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Tangi-Pac, LLC

Parent Companies:
EPA Facility ID:
100000230092
Other ID:
Facility DUNS:
0

Location:

Address:
101 Ponchatoula Parkway
Ponchatoula, LA 70454
County:
TANGIPAHOA
Lat / Long:
30.425, -90.439 (Get map)
Method:
Address Matching - Block Face
Description:
Administrative Building
Horizonal accuracy:
2 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Ragan and Massey
Phone:
(985) 386-6042
Address:
101 Ponchatoula Parkway
Ponchatoula, LA 70454
Foreign Address:

Person responsible for RMP implementation:

Name:
Mike Massey
Title:
VP

Emergency contact:

Name:
Mike Massey
Title:
VP
Phone:
(985) 386-6042
24-hour phone:
(985) 507-9896
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Full-Time Equivalent Employees:
2
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Inspecting Agency:
Never had one
Using Predictive Filing:
No

Processes:

Amination
RMP ID:
1000064262
CBI claimed:
No
Program Level:
3
NAICS:
Farm Supplies Merchant Wholesalers (42491)
Chemical name
CAS#
Quantity (lbs.)
CBI
Isopropylamine [2-Propanamine]
75-31-0
379,500
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Providence
Address:
1201 Main St.
Baton Rouge, LA 70802
Foreign Address:

Phone:
(225) 766-7400

Latest RMP Submission:

Date:
Jan. 5, 2016
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
1000050617

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

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 Amination)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Retaining Wall
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 Amination)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Dikes
not considered:
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Water curtain

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Amination, Farm Supplies Merchant Wholesalers (42491)
Prevention Program ID:
1000055391
Safety Review Date
Feb. 24, 2015, since latest RMP submission
PHA Update Date
Oct. 1, 2015, since latest RMP submission
PHA Techniques
  • Checklist
Hazards Identified
  • Fire
  • Explosion
Process Controls
  • Vents
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Emergency Power
  • Rupture Disks
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Observation
Procedure Review Date
Sept. 2, 2015, since latest RMP submission
Training Review Date
Sept. 2, 2015, since latest RMP submission
Maintenance Review Date
Aug. 10, 2015, since latest RMP submission
Maintenance Inspection Date
Aug. 10, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Sept. 2, 2015
Pre-startup Review Date
None
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Sept. 2, 2015
Hot Work Review Date
Sept. 2, 2015
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:
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:
Sept. 1, 2015
Local Response Agency:
Local Response Agency Phone:
(985) 386-6648
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

EXECUTIVE SUMMARY



Tangi-Pac is committed to operating in a manner that is safe for the plant workers, the public, and the environment. Tangi-Pac strives to protect and promote the health and safety of its employees, its neighbors, and others who may be affected by activities at the facility. Tangi-Pac also strives to limit adverse effects on the physical environment in which its activities are carried out. The facility has established systems to help ensure safe operation of the processes at this facility. One part of these systems is the risk management program which helps manage the risks at the facility and complies with the requirements of the EPA's Rule 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit an RMP describing the risk management program at the facility.



ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONCE POLICIES



Tangi-Pac's goal at its program 3 stationary source is accidental release prevention, while maintaining emergency response procedures to minimize consequences in the event of any such release. Tangi-Pac maintains a Process Safety Manual directing employees to process safety information in accordance with respective Occupational Safety and Health Administration (OSHA) process safety management and EPA chemical accident prevention provisions. Tangi-Pac also maintains an Emergency Procedures Manual providing necessary information and guidelines to utilize in the event of an emergency situation resulting in accidental release of a regulated substance. Tangi-Pac's objective is to train affected employees and contractors in emergency response procedures, and requires that emergency response actions are supported by proper consideration for safety, health, and welfare of employees, contractors, the surrounding community, and property.



ACCIDENTAL RELEASE PREVENTION PROGRAM



Tangi-Pac has developed a management system to oversee imp
lementation of the RMP elements. Tangi-Pac assigns responsibility for implementing individual requirements of the program to identified persons exhibiting respective qualifications. Tangi-Pac's system includes:



*Compiling process safety information to support completing process hazard analyses.

