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LaRoche Industries Inc. - Gramercy Facility

Parent Companies:
LaRoche Industries Inc.
EPA Facility ID:
100000087997
Other ID:
70052LRCHCPOBOX
Facility DUNS:
8182289
Parent Company DUNS:
150995942

Location:

Address:
1134 Jefferson Highway
Gramercy, LA 70052
County:
ST. JAMES
Lat / Long:
30.059, -90.667 (Get map)
Method:
Interpolation - Map
Description:
Administrative Building
Horizonal accuracy:
m
Horizontal reference datum:
Source map scale:

Owner/Operator:

Name:
Steven M. Parker
Phone:
(225) 869-6406
Address:
1134 Jefferson Highway
Gramercy, LA 70052 -5500
Foreign Address:

Person responsible for RMP implementation:

Name:
Ed Patz and Todd Johnson
Title:
Environmental Health & Safety
Email:

Emergency contact:

Name:
Ed Patz
Title:
Environmental Engineer
Phone:
(225) 869-6357
24-hour phone:
(225) 869-6400
Ext or PIN:
Email:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Full-Time Equivalent Employees:
104
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:
Feb. 24, 1999
Inspecting Agency:
Lousiana Department of Environmental Quality
Using Predictive Filing:
No

Processes:

Chlor-Alkali Plant
RMP ID:
8470
CBI claimed:
No
Program Level:
3
NAICS:
Alkalies and Chlorine Manufacturing (325181)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
3,523,000
No
Public OCA Chemical
0
No
HCFC-141b
RMP ID:
8471
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen fluoride/Hydrofluoric acid (conc 50% or greater) [Hydrofluoric acid]
7664-39-3
340,182
No
Vinylidene chloride [Ethene, 1,1-dichloro-]
75-35-4
175,085
No
Chlorine
7782-50-5
10,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
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:
No
RMP ID:
7045

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
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 Chlor-Alkali Plant)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
Model used:
EPA's OCA Guidance Reference Tables or Equations
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 Chlor-Alkali Plant)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's OCA Guidance Reference Tables or Equations
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:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in HCFC-141b)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's OCA Guidance Reference Tables or Equations
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:
  • 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 HCFC-141b)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • dikes
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 HCFC-141b)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • Dikes
not considered:
  • 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

July 4, 1995 at 07:40
ID:
689
NAICS:
Alkalies and Chlorine Manufacturing (325181)
Duration:
20 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
4.0 meters/second SE
Temperature:
86.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
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:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Overpressurization
  • Upset condition
  • Maintenance activity/inactivity
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Took the restricted stripper out of service;upgraded chlorine header piping

7. Prevention: Program level 3

Chlor-Alkali Plant, Alkalies and Chlorine Manufacturing (325181)
Prevention Program ID:
3718
Safety Review Date
June 26, 1998, since latest RMP submission
PHA Update Date
May 1, 1995, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
May 21, 1999, since latest RMP submission
Training Review Date
June 28, 1998, since latest RMP submission
Maintenance Review Date
June 28, 1998, since latest RMP submission
Maintenance Inspection Date
April 26, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 18, 1999
Management of Change Review Date
June 28, 1998
Pre-startup Review Date
None
Compliance Audit Date
June 28, 1998
Compliance Audit Change Completion Date
July 31, 1999
Incident Investigation Date
April 21, 1999
Incident Invest. Change Completion Date
Oct. 31, 1999
Participation Plan Review Date
June 28, 1998
Hot Work Review Date
June 28, 1998
Contractor Safety Review Date
June 28, 1998, since latest RMP submission
Contractor Safety Eval. Date
April 28, 1999, since latest RMP submission
HCFC-141b, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
3719
Safety Review Date
June 28, 1998, since latest RMP submission
PHA Update Date
April 1, 1995, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Polymerization
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 19, 1999, since latest RMP submission
Training Review Date
April 14, 1999, since latest RMP submission
Maintenance Review Date
June 28, 1998, since latest RMP submission
Maintenance Inspection Date
May 3, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 1, 1999
Management of Change Review Date
June 28, 1998
Pre-startup Review Date
Aug. 1, 1993
Compliance Audit Date
June 28, 1998
Compliance Audit Change Completion Date
July 31, 1999
Incident Investigation Date
April 21, 1999
Incident Invest. Change Completion Date
Oct. 31, 1999
Participation Plan Review Date
June 28, 1998
Hot Work Review Date
June 28, 1998
Contractor Safety Review Date
June 28, 1998, since latest RMP submission
Contractor Safety Eval. Date
April 28, 1999, 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:
Nov. 1, 1997
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:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Executive Summary for the LaRoche - Gramercy Plant

1. Accidental Release Prevention and Emergency Response Policies
We at LaRoche Industries Inc. - Gramercy Facility are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances.

