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Multi-Chem Group, LLC, New Iberia

Parent Companies:
Multi-Chem Group, LLC
EPA Facility ID:
100000206715
Other ID:
LAR000063172
Facility DUNS:
179379396
Parent Company DUNS:
0

Location:

Address:
3401 W. Admiral Doyle Dr.
New Iberia, LA 70560
County:
IBERIA
Lat / Long:
30.032, -91.863 (Get map)
Method:
Address Matching - Digitized
Description:
Storage Tank
Horizonal accuracy:
1 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Multi-Chem Group, LLC
Phone:
(337) 364-0580
Address:
3401 W. Admiral Doyle Dr.
New Iberia, LA 70560
Foreign Address:

Person responsible for RMP implementation:

Name:
Cade Bourque
Title:
EHS/DOT Director

Emergency contact:

Name:
Cade Bourque
Title:
EHS/DOT Director
Phone:
(337) 364-0580
24-hour phone:
(337) 335-8546
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Iberia Parish LEPC
Full-Time Equivalent Employees:
25
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1260-00159-00
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Inspecting Agency:
Never had one
Using Predictive Filing:
No

Processes:

Chemical Storage & Dist.
RMP ID:
1000011336
CBI claimed:
No
Program Level:
3
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Chemical name
CAS#
Quantity (lbs.)
CBI
Acrolein [2-Propenal]
107-02-8
56,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Robert Kuykendall
Address:
2255 Morello Avenue, Suite 208
Pleasant Hill, CA 94523
Foreign Address:

Phone:
(858) 602-2333

Latest RMP Submission:

Date:
July 21, 2009
Type:
Resubmission
Reason:
Revised OCA due to change (40 CFR 68.190(b)(6))
Registered:
No
RMP ID:
1000009629

Deregistration:

Date:
Effective Date:
Reason:
Source reduced inventory of all regulated substances below TQs
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 Chemical Storage & Dist.)
CBI claimed:
No
Percent weight:
95.0
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:
Rural
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 Chemical Storage & Dist.)
CBI claimed:
No
Percent weight:
95.0
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres [ALOHA(R)]
Wind speed (meters per sec):
4.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
  • Neutralization
  • Emergency shutdown
not considered:
  • Water curtain
  • Excess flow valve
  • Flares
  • Scrubbers

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Chemical Storage & Dist., Other Chemical and Allied Products Merchant Wholesalers (42469)
Prevention Program ID:
1000009232
Safety Review Date
March 1, 2009, since latest RMP submission
PHA Update Date
March 1, 2009, since latest RMP submission
PHA Techniques
  • What if
  • Checklist
  • What if/Checklist
  • HAZOP
  • FMEA
  • FTA
Hazards Identified
  • Toxic release
  • Fire
  • Polymerization
  • Overpressurization
  • Equipment failure
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Alarms
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Demonstration
  • Observation
Procedure Review Date
March 1, 2009, since latest RMP submission
Training Review Date
March 1, 2009, since latest RMP submission
Maintenance Review Date
March 1, 2009, since latest RMP submission
Maintenance Inspection Date
March 1, 2009, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 1, 2009
Management of Change Review Date
March 1, 2009
Pre-startup Review Date
March 1, 2009
Compliance Audit Date
March 1, 2009
Compliance Audit Change Completion Date
March 1, 2009
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
March 1, 2009
Hot Work Review Date
March 1, 2009
Contractor Safety Review Date
None, since latest RMP submission
Contractor Safety Eval. Date
None, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
No
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:
March 1, 2009
Local Response Agency:
Local Response Agency Phone:
(337) 369-2380
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

MULTI-CHEM, LLC A? NEW IBERIA, LA: EXECUTIVE SUMMARY

1. Accidental Release Prevention and Emergency Response Policies

Multi-Chem is committed to being a responsible member of the community in which it operates by giving top priority to operating in a safe and environmentally sound manner. Multi-Chem personnel work continuously to identify methods to reduce the use of hazardous materials and to reduce the risk to the community and environment through implementation of new technology and procedures. This commitment to safe and environmentally sound operations is one of Multi-Chem's core values as documented in policy and compliance manuals, and in its mission statement, which are available to all employees.