*Issuing written operating procedures that provide instructions for safely conducting activities in the covered process, and training employees involved in operating the process.

*A mechanical integrity program.

*Management of change procedures and pre-startup safety reviews.

*Compliance audits in order to evaluate compliance with provisions of the program.

*Incident investigation for incidents which resulted in, or could reasonably have resulted in, a release of a regulated substance.

*An established hot work permit program.

*Employee participation and training.

*Contractor pre-qualification, participation, and training.



Tangi-Pac's prevention steps include engineering and administrative controls. Redundant equipment and instrumentation is installed where applicable. Tangi-Pac uses a Distributed Control System to control production in covered process units. Administratively, Tangi-Pac engages in periodic inspection and maintenance practices consistent with industry standards, as well as OSHA and EPA regulatory provisions. Tangi-Pac's covered process units also include fire suppression, containment, and mitigation systems.



EMPLOYEE PARTICIPATION



Employee participation is a goal at Tangi-Pac. Keeping employees informed and involved creates a team unity atmosphere. Employees participate on Process Hazards Analysis (PHA) teams and have access to all information and recommendations. This information along with updated Operation Manuals is available in assigned locations throughout the facility. Operation manuals are developed, updated, and reviewed by Operations personnel and the Training Department. These Operation Manuals assist employees in refresher train
ing and Operator Recertification Programs.



Safety meetings are held on a regular basis for Operations, Maintenance, Administration, and Contract personnel. Topics chosen are relevant to respective personnel assigned duties, and general and specific information is provided as informational instruments to enhance employee participation in facility-wide safety performance.



PROCESS SAFETY INFORMATION



Tangi-Pac keeps a variety of technical documents that are used to help maintain safe process operations. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within Tangi-Pac are assigned responsibility for maintaining up-to-date process safety information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in safety data sheets. For specific process areas, Tangi-Pac has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the operation manuals for each process unit. Tangi-Pac promotes maintaining process parameters within limits by using process controls and monitoring instruments, operating procedures, trained personnel, and protective instrument systems (e.g., automated shutdown systems).



Tangi-Pac also maintains technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to enhance safety features in respective processes.



PROCESS HAZARD ANALYSIS



Tangi-Pac has a comprehensive PHA pr
ogram to recognize and control hazards associated with the process. Within this program, the existing covered process and potential future processes are systematically examined.



Tangi-Pac primarily uses the What-If/Checklist technique to perform these evaluations. The analyses are conducted using a team of personnel who exhibit operating, maintenance, and process engineering experience and expertise. This team identifies and evaluates hazards of the process as well as recommends accident prevention and/or mitigation measures when the team believes such measures are warranted.



Tangi-Pac periodically updates PHAs of affected units. These periodic reviews will be conducted at least every five years and will be conducted at this frequency until the process is no longer operating.



OPERATING PROCEDURES



Tangi-Pac maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and annually certified as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made to the process. In addition, the Tangi-Pac operating procedures provide guidance on how to respond to events that result in exceeding safe operating limits for specific process or equipment parameters. The written operating procedures are readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks.



TRAINING



To complement the written procedures for process operations, Tangi-Pac has implemented a training program for all employees involved in operating a process. New employees receive basic training in Tangi-Pac operations. After operators demo
nstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures in order to maintain skills and knowledge at an acceptable level.



CONTRACTORS



Tangi-Pac uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, Tangi-Pac has procedures in place to provide that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform Tangi-Pac personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, (4) safe work practices, and (5) a work permit process (i.e., for hot work, confined space, etc.) prior to their beginning work. In addition, Tangi-Pac evaluates contractor safety programs and performance during the selection of a contractor. Tangi-Pac personnel monitor contractor performance to evaluate the level at which contractors are fulfilling their safety obligations.



PRE-STARTUP SAFETY REVIEW



Tangi-Pac conducts a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information. This review provides that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to corroborate that construction is in accordance with the design specifications and that all supporting systems are operationally ready. Th
e review team uses checklists to verify all aspects of readiness. A review involves field verification of the construction and serves a quality assurance function.



