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Ergon - Baton Rouge, Inc.

Parent Companies:
Ergon, Inc.
EPA Facility ID:
100000177612
Other ID:
LAD980810345
Facility DUNS:
61239216
Parent Company DUNS:
87023743

Location:

Address:
390 West Thomas Road
Baton Rouge, LA 70874
County:
EAST BATON ROUGE
Lat / Long:
30.550, -91.200 (Get map)
Method:
Interpolation - Photo
Description:
Unknown
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Ergon - Baton Rouge, Inc.
Phone:
(225) 775-0526
Address:
390 West Thomas Road
Baton Rouge, LA 70874
Foreign Address:

Person responsible for RMP implementation:

Name:
William Hutton
Title:
Terminal Manager

Emergency contact:

Name:
Nathan Pendergrass
Title:
EHS
Phone:
(225) 775-0526
24-hour phone:
(225) 281-4385
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(601) 933-3000
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
East Baton Rouge LEPC
Full-Time Equivalent Employees:
12
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:
Oct. 6, 2003
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Vinyl Acetate Storage
RMP ID:
1000073606
CBI claimed:
No
Program Level:
2
NAICS:
Other Warehousing and Storage (49319)
Chemical name
CAS#
Quantity (lbs.)
CBI
Vinyl acetate monomer [Acetic acid ethenyl ester]
108-05-4
17,993,884
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Sept. 1, 2017
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000059018

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 Vinyl Acetate Storage)
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:
  • Dikes
not considered:
  • 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 Vinyl Acetate Storage)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
1.50
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • drip pans under hose connections
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • drip pans under hose connections
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

Vinyl Acetate Storage, Other Warehousing and Storage (49319)
Prevention Program ID:
1000046229
Safety Review Date
Dec. 10, 2010, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Toxic Release
  • Polymerization
  • Equipment failure
  • Tornado
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Alarms
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • On the Job
Competency Testing
  • Observation
Procedure Review Date
July 14, 2016, since latest RMP submission
Training Review Date
July 14, 2016, since latest RMP submission
Maintenance Review Date
July 14, 2016, since latest RMP submission
Maintenance Inspection Date
July 14, 2016, 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
July 14, 2016
Compliance Audit Change Completion Date
July 14, 2016
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:
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. 29, 2010
Local Response Agency:
Local Response Agency Phone:
(225) 389-5255
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

General Executive Summary for Ergon - Baton Rouge, Inc.



Accidental Release Prevention and Emergency Response Policies

We at Ergon are strongly committed to employee, public, and environmental safety and health. This commitment is inherent to a comprehensive accidental release prevention program that includes procedures for the operation, maintenance, emergency response, and employee training associated with the regulated process at this facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances and adhere to all applicable federal and state rules and regulations.



The Stationary Source and the Regulated Substances Handled

The regulated substance present at the facility is vinyl acetate. The vinyl acetate is stored for use by local industry. The maximum inventory of vinyl acetate stored at Ergon - Baton Rouge, Inc. is 17,993,884 pounds.



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, were evaluated by using the RMP*Comp program and the U.S. Environmental Protection Agency's (EPA's) Risk Management Plan (RMP) Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios as required by 40 Code of Federal Regulations (CFR) Part 68.1 - 68.33.



The Worst-Case Release Scenario for regulated toxic gases involves the ground-level release of the entire contents of the largest vessel at the facility over a ten minute period. In the worst-case situation, this type of release would coincide with meteorological conditions that result in minimal dilution of the vessel contents. The endpoint for toxic substances is the maximum airborne concentration below which nearly all individuals can be exposed for up to one hour without developing serious health effects which could impair the ability to take protective cover. For vinyl acetate, t
his toxic endpoint is 0.26 mg/L. The distance to endpoint was determined using RMP*Comp, a software program developed by the National Oceanic and Atmospheric Administration (NOAA).



The Worst-Case Release Scenario for Ergon - Baton Rouge, Inc. involves the release of vinyl acetate from the 55,000 barrel storage tank. The distance to endpoint for this release is approximately 6.2 miles.



The Alternative Release Scenario is an event which is much more likely to occur than the Worst-Case Release Scenario and which will reach an endpoint offsite, unless no such scenario exists. In determining the distance to endpoint for the Alternative Release Scenario, any mitigation controls employed in the process can be used. The distance to endpoint for the Alternative Release Scenario was determined using RMP*Comp.



The most likely Alternative Release Scenario for Ergon - Baton Rouge, Inc. would involve a release from the hose that attaches to the barge for unloading vinyl acetate. A check valve exists at the connection to the pipeline that prevents backflow of vinyl acetate should the hose lose its attachment. This Alternative Release Scenario could result in the release of a maximum of 110 gallons of vinyl acetate. The distance to toxic endpoint calculated by RMP*Comp for this release is approximately one tenth of a mile.



The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps

The Ergon facility is in compliance with EPA's Accident Release Prevention Rule set out under 40 CFR Part 68 and all applicable state codes and regulations. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.



Safety Information

Ergon - Baton Rouge, Inc. maintains the applicable Safety Data Sheets related to this process. The facility also maintains detailed records of safety information that describes the chemical hazards, operating parameters, and equipment designs ass
ociated with this process.



Hazard Review

Ergon - Baton Rouge, Inc. conducts comprehensive reviews to ensure that the hazards associated with the process are identified and controlled efficiently. The studies are undertaken by qualified personnel who are experienced in engineering and process operations. The reviews are updated every five years or whenever a major change in the process occurs. Any findings related to the hazard analysis are addressed in a timely manner.



Operating Procedures

In order to ensure safe operation of the covered process, Ergon - Baton Rouge, Inc. maintains written standard 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 reviewed periodically, certified annually, and readily accessible to operators involved in the processes.



Training

Ergon - Baton Rouge, Inc. has a comprehensive training program in place to ensure that employees who are operating this process are competent in the operating procedures associated with this process. Refresher training is provided at least every three years and more frequently as needed.



Maintenance

Ergon - Baton Rouge, Inc. carries out highly documented maintenance checks to maintain the mechanical integrity of the process equipment. 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 carried out by qualified personnel with previous training in maintenance practices. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.



Compliance Audits

Ergon - Baton Rouge, Inc. conducts audits on a regular basis to determine whether the provisions set out under 40 CFR Part 68 are bein
g implemented and reviewed. These audits are performed by qualified personnel and are carried out at least every three years. Any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. The most recent two audits are kept on site.



Incident Investigation

Ergon - Baton Rouge, Inc. promptly investigates 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. Any investigation findings are resolved promptly and the corresponding resolutions or corrective measures are documented. All reports are retained for a minimum of five years.



Five-year Accident History

Ergon - Baton Rouge, Inc. hasn't had any accidental releases during the previous five years.



Emergency Response Plan

In the event of an emergency release of vinyl acetate, it is the policy of Ergon - Baton Rouge, Inc. to notify the East Baton Rouge Fire Department and request that they respond to the emergency.