full-Time Equivalent Employees:
8
Covered by OSHA PSM:
No
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 18, 1998
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

Drum storage
RMP ID:
7004
CBI claimed:
No
Program Level:
2
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Cyclohexylamine [Cyclohexanamine]
108-91-8
49,984
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 21, 1999
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
5848

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 Drum storage)
CBI claimed:
No
Percent weight:
99.9
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
519.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
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 Drum storage)
CBI claimed:
No
Percent weight:
99.9
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

No Prevention Program level 3

8. Prevention Program level 2

Drum storage, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
3655
Safety Review Date
May 12, 1999, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Toxic Release
  • Fire
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Alarms
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Observation
Procedure Review Date
May 4, 1999, since latest RMP submission
Training Review Date
Feb. 28, 1997, since latest RMP submission
Maintenance Review Date
Feb. 28, 1997, since latest RMP submission
Maintenance Inspection Date
May 10, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

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:
Feb. 26, 1999
Local Response Agency:
Local Response Agency Phone:
(504) 652-6338
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Executive Summary

Accidental Release Prevention And Emergency Response Policies

Our company senior management and the facility personnel are committed to safety and implementation of safe procedures. We operate under our parent company, Hercules Incorporated's, policy for Safety, Health & Environment. This policy states:

"...we are dedicated to and working towards continuous improvement in our operations to prevent pollution; to reduce risk; and to enhance safety, health and environmental performance."

"We will evaluate the safety, health, and environmental impacts of new and existing products and operations and will work to reduce adverse impacts."

"We will work to continually reduce workplace injuries; incidents with the potential for causing property damage, material loss, or interruption of our business; waste; and releases to the environment."

Facility Description And The Regulated Substances Handled

BetzDearborn Inc. manufactures specialty water-treatment chemicals, primarily used for the treatment of water and wastewater in industrial process systems such as boilers and cooling towers.
Most of our products are formulated by blending several raw materials within a mixing vessel and then packaging into various size containers. Depending on our customer's needs, our package types can range from small 5-gallon pails to 6000-gallon truckload quantities.
Similarly, our raw materials, which we receive from suppliers, come in various size containers depending on customer demand for the product and the amount necessary to meet supply limitations and production demand.


The BetzDearborn - Reserve Plant covers 15.4 acres of property, of which 0.95 acre is used for offices, warehouse(s), production facilities and outdoor material storage. The balance is used for access roads, parking lot or open lawn, or idle areas.



At the facility, cyclohexylamine is a chemical raw material stored onsite as a liquid in 55-gallon drums. It acts as a corrosion inhibi
tor by neutralizing acids and elevating pH in steam condensate, which makes it particularly useful as a component of our product line and to our customers. This material is stored in a protected area and removed from any combustion sources.






The Worst-Case Release Scenario(s) And The Alternative Release Scenario(s)

Within the cyclohexylamine drum storage process, our "Worst Case" event involves a scenario where the contents of several drums are lost as an instantaneous release to an uncontained pavement outdoors during material transfer. Using the U.S. EPA Offsite Consequence Guidance modeling data, this scenario would have an offsite consequence. Although this material is normally stored in a protected containment area when not in transit, for the purposes of meeting the EPA requirements we did not consider any "passive" controls. We also conservatively viewed that an amount of several drums would be released without any intervention by plant personnel to stop the release or to control the spread of the release, even though our facility personnel are capable of responding to mitigate a release of this chemical in various ways.
Because all plant operators are well trained in hazardous chemical handling procedures, forklift operation, and spill response, we think that a release event of this sort is unlikely to occur.

As an "Alternative Scenario" an event more likely to occur than the "Worst Case" involving cyclohexylamine, we considered a release event of one single drum, again using the EPA methodology. Mitigation systems were not included in this scenario. The analysis indicates that this scenario would have an offsite consequence but it would be limited to a distance about half of the distance from the "Worst Case" scenario. We choose to evaluate this scenario because the EPA required an "Alternate Scenario" that extended beyond the fenceline, although we feel an event involving a minor drum puncture of substantially less than a drum quantity woul
d be more likely and would have no offsite consequences.


The General Accidental Release Prevention Program And Chemical-Specific Prevention Steps

The purpose of the program is to define steps that are taken to identify, evaluate, and prevent or mitigate releases of hazardous chemicals that could occur as a result of failures in processes, procedures, or equipment. The prevention program includes elements that cover the compilation of process safety information related to the process, performance of process hazard review to identify and evaluate potential release scenarios, development and use of operating procedures, processes for insuring proper training of employees who are involved in handling hazardous chemicals, preventive maintenance for key equipment to limit the potential for failures that could cause releases, processes for managing changes in the process and conducting incident investigations for any release events that may occur. The prevention program also includes requirements for performing compliance audits of the implementation of the prevention program.


The Five-Year Accident History

At the BetzDearborn - Reserve Plant we have not had any accidental releases that resulted in significant death, injury, property damage on-site or known offsite deaths, injuries, evacuations, sheltering-in-place, property or environmental damage in the past 5 years due to the use or handling of cyclohexylamine.




The Emergency Response Program





Our chemical release response program contains these elements:


- Identification of emergency organization personnel structure and functional responsibilities
- Quarterly inspections to determine any new sources of ignition and a check of safety control devices
- Fire extinguisher training
- Fire drills conducted by our facility
- Spill and release control instructions
- Evacuation procedures and external response notifications
- Incident coordination with local emergency responders
- Incident analysis and review
with all plant personnel, and identification of procedure changes
- Annual program review and re-training
- In applicable regions: Hurricane preparedness and plant readiness procedures


Planned Changes To Improve Safety

Our plans for safety improvement include: implementing a single layer-only operating practice, when transporting RMP-regulated substances on-site via forklift truck. Also, we intend to evaluate the feasibility of additional fire protection equipment to service RMP regulated processes.