MECHANICAL INTEGRITY



Tangi-Pac uses established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include:



*Conducting training.

*Developing written procedures.

*Performing inspections and tests.

*Correcting identified deficiencies.

*Applying quality assurance measures.



In combination, these activities form a system that maintains the mechanical integrity of the process equipment. To help ensure that they can perform their job in a safe manner, maintenance personnel receive training on:



*An overview of the process.

*Safety and health hazards.

*Applicable maintenance procedures.

*Emergency response plans.

*Applicable safe work practices.



Written procedures are used in the order that work is performed in a consistent manner and provide a basis for training. Inspections and tests are completed to evaluate equipment functioning as compared to that intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.



Another integral part of the mechanical integrity program is quality assurance. Tangi-Pac incorporates quality assurance measures into equipment purchases and repairs. This practice assesses suitability of new equipment for its intended use and establishes that proper materials and spare parts are used when repairs are made.



MANAGEMENT OF CHANGE



Tangi-Pac
has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards, and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process technology information, equipment information, and procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change.



INCIDENT INVESTIGATION



Tangi-Pac will investigate incidents that resulted in, or reasonably could result in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team, which can include contractors, will document its findings, develop recommendations to prevent a recurrence, and forward these results to Tangi-Pac management for resolution. Corrective actions will be taken in response to the investigation team's findings, and recommendations will be tracked until they are complete. The final resolution of each finding or recommendation will be documented, and the investigation results will be reviewed with all employees (including contractors) who could be affected by the findings.



COMPLIANCE AUDITS



Tangi-Pac is a new site that has recently started operations; therefore, there are no relevant compliance audits to report at this time. Compliance audits will be conducted at least every three years to confirm the procedures and practices required by the chemical accident prevention program are being implemented.



HOT WORK PERMIT




The facility's authorized for hot work; and identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations.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. The permit is followed through to completion of the work and those permits are maintained on site. The facility implements other work permits as necessary to assure safe work conditions are communicated to maintenance and contract personnel.



SAFE WORK PRACTICES



Tangi-Pac has safe work practices in place to sustain worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control welding and other spark-producing activities, and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to foster that operations and maintenance activities are performed safely.



ADDITIONAL SAFETY FEATURES



In addition to the accident prevention program activities, Tangi-Pac has many safety features to help prevent the accidental releases of regulated substances in the facility. These safety features help to prevent potential accident scenarios that could be caused by equipment failures and human error. These features include but are not limited to:



*Operating parameter monitors with alarms

*Process relief systems

*Isolation valves (manual or automated)



FIVE YEAR ACCIDENT HISTORY



Tangi-Pac is a new site that has recently started operations; therefore, there is no relevant accident history to repo
rt at this time. In accordance with the requirements of 40 CFR 68.42, information relating to any accidental release that results in death, injury, significant property damage, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage will be documented for the facility and provided in future RMP submittals.



EMERGENCY RESPONSE PROGRAM



Tangi-Pac's emergency response program is set forth in its Emergency Procedures Manual. That manual is comprised of numerous relevant sections. Those sections deal with, but are not limited to:



*Employee participation

*Incident command management

*Response teams

*Emergency evacuation procedures

*Fire response



The Emergency Procedures Manual states Tangi-Pac's management issued policy statement, which is briefly described in the Accidental Release Prevention and Emergency Response Policies section in this Executive Summary.



PLANNED CHANGES TO IMPROVE SAFETY



Tangi-Pac's mechanisms to improve safety include written procedure review, process hazard analysis, management of change, incident reporting and investigation, near miss reporting and investigation, and employee safety meetings and suggestion processes. Also, Tangi-Pac's pre-startup safety review includes, among other things, 'show stoppers' that prohibit any startup until those items are closed. Tangi-Pac assigns respective tasks resulting from each of these mechanisms to responsible persons, and closure is approved only after all recommendations and action items are documented as complete.