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Syngenta Crop Protection, LLC - St. Gabriel Plant

Parent Companies:
Syngenta Crop Protection, LLC
EPA Facility ID:
100000092614
Other ID:
70776cbggyriver
Facility DUNS:
114749984
Parent Company DUNS:
966616633

Location:

Address:
3905 Hwy 75
St. Gabriel, LA 70776
County:
IBERVILLE
Lat / Long:
30.247, -91.103 (Get map)
Method:
Interpolation - Photo
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Bryce Danna
Phone:
(225) 642-1100
Address:
P.O. Box 11
St. Gabriel, LA 70776 -0011
Foreign Address:

Person responsible for RMP implementation:

Name:
Todd Bartow
Title:
HSES Lead

Emergency contact:

Name:
PSS
Title:
Plant Shift Superintendent
Phone:
(225) 642-1585
24-hour phone:
(225) 642-1318
Ext or PIN:
Email:
N/A

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Iberville Parish LEPC
Full-Time Equivalent Employees:
333
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2898,2904,2931
OSHA Star/Merit Ranking
Yes
Last Safety Inspection Date:
July 1, 2014
Inspecting Agency:
State environmental agency
Using Predictive Filing:
Yes

Processes:

HCN/HPF
RMP ID:
1000052721
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Pesticide and Other Agricultural Chemical Manufacturing (32532)
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
500,000
No
Sulfur dioxide (anhydrous)
7446-09-5
24,000
No
Hydrocyanic acid
74-90-8
1,000,000
No
Chlorine
7782-50-5
31,000
No
Isopropylamine [2-Propanamine]
75-31-0
590,000
No
Ethylamine [Ethanamine]
75-04-7
590,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
MMU
RMP ID:
1000052722
CBI claimed:
No
Program Level:
3
NAICS:
Pesticide and Other Agricultural Chemical Manufacturing (32532)
Chemical name
CAS#
Quantity (lbs.)
CBI
Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl-]
584-84-9
280,000
No
Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl-]
91-08-7
71,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Vic Cross
Address:
3905 Hwy 75
St. Gabriel, LA 70776 -0011
Foreign Address:

Phone:
(225) 642-1483

Latest RMP Submission:

Date:
June 12, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000042732

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 HCN/HPF)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
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 HCN/HPF)
CBI claimed:
No
Percent weight:
Physical state:
Gas
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:
  • Excess flow valve
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in HCN/HPF)
CBI claimed:
No
Percent weight:
Physical state:
Gas
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:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in HCN/HPF)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
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:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in HCN/HPF)
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:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in MMU)
CBI claimed:
No
Percent weight:
96.8
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
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in MMU)
CBI claimed:
No
Percent weight:
30.0
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
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

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 HCN/HPF)
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 HCN/HPF)
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
Public OCA Chemical (in HCN/HPF)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Relief valves
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