We also have a thorough emergency response plan in place in which our employees and local responders are familiar with through periodic training. Should a release occur that requires emergency response, the Saint John CAER, Saint James LEPC, and the Saint James Mutual Aid Organization stand ready to work with us to implement this plan and provide highly trained emergency response personnel to control and mitigate the effects of the release.

2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass two RMP-covered processes: Process 1 - Manufacture of Chlorine; and Process 2 - Manufacture of HCFC 141b. We have four regulated substances present at our facility. These substances include Chlorine, Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid], and Vinylidene chloride [Ethene, 1,1-dichloro-]. Of the four regulated substances, three are stored/handled at quantities greater than the Threshold Quantities. The fourth material is a trade secret material which is stored/handled in a manner that does not subject it to coverage under this regulation. The regulated substances are involved in several uses at our facility. Chlorine is manufactured from the electrolysis of a brine solution (salt water) in Process 1 and is used to treat our cooling water and as a process additive in Process 2. In Process 2, Hydrogen fluoride/Hydrofluoric ac
id [Hydrofluoric acid] and Vinylidene chloride [Ethene, 1,1-dichloro-] are reacted to form the HCFC-141b product.

The maximum inventory of Chlorine at our facility is approximately 3,533,000 lb. (1,766.5 tons) while Hydrogen fluoride/Hydrofluoric acid [Hydrofluoric acid], and Vinylidene chloride [Ethene, 1,1-dichloro-] are present at our facility in quantities of approximately 340,000 lb. (170 tons), and approximately 175,000 lb. (87.5 tons), respectively. These maximum inventory amounts listed above are a summation of all process vessels, piping, cylinders, etc. used to store/handle the chemicals.

3. The Worst-Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To evaluate the worst-case scenarios, we have used the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance as well as Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance. Similarly for alternative release scenario analyses, we have employed the look-up tables and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. Neutral weather conditions are defined as D atmospheric stability and a windspeed of 3.0 m/s and worst-case weather conditions are defined as F atmospheric stability and a windspeed of 1.5 m/s.

Toxics - Worst-Case Release Scenario

The worst-case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from the Chlor-Alkali Plant. The scenario involves the release of 800,000 lb. (400 tons) of Chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L.

Toxics - Alternate Release Scenarios

One alternative release scenario wil
l be submitted for each toxic substance present in Program 3 processes (Process 1 and Process 2).

The alternative release scenario for Chlorine involves a release from Rail Car Loading in the Chlor-Alkali Plant process (Process 1). The scenario involves the release of 100 lb. of Chlorine. The liquid chlorine is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 0.31 miles (1,637 feet).

The alternative release scenario for Hydrogen fluoride [Hydrofluoric acid] involves a release from Process Piping in the HCFC-141b process (Process 2). The scenario involves the release of 49 lb. of Hydrogen fluoride in a gaseous form over 21 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.016 mg/L of Hydrogen fluoride is 0.06 miles (317 feet).

Flammables - Worst-Case Release Scenario

The worst-case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from Tank #1 (TK-1) in the HCFC-141b process. The scenario involves the release of 175,000 lb. (87.5 tons) of Vinylidene chloride [Ethene, 1,1-dichloro-]. Passive mitigation systems such as dikes have been considered when evaluating this scenario. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst-case weather conditions, the maximum distance of 0.27 miles (1,426 feet) is obtained corresponding to an endpoint of 1 psi overpressure.

