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Bayer CropScience - Erskine Facility

Parent Companies:
Bayer CropScience
EPA Facility ID:
100000196664
Other ID:
Facility DUNS:
849659276
Parent Company DUNS:
0

Location:

Address:
103 Erskine Street
Lubbock, TX 79403
County:
LUBBOCK
Lat / Long:
33.608, -101.839 (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:
Bayer CropScience
Phone:
(806) 765-8846
Address:
103 Erskine Street
Lubbock, TX 79403
Foreign Address:

Person responsible for RMP implementation:

Name:
Austin Burrow
Title:
Site Manager

Emergency contact:

Name:
Austin Burrow
Title:
Site Manager
Phone:
(806) 765-8846
24-hour phone:
(806) 319-0729
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(520) 438-5156
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Lubbock County LEPC
Full-Time Equivalent Employees:
15
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
133997
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
June 5, 2017
Inspecting Agency:
USDA
Using Predictive Filing:
No

Processes:

Cotton Seed Delinting
RMP ID:
1000072600
CBI claimed:
No
Program Level:
3
NAICS:
Postharvest Crop Activities (except Cotton Ginning) (115114)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
25,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Chris Brisendine
Address:
Rt. 25 @ I-64
Institute, WV 25112
Foreign Address:

Phone:
(304) 400-9426

Latest RMP Submission:

Date:
June 3, 2016
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000058087

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 Cotton Seed Delinting)
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 Cotton Seed Delinting)
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:
  • None
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

May 8, 2013 at 19:45
ID:
1000044699
NAICS:
Postharvest Crop Activities (except Cotton Ginning) (115114)
Duration:
18 hours
Chemicals involved:
  • Hydrochloric acid (conc 37% or greater)
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
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:
200
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Airgas altered its HCl trailer retest procedures.

7. Prevention: Program level 3

Cotton Seed Delinting, Postharvest Crop Activities (except Cotton Ginning) (115114)
Prevention Program ID:
1000060805
Safety Review Date
Nov. 11, 2016
PHA Update Date
Aug. 25, 2017
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Cooling loss
  • Tornado
Process Controls
  • Vents
  • Relief Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Water Curtain
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Process Detection
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 11, 2016
Training Review Date
Aug. 1, 2017
Maintenance Review Date
Aug. 16, 2017
Maintenance Inspection Date
June 20, 2016
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 6, 2017
Management of Change Review Date
Jan. 6, 2017
Pre-startup Review Date
Nov. 11, 2016
Compliance Audit Date
March 17, 2015
Compliance Audit Change Completion Date
Dec. 31, 2018
Incident Investigation Date
May 20, 2013
Incident Invest. Change Completion Date
Feb. 11, 2015
Participation Plan Review Date
March 22, 2017
Hot Work Review Date
Jan. 18, 2017
Contractor Safety Review Date
Jan. 16, 2017
Contractor Safety Eval. Date
April 17, 2017

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:
Feb. 10, 2017
Local Response Agency:
Local Response Agency Phone:
(806) 775-1558
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Bayer CropScience has a vision to provide innovative solutions meeting the needs of our customers in line with the global principles of Responsible Care and Sustainable Development. To meet our vision, we conduct our business with respect and care for the environment and without compromising the health and safety of people, whether employees, customers, or citizens around the world. Facility and organization management fully supports the implementation of process safety at the plant. It is our policy to proactively implement appropriate measures to prevent possible releases. If such a release does occur, our first concerns are for the safety of our employees, the safety of the community, and the protection of the environment. Furthermore, it is our policy to work cooperatively with the local fire department on emergency response matters.



The facility produces cotton seed. Cotton seed is received from cotton gins, delinted and cleaned, treated, and then packaged for distribution to customers. Anhydrous hydrogen chloride, a regulated substance, is used in the delinting process.



The facility has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68. Employees are trained to recognize the hazards of the process and all changes to the process are reviewed to ensure that the safety, health, and environmental consequences of the change are addressed prior to the implementation of the change. The facility is also subject to OSHA's PSM rule.



There has been one release of hydrogen chloride in the last five years. There were no offsite consequences. Police department did evacuate everyone within one mile of the facility. The cause of the release was the deterioration of a silver washer in a pressure release value on the AirGas cylinder. AirGas determined that moisture was in the cylinder at the time the cylinder was filled causing the deterioration.



The emergency action plan was followed and the r
elease resulted in no injuries to anyone nor was there any property damaged. Evacuation drills are periodically conducted and the facility communicates regularly with the local fire department.