HCN/HPF, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000044398
Safety Review Date
May 18, 2015, since latest RMP submission
PHA Update Date
May 18, 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
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
  • Process Controls
  • Process Detection
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Nov. 22, 2017, since latest RMP submission
Training Review Date
June 12, 2017, since latest RMP submission
Maintenance Review Date
Nov. 29, 2017, since latest RMP submission
Maintenance Inspection Date
Jan. 5, 2018, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 1, 2018
Management of Change Review Date
Jan. 30, 2017
Pre-startup Review Date
Dec. 4, 2017
Compliance Audit Date
Aug. 19, 2016
Compliance Audit Change Completion Date
Aug. 1, 2019
Incident Investigation Date
Nov. 26, 2017
Incident Invest. Change Completion Date
Oct. 31, 2018
Participation Plan Review Date
Feb. 8, 2017
Hot Work Review Date
Feb. 11, 2016
Contractor Safety Review Date
March 8, 2017, since latest RMP submission
Contractor Safety Eval. Date
Jan. 4, 2018, since latest RMP submission
HCN/HPF, Pesticide and Other Agricultural Chemical Manufacturing (32532)
Prevention Program ID:
1000044399
Safety Review Date
March 28, 2016, since latest RMP submission
PHA Update Date
March 28, 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
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
  • Process Controls
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Jan. 18, 2018, since latest RMP submission
Training Review Date
Dec. 9, 2016, since latest RMP submission
Maintenance Review Date
Nov. 29, 2017, since latest RMP submission
Maintenance Inspection Date
Nov. 13, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 19, 2018
Management of Change Review Date
Jan. 30, 2017
Pre-startup Review Date
Dec. 11, 2017
Compliance Audit Date
Aug. 19, 2016
Compliance Audit Change Completion Date
Aug. 1, 2019
Incident Investigation Date
Jan. 9, 2018
Incident Invest. Change Completion Date
March 30, 2018
Participation Plan Review Date
Feb. 8, 2017
Hot Work Review Date
Feb. 11, 2016
Contractor Safety Review Date
March 8, 2017, since latest RMP submission
Contractor Safety Eval. Date
Jan. 9, 2018, since latest RMP submission
MMU, Pesticide and Other Agricultural Chemical Manufacturing (32532)
Prevention Program ID:
1000044400
Safety Review Date
Nov. 14, 2016, since latest RMP submission
PHA Update Date
Nov. 14, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Overpressurization
  • Equipment failure
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Grounding Equipment
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Dec. 12, 2017, since latest RMP submission
Training Review Date
Dec. 5, 2017, since latest RMP submission
Maintenance Review Date
Nov. 29, 2017, since latest RMP submission
Maintenance Inspection Date
Feb. 9, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
July 19, 2017
Management of Change Review Date
Jan. 30, 2017
Pre-startup Review Date
Nov. 18, 2016
Compliance Audit Date
Aug. 19, 2016
Compliance Audit Change Completion Date
Aug. 1, 2019
Incident Investigation Date
April 13, 2016
Incident Invest. Change Completion Date
May 3, 2016
Participation Plan Review Date
Feb. 8, 2017
Hot Work Review Date
Feb. 11, 2016
Contractor Safety Review Date
March 8, 2017, since latest RMP submission
Contractor Safety Eval. Date
Jan. 4, 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:
Jan. 11, 2018
Local Response Agency:
Local Response Agency Phone:
(225) 687-5140
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

100000092614 EPA Facility Identifier



2367 LDEQ Facility ID Number



The Syngenta St. Gabriel Plant manufactures and formulates pesticides and specialty chemicals. Specific processes include: 1) manufacture, formulation and packaging of s-triazine herbicides, 2) manufacture of hydrogen cyanide, a raw material, 3) manufacture, formulation, and packaging activities for various other pesticides, herbicides and specialty chemicals, and 4) supportive activities for the above, which include effluent treatment systems, maintenance, utilities, and analytical and quality control.



Safety in Syngenta Crop Protection's St. Gabriel Plant site is incorporated into all aspects of plant operation and is foremost in the design, maintenance and operation of every process. The facility is guided by an operational philosophy that "safety shall not be compromised for economy". Syngenta is proud to be certified as an OSHA VPP STAR facility. We have verifiably achieved a level of safety performance far surpassing our industry counterparts.



The following information fulfills the requirements of 40 CFR 68.155;



(a) The accidental release prevention and emergency response policies at the stationary source;



Syngenta is committed to safety. This commitment is supported from the corporate senior management down to the plant workers. Employees at Syngenta participate in several groups committed to safety at the plant. These include a Unit Health and Safety Committees and the Total Safety Team.

Some of our awards and recognitions that reflect our strong safety and environmental commitments include: Award for Pollution Prevention Activities (LaDEQ), Environmental Leadership Program Pilot Program (DEQ/EPA), Gold Medal for Corporate Environmental Achievement (World Environmental Center), Total Quality Management Award (Malcolm Baldridge) and the National Award for Environmental Sustainability (Renew America). A major award the facility received in 2008 is the Platinum Awar
d for Continued Excellence (PACE) from the Manufacturing Extension Partnership of Louisiana.

