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Monsanto Company Luling Plant

Parent Companies:
EPA Facility ID:
100000126561
Other ID:
70070MNSNTRIVE
Facility DUNS:
1700756

Location:

Address:
12501 River Road
Luling, LA 70070
County:
ST. CHARLES
Lat / Long:
29.926, -90.349 (Get map)
Method:
Global Positioning System (GPS) Carrier Phase Static Relative Positioning Technique
Description:
Plant Entrance (General)
Horizonal accuracy:
1 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Monsanto Company
Phone:
(985) 785-8211
Address:
12501 River Road
Luling, LA 70070
Foreign Address:

Person responsible for RMP implementation:

Name:
Enrique Wehlen
Title:
Plant Manager

Emergency contact:

Name:
Bradley S. Phillips
Title:
Senior environmental Engineer
Phone:
(985) 785-8211
24-hour phone:
(985) 377-5566
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(985) 785-8211
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. Charles Parish LEPC
Full-Time Equivalent Employees:
718
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2517-V6
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
April 7, 2015
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

ACL/CYA
RMP ID:
1000064865
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
990,000
No
Public OCA Chemical
0
No
GI A-D
RMP ID:
1000064866
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Formaldehyde (solution)
50-00-0
7,100,000
No
Isopropylamine [2-Propanamine]
75-31-0
2,300,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
GIX
RMP ID:
1000064867
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Formaldehyde (solution)
50-00-0
570,000
No
Public OCA Chemical
0
No
PCl3
RMP ID:
1000064868
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Phosphorus trichloride [Phosphorous trichloride]
7719-12-2
7,700,000
No
Chlorine
7782-50-5
7,300,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Bradley S. Phillips
Address:
12501 River Road
Luling, LA 70070
Foreign Address:

Phone:
(985) 785-3368

Latest RMP Submission:

Date:
Aug. 31, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000051337

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 PCl3)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
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 GIX)
CBI claimed:
No
Percent weight:
50.0
Physical state:
Liquid
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:
  • Dikes
  • Drains
  • Sumps
not considered:
  • Enclosures
  • Berms
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in PCl3)
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:
  • 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 PCl3)
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

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 GI A-D)
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 GI A-D)
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

Dec. 3, 2013 at 11:31
ID:
1000039797
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
8 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
7.0 miles/h SW
Temperature:
74.00 ℉
Atmospheric stability:
F
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:
3
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:
  • Utility piping system not included in inspection program
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Revised maintenance
  • Revised operating procedures