Flammables - Alternate Release Scenario

The alternative release scenario submitted for Program 3 flammable substances involves a release from Tank #1 (TK-1) in the HCFC-141b process. The release is assumed to result in a Vapor Cloud Explosion
. The scenario involves the release of 175,000 lb. (87.5 tons) of Vinylidene chloride [Ethene, 1,1-dichloro-] in 10 minutes. The likelihood of an explosion involving the entire contents of Tank #1 is extremely low. The regulation requires that the Alternate Release Scenario extend beyond the facility limits and the only scenario that meets that criterion is an explosion involving the entire contents of Tank #1. Passive mitigation controls such as dikes are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.18 miles (950 feet).

4. The Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with Kaiser Aluminum and Chemical, Hooker Chemical, and Mine Safety and Health Standards. It is maintained and modified in accordance with current standards including, ASME, API, and NFPA Standards. Both processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.

Process Safety Information
LaRoche Industries Inc. - Gramercy Facility maintains a detailed record of safety information that describes the chemical hazards in the form of Material and Safety Data Sheets (MSDSs), operating parameters within the operating procedures documents, and equipment designs in the Process and Instrument Diagrams (P&IDs) associated with all processes.

Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology u
sed to carry out these analyses for both Process 1 and 2 is Hazard and Operability Study (HAZOP). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. The PHA for Process 1 was conducted on May 1, 1995 and Process 2 was conducted on April 1, 1995. Any findings related to the hazard analysis will be addressed by May 1, 2000 for Process 1 and by April 1, 2000 for Process 2.

Operating Procedures
For the purposes of safely conducting activities within our covered processes, LaRoche Industries Inc. - Gramercy Facility maintains comprehensive written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is readily accessible to operators involved in the processes. The OPs for Process 1 were last reviewed on May 21, 1998 and the OPs for Process 2 were last reviewed on June 19, 1998.

Training
LaRoche Industries Inc. - Gramercy Facility uses computer-based, classroom and on the job methods for its training program to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed.

Mechanical Integrity
LaRoche Industries Inc. - Gramercy Facility carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are presently carried out by a combination of 1) contractors that specialize in services ranging from tank and piping thickness tests to tank and piping tightness tests
and 2) facility personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.

Management of Change
Written procedures are in place at LaRoche Industries Inc. - Gramercy Facility to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.

Pre-startup Reviews
Pre-startup safety reviews related to new processes and to modifications in established processes are conducted prior to startup at LaRoche Industries Inc. - Gramercy Facility. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Process 1 has never conducted a PSSR because the process has not been significantly modified from the initial design. A PSSR was performed for Process 2 on August 1, 1993.

Compliance Audits
LaRoche Industries Inc. - Gramercy Facility conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. The last compliance audit was performed by KEMRON Environmental Services, Inc. on June 28, 1998.

Incident Investigation
LaRoche Industries Inc. - Gramercy Facility investigates, within 24 hours, any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release
from reoccurring. All reports are retained in the main office building at our facility for a minimum of 5 years.

Employee Participation
LaRoche Industries Inc. - Gramercy Facility truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. All of our RMP documents are kept under strict document control (the documents cannot leave the property) and our employees can review the documents while on site.

Contractors
Our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. LaRoche Industries Inc. - Gramercy Facility has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.

5. Five-year Accident History
LaRoche Industries Inc. - Gramercy Facility has had an excellent record of preventing accidental releases. Due to our stringent release prevention policies, the number of accidental releases has been reduced to a minimum. In the last five years only one incident (7/4/95) meeting the RMP criteria has occurred at our facility. According to the RMP Rule, an accidental release is defined as one that resulted in death, injuries, significant property damage, evacuations, shelter in place, or environmental damage.

A release of 12 lb. of Chlorine, occurred on 07/04/1995 due to equipment failure. The Saint James Parish Sheriff's Department shut down Route 61 located
north of our facility as a precautionary measure.

6. Emergency Response Plan
LaRoche Industries Inc. - Gramercy Facility has an emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.

To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. The plan is also promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. In addition, we conduct periodic emergency response drills to keep our employees and local responders familiar with the plan.

7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. We are upgrading our HazMat team and combining all of our various response plans into one single plan. We have improved our perimeter monitoring systems as well as our accident simulation system. We have implemented a computer work order system to track preventative maintenance and predictive maintenance items. We are constantly looking to improve our Environmental Health and Safety performance.