The Syngenta St. Gabriel Plant site instills a strong site level commitment to health safety and the environment. These are evident in several plant policies and procedures, including Plant Procedure A-1, which is the Statement of Policy. This procedure states that "safety is a primary concern and a core value" and that "it is the policy of the St. Gabriel Plant management that safety is a definite job requirement at every level of the organization".

More relevant to the Risk Management Program is Plant Procedure C-8 which is entitled Process Safety Management Standard Compliance Procedure. The purpose of this procedure is "To establish measures (per Process safety Management standard 29 CFR 1910.11 and Risk Management Program 40 CFR 68) to ensure that accidental releases of toxic, reactive, flammable, or explosive chemicals are minimized and procedures are in place to lessen the consequence should a large release occur.



(b) The stationary source and regulated substances handled;



Syngenta has separated the facility into several processes. Of these, the processes subject to RMP and the regulated substances handled by these processes are as follows:

HCN/ HPF and associated Tank Farms - anhydrous ammonia; sulfur dioxide; hydrocyanic acid; chlorine; isopropylamine; ethylamine

MMU - Toluene 2,4-diisocyanate, Toluene 2,6-diisocyanate

Note that in completing Section 7.0 of the RMP, the description of the prevention programs for these units, Syngenta separated the HCN/ HPF and associated Tank Farms into two sub-processes. This was done because the Process Hazard Analysis for each of these is done independently of the others. Also note that the information provided for each of these represents the entire unit and associated chemicals as opposed to describing only the regulated compounds.



(c) The general accidental release prevention program and chemical-s
pecific prevention steps;



Syngenta is regulated by the Process Safety Management regulations and as such conducts various process hazard analyses to prevent accidental releases from the facility. These analyses are conducted on unit equipment as well as processes and procedures.

Syngenta also has comprehensive procedures for inspection and maintenance of equipment. The Syngenta Maintenance Department maintains a Preventive/Predictive Maintenance (PM/PDM) Manual. This comprehensive manual documents the system used to ensure that maintenance and inspections are conducted effectively and efficiently and that closure is attained on recommendations resulting from these activities. The PM/PDM incorporates inspection plans designed to "enhance safety, environmental integrity, operational reliability, and protection for plant personnel and the surrounding community".

Syngenta also conducts extensive employee training. Some of this training is done via a web-based computer aided training system, Intelex, which allows on demand training around the clock. The Intelex Training module electronically records this training.



(d) The five-year accident history;



Within the past 5 years (June 12, 2009 to June 12, 2014), Syngenta has had no accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.



(e) The emergency response program;



Syngenta is a very proactive participant of the local Community Awareness and Emergency Response (CAER) committee as well as having close involvement and interaction with the Iberville Parish Emergency Preparedness agency (the local LEPC). The facility is part of the community emergency response plan and has a facility emergency response plan. Both plans i
nclude specific actions to be taken in response to accidental releases of regulated substances.

In the event of an emergency, Syngenta, in conjunction with the LEPC, has several mechanisms in place to notify the surrounding community including an automated dial-up phone system, activation of a televised public announcement and a strategically placed community siren system. Syngenta also has on-site first aid and emergency medical responders, a hazmat team as well as emergency response equipment including a fire truck and ambulance.



(f) Planned changes to improve safety.



The site has developed and implemented a new Incident Management System which enhanced the ease of reporting, completing root cause analysis, tracking associated actions, and trending and communicating data. The same data management tool will be utilized to replace existing MOC, and HSE Audit systems.

A new position of Technical Training Coordinator was added to the site in January of 2009 in order to enhance training systems, and is now being conducted by a contract training coordinator. The site has a mature workforce so much effort is being placed on early development of new Technicians so that the plant maintains its current skill level into the future. Development of new employee training curriculum and systems for auditing of existing SOPs are two of the current 2009 projects for this position. A new electronic work permit system has been developed to make permits easier to create, implement, and track to completion.