ICI Americas Inc. - St. Gabriel Site - Executive Summary |
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14535 LDEQ Facility ID Number The ICI Americas Inc. St. Gabriel facility is located on approximately 56 acres one mile south of St. Gabriel, on Louisiana Highway 75. The facility manufactures the refrigerant gas 1,1,1,2-Tetrafluoroethane (KLEA 134a). The facility has been in operation since December 1992 and currently employes 88 people (including contract workers). Although KLEA 134a is the primary product, the facility also produces hydrochloric acid as a process by-product. KLEA 134a is the ozone friendly replacement refrigerant for CFC12. It is used in automotive air conditioners, refrigerators, freezers, appliances (both home and commercial), and has many other consumer uses. It is also purified to a medical-grade for use as a propellant in inhalers. Under EPA's RMP rule, 1,1,1,2-Tetrafluoroethane (KLEA 134a) is not regulated. However, hydrogen fluoride (a raw material used in the process) and hydrochloric acid (a process by-product) are both regulated under the rule. Fl ammable chemcials are not present at the ICI facility in quantities regulated under the RMP rule. This RMP involves predictive filing for hydrochloric acid. The facility produces 36% nominal strength hydrochloric acid. However, it has the capability to produce hydrochloric acid at strengths up to 38%. Since the threshold concentration for hydrochloric acid in the RMP rule is 37% and the facility is capable of producing acid at strengths up to 38%, the predictive filing option is used for 38% hydrochloric acid. The worst-case scenario for the facility is the release of one tank of hydrogen fluoride over a 10-minute period. The quantity modeled for the worst-case scenario is the maximum quantity in one tank taking into account a high level trip that would limit the quantity to that specified herein. No passive mitigation was considered in the modeling of this release scenario. Based on modeling results, offsite impacts would occur. However, the areas affected would depend on the weather conditions for that day. The facility's alternative release scenarios include releases of hydrogen fluoride, anhydrous hydrogen chloride, and 38% hydrochloric acid. Active mitigation, in the form of emergency shutdown systems and the use of a water spray, were considered for the release of hydrogen fluoride. For the release of anhydrous hydrogen chloride, only the use of a water spray was considered for active mitigation. Passive mitigation was not considered for either of these scenarios. Passive mitigation, in the form of a dike, and active mitigation, in the form of emergency shutdown systems and the use of a water spray, were considered for the release of 38% hydrochloric acid. Modeling results indicate that each of these scenarios would have offsite impacts of varying degrees. The quantities of hydrogen fluoride and hydrochloric acid (conc. 37% or greater) provided in Section 1.17.c.3 include not only the maximum quantity found in the manufacturing process, but als o the maximum quantity found in railcars located on-site. Only a small fraction of that shown is in the manufacturing process and of that a significant fraction is in storage (i.e., the bulk of the quantities provided are in storage either in storage tanks or in railcars). Hydrogen chloride (anhydrous) is found only in the manufacturing process. The ICI facility has not, in its entire history, had a release that meets the criteria in the RMP rule for inclusion in the accident history submitted herein. In November 1998 the site achieved 21 years without a lost time accident. The facility has been recognized by the National Safety Council for its outstanding safety performance and has recently been awarded the Chemical Manufacturers Association (CMA) Award of Excellence for achieving zero lost workday cases among both employees and contractors. The facility employs several measures to prevent a catastrophic release from occuring: Design: design reviews; process hazard analyses; ad herence to national, industry, and company design standards; experienced designers; and management of change; Construction: positive material identification; quality assurance inspection; quality assurance testing; and pre-startup safety reviews; Preventive Maintenance: inspection and testing programs; full service maintenance programs; root cause analysis; and improvement upgrades; Control Systems: alarms; interlocks; monitoring systems; computer monitoring and control systems; and backup and fail-safe systems; Training: rigorous employee selection process; new employee training; and annual recertification testing; Auditing: internal audits; corporate audits; and outside/independent audits. In the event of a release, the facility has written procedures and a full emergency response plan in place, along with trained personnel to respond to the emergency. Emergency response drills are held periodically to insure that responders are proficient in the use of mitigation systems and that notification procedures are followed. The facility works in conjunction with the Local Emergency Planning Committee and participates in the activation of the Community Alert Notification (CAN) system. Alarms can be sounded at the facility and, if necessary, throughout the community. The facility is a member of the Geismar Area Mutual Aid (GAMA) association and the Baton Rouge Area Mutual Aid System (BRAMAS) and can request assistance through these organizations. Changes to improve safety are constantly being implemented at the facility. Employee participation programs provide employees significant opportunities for input. Internal reviews and audits provide a means of self-check and identify areas for improvement. Learnings from incidents and incident investigations are shared with all employees as a means of safety improvement. Actions to prevent a recurrence of an incident are tracked to insure timely completion. Site Improvement Teams allow all employees to contribute to the successful operation of the facility. The facility is constantly striving for the highest standards in safe and environmentally sound operation. The ICI Americas Inc. St. Gabriel facility was designed and constructed with prevention of catastrophic releases as a primary goal. In addition, facility personnel are well aware of the hazards associated with the process and work to insure that the facility is operated in a safe, environmentally sound manner. The entire St. Gabriel site is strongly committed to the safeguarding of human health and the environment. Additional Emergency Contacts are provided below: Name/Title Telephone # 24-Hour Telephone # Joel Hall, Safety, Health, & Env. Manager (225)642-6348 (225)642-0094 Jimmy Plauche', Production Supervisor (225)642-6310 (225)642-0094 On-Duty Shift Leader (225)642-6316 (225)642-0094 |