7. Prevention: Program level 3

ACL/CYA, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000053871
Safety Review Date
March 31, 2015, since latest RMP submission
PHA Update Date
May 13, 2014, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • 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
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Deluge System
  • Enclosure
  • Neutralization
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 31, 2015, since latest RMP submission
Training Review Date
July 31, 2015, since latest RMP submission
Maintenance Review Date
July 31, 2015, since latest RMP submission
Maintenance Inspection Date
April 2, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
July 21, 2015
Management of Change Review Date
Sept. 3, 2012
Pre-startup Review Date
Aug. 26, 2015
Compliance Audit Date
Dec. 6, 2013
Compliance Audit Change Completion Date
Oct. 1, 2015
Incident Investigation Date
May 27, 2015
Incident Invest. Change Completion Date
Oct. 1, 2015
Participation Plan Review Date
May 1, 2012
Hot Work Review Date
Oct. 1, 2012
Contractor Safety Review Date
Aug. 1, 2014, since latest RMP submission
Contractor Safety Eval. Date
Aug. 13, 2015, since latest RMP submission
GI A-D, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000053872
Safety Review Date
March 31, 2015, since latest RMP submission
PHA Update Date
Feb. 26, 2015, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 29, 2015, since latest RMP submission
Training Review Date
Jan. 29, 2015, since latest RMP submission
Maintenance Review Date
Jan. 29, 2015, since latest RMP submission
Maintenance Inspection Date
Jan. 12, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
July 22, 2015
Management of Change Review Date
Sept. 3, 2012
Pre-startup Review Date
Aug. 25, 2015
Compliance Audit Date
Dec. 6, 2013
Compliance Audit Change Completion Date
Oct. 1, 2015
Incident Investigation Date
Aug. 6, 2015
Incident Invest. Change Completion Date
Oct. 1, 2015
Participation Plan Review Date
May 1, 2012
Hot Work Review Date
Oct. 1, 2012
Contractor Safety Review Date
Aug. 1, 2014, since latest RMP submission
Contractor Safety Eval. Date
Aug. 13, 2015, since latest RMP submission
GIX, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000053873
Safety Review Date
March 31, 2015, since latest RMP submission
PHA Update Date
Feb. 26, 2015, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 25, 2015, since latest RMP submission
Training Review Date
Feb. 25, 2015, since latest RMP submission
Maintenance Review Date
Feb. 5, 2015, since latest RMP submission
Maintenance Inspection Date
Dec. 11, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 27, 2015
Management of Change Review Date
Sept. 3, 2012
Pre-startup Review Date
Aug. 17, 2015
Compliance Audit Date
Dec. 6, 2013
Compliance Audit Change Completion Date
Oct. 1, 2015
Incident Investigation Date
Sept. 10, 2014
Incident Invest. Change Completion Date
Sept. 10, 2015
Participation Plan Review Date
May 1, 2012
Hot Work Review Date
Oct. 1, 2012
Contractor Safety Review Date
Aug. 1, 2014, since latest RMP submission
Contractor Safety Eval. Date
Aug. 13, 2015, since latest RMP submission
PCl3, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000053874
Safety Review Date
March 31, 2015, since latest RMP submission
PHA Update Date
Jan. 31, 2013, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Deluge System
  • Enclosure
  • Neutralization
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Increased Inventory
  • Process Controls
  • Process Detection
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Oct. 29, 2014, since latest RMP submission
Training Review Date
Oct. 29, 2014, since latest RMP submission
Maintenance Review Date
Oct. 29, 2014, since latest RMP submission
Maintenance Inspection Date
May 6, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 26, 2015
Management of Change Review Date
Sept. 3, 2012
Pre-startup Review Date
Aug. 28, 2015
Compliance Audit Date
Dec. 6, 2013
Compliance Audit Change Completion Date
Oct. 1, 2015
Incident Investigation Date
Jan. 14, 2015
Incident Invest. Change Completion Date
Feb. 23, 2015
Participation Plan Review Date
May 1, 2012
Hot Work Review Date
Oct. 1, 2012
Contractor Safety Review Date
Aug. 1, 2014, since latest RMP submission
Contractor Safety Eval. Date
Aug. 13, 2015, 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:
Aug. 13, 2015
Local Response Agency:
Local Response Agency Phone:
(985) 783-5050
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

RMP Executive Summary A? Monsanto Luling Plant

LDEQ Agency Interest Number 1096



Accidental Release Prevention and Emergency Response Policies:

Monsanto is an agricultural company. We apply innovation and technology to help farmers around the world produce more while conserving more. We help farmers grow yield sustainably so they can be successful, produce healthier foods, better animal feeds and more fiber, while also reducing agriculture's impact on our environment.



To facilitate these efforts, Monsanto developed a "Pledge" several years ago. The Monsanto Pledge is our commitment to how we do business. It is a declaration that compels us to listen more, to consider our actions and their impact broadly, and to lead responsibly. It helps us to convert our values into actions, and to make clear who we are and what we champion. One aspect of the Pledge is "Respect", which states: "The safety of our employees, the communities where we operate, our customers, consumers, and the environment will be our highest priority." Thus, Monsanto's strong commitment to chemical safety begins at the upper level of the corporation.



This commitment extends to Monsanto's chemical manufacturing facilities, including the Luling facility. As evidence of this strong commitment, the Luling Plant received certification as a Voluntary Protection Program (VPP) "Star" site in 1994, and has continuously retained this rating since then.



Facility Description and Regulated Substances Handled:

The Monsanto Luling facility is located in St. Charles Parish in Louisiana at 12501 River Road, Luling. The facility manufactures Roundup(c) brand herbicide and ACL(c) brand active chlorine. As part of its operations, the facility handles sufficient quantities of Chlorine, Formaldehyde, Phosphorus Trichloride (PCl3) and Isopropylamine (IPA) to make it subject to EPA's Risk Management Program rule.



This Risk Management Plan report is being updated in response to a change in facility
contact information in Section 1. Monsanto is also taking this opportunity to conduct the full five year review of the plan earlier than is required by law.



General Accidental Release Prevention Program and Chemical-Specific Prevention Steps

The Luling plant is also subject to the provisions of the OSHA PSM regulation, whose provisions align closely with the major RMP prevention program elements. Accordingly, the Luling Plant employs a comprehensive collection of safety systems to maintain the equipment and work practices utilized in our operation to comply with these rules. Some examples include:



- A Process Hazard Analysis (PHA) is conducted at a minimum of every 5 years. This involves a team of experts who review the hazards posed by the chemical, best industry practices for handling the material, and a defined system to identify hazards. Recommendations for improvement are made, and priority is placed on implementing them in a prompt manner.