2. Stationary Sources and Regulated Substance Handled

Acrolein, also known as 2-propenal, is an aldehyde. It is present between 92-96% pure in the product received in the Acrolein tanks. It is inhibited by hydroquinone (0.35%) and covered with a nitrogen blanket to prevent hazardous polymerization. Acrolein is acutely toxic, as well as an inhalation and fire hazard. Some of the typical physical and chemical properties listed below.
A? CAS # 107002-8
A? Clear, colorless liquid
A? Acrid and pungent odor, extremely irritating
A? pH 7
A? flashpoint of A? 13 F (TCC)
A? heavier than air
A? can produce exothermic hazardous polymerization reaction
A? can be neutralized with soda ash or sodium bisulfite (increasing the pH results
in decreased half-life)
A? OSHA permissible exposure limit (PEL), 0.1 ppm
A? OSHA short term excursion limit (STEL), 0.3 ppm

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

Multi-Chem, New Iberia has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68.

The following sections briefly describe the elements of Multi-Chem's release prevention program that are in place at the New Iberia facility.

Process Information:
Acrole
in is delivered by truck to the site in ISO containers containing approx 40,000 lbs acrolein. Acrolein is loaded via a hose into a maximum of twenty pressurized field tanks containing up to 399 gallons (2,797 lbs.) of acrolein each. During unloading, the ISO tank remains under motive transport; potential spills from the ISO tank have not been considered per EPA RMP requirements. During and after field tank filling, the transfer hose line is purged of acrolein using nitrogen, and the purge gas is vented through a gas scrubber control system into the atmosphere. The acrolein is inhibited by adding hydroquinone to slow oxygen catalyzed polymerization. Additionally, the head space at the top of the cylinder is filled with pure nitrogen. The maximum expected inventory of acrolein at the Multi-Chem facility is 56,000 pounds (twenty 2,797 lb acrolein tanks). There are no acrolein chemical processes involved at the Multi-Chem facility as no product is used at the facility.



Process Hazard Analysis:
The HAZOP method will be employed by Multi-Chem personnel to systematically identify, analyze and correct potential hazards associated with the storage, handling and movement of acrolein at the facility. After completion of the initial process hazard analysis, the HAZOP will be reviewed and the finalized. The process hazard analysis findings worksheets will be used to document the findings, recommendations, corrective actions and completion dates. It will also be used to document that the affected employees have been informed of the recommendations or actions. The EHS/DOT Director and New Iberia Facility Manager are responsible for ensuring that any recommendations are resolved in a timely manner and that the resolution is documented. The New Iberia Facility Manager will ensure that the affected employees are informed of any changes. The HAZOP analysis will be updated and revalidated every five (5) years to ensure that the process hazard analysis is consistent with
the current process and handling procedures.

Operating Procedures:
For the purposes of safely conducting activities within our covered processes, Multi-Chem New Iberia will maintain written operating procedures. These procedures will address various modes of operation such as transportation, storage and emergency operations. The information will be regularly reviewed and readily accessible to operators involved with the processes.

Training:
Each employee presently involved in operating the process and new employees, will be trained in an overview of the process and in the operating procedures for acrolein prior to handling acrolein. The training will include emphasis on the health and safety hazards, emergency operations including shutdown and safe work practices. Forklift training and certification is conducted as required by OSHA requirements. Hazard awareness and container storage and handling training will be given to Materials Handlers who may have occasion to on or off load the containers. Awareness training will be given to all employees to be aware of the hazards of the product, to recognize the containers and to avoid any possible exposure to the material.

Refresher training will be provided at least every three years or more often if necessary. The training will assure that the employee understands and adheres to the current operating procedures. The Facility Manager or designated supervisor will discuss and determine with the employees the frequency of the refresher training. Forklift drivers receive refresher training and recertification every three years as required by OSHA.

Mechanical Integrity:
In accordance with 29 CFR 1910.119, a maintenance equipment program involving documented inspections and testing of equipment will be implemented. The following equipment will be included in the maintenance program:
A? Acrolein Tanks (including all valves attached to tank)
A? Forklifts
Stringent Federal Department of Transportation (DOT) design, in
spection and testing specifications govern the fabrication, charging and transportation of acrolein containers. Upon request by regulatory agencies, documentation will be provided by Multi-Chem personnel on the various tests and inspections performed on these containers. These DOT tests and inspections performed by an independent inspection agency include the following:
A? Verify chemical analysis of material(s) of construction
A? Inspect welds and fabrication
A? Verify container markings
A? Internal condition of container
A? Verify threads meet specifications
A? Verify heat treatment of materials
A? Witness pressure tests
A? Verify wall thickness requirements
A? Verify volume and weight of container
A? Pressure test each container and certify every five years
A? Safety relief valve testing
A? Furnish complete test results to purchaser upon request.

