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Brenntag Southwest, Inc. St. Gabriel Bleach Plant

Parent Companies:
Brenntag, Inc.
EPA Facility ID:
100000164706
Other ID:
070411-LA-001
Facility DUNS:
0
Parent Company DUNS:
145865148

Location:

Address:
4205 Hwy 75
St. Gabriel, LA 70776
County:
IBERVILLE
Lat / Long:
30.241, -91.103 (Get map)
Method:
GPS - Unspecified
Description:
Center of Facility
Horizonal accuracy:
50 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Brenntag Southwest
Phone:
(918) 245-6666
Address:
206 East Morrow Road
Sand Springs, OK 74063
Foreign Address:

Person responsible for RMP implementation:

Name:
Tom Crain
Title:
President

Emergency contact:

Name:
Matthew Cotten
Title:
Operations Manager
Phone:
(225) 642-5456
24-hour phone:
(225) 892-9313
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Iberville Parish LEPC
Full-Time Equivalent Employees:
5
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 19, 2017
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Chlorine
RMP ID:
1000080794
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
199,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 27, 2017
Type:
Resubmission
Reason:
Revised OCA due to change (40 CFR 68.190(b)(6))
Registered:
Yes
RMP ID:
1000064398

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 Chlorine)
CBI claimed:
No
Percent weight:
99.9
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:
  • Enclosures
not considered:
  • Dikes
  • 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 Chlorine)
CBI claimed:
No
Percent weight:
99.9
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:
  • Enclosures
not considered:
  • Dikes
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Scrubbers
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

Oct. 17, 2013 at 06:10
ID:
1000049877
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
10 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
5.0 miles/h SW
Temperature:
67.00 ℉
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:
$20000
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 Only
Changes introduced as a result of the accident:
  • Revised training

7. Prevention: Program level 3

Chlorine, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000067992
Safety Review Date
April 20, 2017, since latest RMP submission
PHA Update Date
June 20, 2017, since latest RMP submission
PHA Techniques
  • What if
  • FMEA
Hazards Identified
  • Toxic release
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Earthquake
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Enclosure
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
May 9, 2017, since latest RMP submission
Training Review Date
May 9, 2017, since latest RMP submission
Maintenance Review Date
May 9, 2017, since latest RMP submission
Maintenance Inspection Date
June 13, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 9, 2017
Management of Change Review Date
April 20, 2017
Pre-startup Review Date
Jan. 9, 2017
Compliance Audit Date
April 20, 2017
Compliance Audit Change Completion Date
July 31, 2017
Incident Investigation Date
July 21, 2015
Incident Invest. Change Completion Date
July 21, 2015
Participation Plan Review Date
April 20, 2017
Hot Work Review Date
April 20, 2017
Contractor Safety Review Date
April 20, 2017, since latest RMP submission
Contractor Safety Eval. Date
April 20, 2017, 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:
May 1, 2016
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

***** Executive Summary *****



Introduction



Brenntag Saint Gabriel manufacturing facility is co-located on approximately 6 acres, 12 miles south of Baton Rouge, LA., owned and operated by Olin Chlor Alkali Company, Inc. The Brenntag facility resides on the northeast corner of the Olin site and wholly owns and operates this facility. The main products produced at St. Gabriel is sodium hypochlorite and repacking chlorine. Chlorine is an element that occurs naturally as sodium chloride (table salt). Brenntag's products play an important role in the purification of drinking water, treating swimming pools and industrial waters and laundry bleach.



Brenntag's environmental and safety and health policies recognize the importance of safeguarding the environment and protecting the community throughout the manufacturing process. Programs are in place to ensure compliance with regulations and continuing improvement of performance over the years. Facility personnel are trained extensively in safe operation of the facility and in maintaining compliance with all applicable regulations. Operations employees at the Brenntag site are all 40-hr HAZWOPER trained and undergo an annual 8-hr refresher.



Chlorine is the only chemical at the facility that falls under the RMP regulations.



Prevention Program



Brenntag has developed an accidental release prevention program based on the elements of OSHA's Process Safety Management Program. Each of the 12 elements is fully implemented and integrated into the standard operating practices of the plant. Summarized below are brief descriptions of each of the elements:



Process Safety Information - Critical information on chlorine properties, chlorine handling and chlorine repackaging techniques, is made readily available to facility personnel through Material Safety Data Sheets, current drawings, and comprehensive operations manuals. Additionally, the Chlorine Institute provides information and guidelines in the form of regula
rly updated technical pamphlets. This information is used as the basis for many of our operating procedures and chemical process systems.



Process Hazard Analysis - Brenntag performs Process Hazard Analyses on an established schedule. A trained team rigorously scrutinizes the operating processes and makes recommendations for safety enhancements. The recommendations are then prioritized and implemented accordingly.



Operating Procedures - Clear and concise instructions have been developed by experienced personnel for all facility operations. The operating instructions are kept current by regularly scheduled annual review, and by integrating the Management of Change procedures.