- Our mechanical integrity system requires regular inspection of the equipment, relief devices, and other systems utilized in handling regulated materials.



- Instructions have been developed to provide detailed actions for employees operating the equipment. These procedures are developed and reviewed with active involvement from operating personnel, and are certified annually.



- A change management system is utilized for changes in equipment, operating parameters, and personnel. Each change is appropriately reviewed by a team of personnel to determine if there is any impact to system safety.



- The site utilizes a number of contract personnel for a variety of services. Our Contractor/Guest program requires that contractors be selected using their actual safety performance as a criteria, and open communication exists between Monsanto and contract employees to identify and control hazards.



In addition, we utilize a number of systems for specific chemicals. Examples include:



- Process alarms an
d interlocks,

- Area monitors to quickly detect leaks,

- Water sprinkler systems to extinguish process fires, and

- Excess flow valves which will stop chlorine flow under certain conditions.



Both the general and chemical specific systems work together to minimize the frequency and consequences of chemical releases.



Five-Year Accident History:

During the past 5 years, there have been one RMP-defined accidental release events. This most recent event meeting this criteria was on December 3, 2013 when approximately 2.2 pounds of chlorine was released from a failure in a nitrogen pipeline used to supply nitrogen for evacuation of the chlorine supply piping to facilitate inspection. When the nitrogen piping failed, the chlorine backed into the nitrogen line momentarily before safety interlocks and valving isolated the chlorine material and eliminated any further release. As a result of the release, three contract employees located at the pipe failure location were taken to the hospital for evaluation before being released. The event did not result in any community impact. The incident was investigated in accordance with Monsanto procedures, and all corrective recommendations made by the investigation team have been implemented. Prior to this event, the previous incident occurred on November 14, 2002.



Emergency Response Program:

In accordance with the provisions of the RMP and PSM rules, Monsanto's Luling facility has a documented Emergency Response Plan that includes defined responsibilities and actions to be implemented for a number of events, including inclement weather, fire, and toxic chemical releases. Personnel responsible for implementing this procedure are available onsite at all times. In general, the plan describes actions which result in a safe response for company employees as well as prompt notification of community organizations. The plan has been integrated with the St. Charles Parish Department of Emergency Preparedness (DEP) and othe
r appropriate organizations.



The following actions take place in the event of an emergency:



- DEP is notified immediately;

- Plant personnel respond immediately; and

- DEP determines possible community impact and takes appropriate action. These actions could include no action, shelter-in-place, evacuation, or continual communications. Methods of communicating to the public include a siren system, cable TV or radio broadcasts, a telephone alert system, and door-to-door notifications.



The Luling plant Emergency Response Team (ERT) provides Fire, HAZMAT, EMS and Rescue Response. The ERT consists of 68 members; however, the number can fluctuate with personnel changes over the year. Emergency response equipment in the plant is routinely inspected and maintained to ensure a state of readiness, and is summarized as follows:



Emergency Vehicles

Ambulance

HAZMAT Truck

Fire Truck

Mobile Emergency Control Center

Rescue Truck

Rescue Boat



Emergency Trailers

HAZ MAT Trailer

PCl3 Foam Trailer

Fire Fighting Foam Trailer

Air Bottle Trailer



All of this equipment is maintained in the Fire Bay, except that the fire fighting foam trailer is maintained in the Emergency Equipment Bay (also known as the Project Warehouse).



Other equipment is placed throughout the plant for quick response and includes (but is not limited to) fire hose houses and monitors, sprinkler and deluge systems, spill response kits, absorbent materials, Industrial Hygiene monitoring equipment, bunker gear, SCBAs and other equipment.



Planned Changes to Improve Safety:

Over the next 5 years the plant plans to continue to improve safety through continuation of participation in programs such as VPP, continuing internal initiatives such as the Behavior Based Safety program, as well as conducting audits required by PSM and RMP.



This brief summary provides some insight into the extensive system Monsanto utilizes to maintain safe operations. If you would like additional informati
on about Monsanto Company, please visit our corporate internet home page at www.monsanto.com. If you have any questions about this Risk Management Plan, please contact the Luling Plant at (985) 785-8211.