Upon receipt and during handling and storage of the acrolein tanks, Multi-Chem employees need only to perform visual checks of these containers. Routine checks, which will be performed on these containers, are as follows:

A? Upon receipt of acrolein containers: Visually check containers for bulging, corrosion or significant cuts or gouges. Also check the container shut-off and safety valves for any visual defects. Any containers showing any significant defect will be rejected and returned to the supplier. The serial number of any rejected container will be documented. Also check the container to insure that the weight is indicated.
A? Upon handling of acrolein containers: Visually check containers for defects.
A? Multi-Chem employees will also perform non-documented visual checks of the container and document abnormalities of a given container taking down the serial number of the container and describing the abnormality. Any abnormalities will be immediately reported and acted upon.

Management of Change:
Prior to any change or modification in technology, equipment, standard operating procedures or the facility,
a review of the change will be conducted by the Facility Manager, EHS/DOT Director, or other competent technical personnel. Where appropriate, other departments may be called upon to review the changes. This would not include replacements-in-kind.
The review will consider the following:
A? Technical basis for the proposed change
A? Impact of change on safety and health
A? Modifications to operating procedures
A? Necessary time period for the change, and
A? Authorization requirements for the proposed change
Employees involved in handling acrolein will be informed and trained in the change prior to startup. Process safety information and operating procedures will be updated, as needed, accordingly.

Pre-startup Reviews:
A pre-startup safety review will be conducted when any modification is significant enough to require change in the process safety information. The review will be conducted by appropriate personnel and other support groups when appropriate.

The review shall consist of at least the following: review of equipment specifications; safety, operating, maintenance, and emergency procedures are in place and adequate; and a process hazard analysis has been performed of the new or modified systems as a whole. The employees will be trained on the new or modified system.

Compliance Audits:
An audit will be conducted on the process safety management of acrolein by Multi-Chem at least once every three years to verify that the procedures and practices developed under the program standard are adequate and are being followed. The audit team shall include personnel from EHS/DOT Director and Facility Manager, and others as deemed appropriate by both parties.

A report will be developed with findings, recommendations and a corrective action plan. The EHS/DOT Director is responsible for developing and implementing the corrective action. The last two audit reports will be retained by the Facility Manager, EHS/DOT Director, and Multi-ChemA?s Risk Manager.

Incident In
vestigation:
Each incident, which results in, or could reasonably have resulted in a catastrophic release of
acrolein, will be investigated promptly - no later than 24 hours following the incident. The
EHS/DOT Director will establish an incident investigation team consisting of at least one person knowledgeable of the acrolein process, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident.

A report shall be prepared by Facility Manager at the conclusion of the investigation and will include at a minimum the following:
A? Date of incident
A? Date investigation began
A? Description of incident
A? Factors that contributed to the incident, and
A? Any recommendations resulting from the investigation
The report shall also establish a corrective action plan, completion dates and documentation of the corrective actions. All affected employees shall review the report. The incident report will be maintained in files for at least five years.

Contractors:
Contractors or visitors working on the acrolein storage area or adjacent to it will be informed of the potential safety and health hazards associated with the process. The contractors will also be informed of the emergency action plan and its contents. The contractorA?s entrance and exit from the facility will be controlled. The contractor will be responsible for complying with the requirements of the OSHA regulation, 29 CFR 1910.119.

4. Five-year Accident History
Multi-Chem, New Iberia has no history of accidents.

5. Emergency Response Plan
Multi-Chem, New Iberia carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public.
To ensure proper functioning, all emergenc
y response equipment are regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within Multi-ChemA?s processes that would require a modified emergency response.


6. Planned Changes to Improve Safety
All safety procedures and plans are in place as of April, 2009. Multi-Chem will review and update these procedures and plans, as required, with maximum intervals of three years. Multi-Chem will be responsible for training all personnel in the use of these safety procedures and for reviewing all changes in the procedures with trained employees.