Training - Employees are thoroughly trained on the technical aspects of the manufacturing process including on the job (OJT) training and operating procedures that lead them step by step through the necessary operating instructions. The training program is ongoing and used to continually enhance the capabilities of all plant employees.



Mechanical Integrity - The Mechanical Integrity program in place at the plant is specifically designed to keep our equipment in viable condition. Operations personnel ensure all pipes, tanks, valves and mechanical equipment involved in chlorine service are checked prior to placing in service on a daily basis. Chlorine equipment is inspected and tested on an established schedule as established by the Chlorine Institute.



Management of Change - Written procedures are in place to ensure that all process changes at the plant undergo review at the planning stage. No changes are made without review by a team that includes engineering, operations and maintenance personnel. Once a process change has been made, systems are in place to make sure that communication of the change will be made to all that may be affected.



Pre Startup Reviews - Before being placed into service, any new or modified system is thoroughly reviewed by engineering and operati
ons personnel. This review is designed to ensure appropriate design, adequate safety systems, and sufficient training. All recommendations from the review are then completed before start up.



Compliance Audits - Internal audits will be performed by the Site Manager and the operations supervisor. Recommendations from the audits are reviewed by the executive committee and are promptly converted into action plans.



Incident Investigation - Significant environmental, safety, or health incidents at the facility are fully investigated by appropriate teams to determine root cause and to put in place action plans designed to prevent recurrence. The findings are documented and communicated to facility personnel.



Employee Participation - Employees are very involved in all aspects of the process safety management program. Employee participation is the cornerstone of the Voluntary Protection Program.



Hot Work - The facility's Hot Work procedure requires that detailed permitting activities take place before, during, and after any job that has the potential to provide a source of ignition.



Contractor Safety - The contractor safety program, places stringent qualification requirements on contracting firms. To become qualified to work at the facility, contractors must provide proof of training that matches our tough requirements. Additional facility specific training is then required before any contract work can take place. Contractor safety performance and compliance with facility safety requirement are monitored closely during all contract projects.





Emergency Response Program



The Brenntag facility is located in close proximity to the Olin Chlor Alkali Company, Inc. facility in St. Gabriel. Brenntag has implemented an emergency response plan which works in conjunction with the local emergency response agencies and industrial neighbors.



Brenntag's personnel are trained to handle minor emergencies with back up assistance from Olin's ER team if neces
sary. Communication systems and chlorine detection systems have been installed to provide rapid communication between companies. Brenntag and Olin work closely together to insure adequate response personnel are available to respond if necessary.



Hypothetical Models



The Environmental Protection Agency has defined the worst case scenario as the hypothetical rupture and full release of all contents of the facility's largest storage tank, assuming all safeguards have failed, during extremely stable weather conditions. While the probability of this scenario coming to pass at any facility is extremely low, it does provide a template for emergency response planning.



The computer-generated model for our worst case scenario is the full release of a chlorine container while filling or in storage. It is assumed that the full contents of the DOT ton container (2,000 lbs) is released in 10 minutes which results in a planning zone of 0.9 miles.



Each facility must also prepare an alternate scenario that could have an off-site impact, based on plant operations. As the alternate scenario we have selected a transfer hose failure used in filling the ton chlorine containers. The computer-generated model for this release results in a possible impact of up to 0.2 miles. The assumptions made for this scenario include the sensors shutting off the main emergency closure valve (AutoMax) isolating 287 feet of 3" active chlorine line, 15 feet of 1" line, and 3 feet of 3/4" transfer hose. This line, fully loaded, captures about 1520 lbs of chlorine and it will be released in a 10 minute timeframe. During this time Brenntag personnel will actively mitigate this release by redirecting this line to the scrubber for neutralization after donning the appropriate response PPE.





Five-Year History



Brenntag had an incident on October 17, 2013 which resulted in 110 pounds of chlorine being released to the atmosphere. No one was injured as result and there were no off site consequ
ences. Investigation revealed that a vapor valve had been left open at the cylinder fill station when the system was charged with chlorine during facility start up procedures. The open valve (normally used to pull chlorine vapors) allowed liquid chlorine to travel to the scrubber system which was unable to process the liquid influx, resulting in chlorine gas being released to the atmosphere.



Safety



Brenntag is committed to a continuous improvement process. Safety, health and environmental related matters are continually being reviewed and revised to make improvements in protecting our employees and our community. Brenntag engineers and constructs our chemical manufacturing facilities using the best available control technology. Sound engineering design coupled with the continuous improvement process we feel provides the best long-term protection concerning everyone's well-being.



We aim to further enhance our partnerships with regulatory agencies and local responders, as well as with other industrial facilities, in the common goal of protecting our employees, our communities, and our futures.



With recent developments concerning tighter regulatory and compliance requirements, Brenntag strives to be a consistent and model facility. Brenntag will continue to invest in their personnel and plant assets to ensure a safe and efficient facility.