Novartis Crop Protection, Inc. - St. Gabriel Plant - Executive Summary

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2367 LDEQ Facility ID Number 
The Novartis St. Gabriel Plant manufactures and formulates pesticides and specialty chemicals.  Specific processes include: 1) manufacture, formulation and packaging of s-triazine herbicides, 2) manufacture of hydrogen cyanide, a raw material, 3) manufacture, formulation, and packaging activities for various other pesticides and specialty chemicals, 4) process development activities, and 5) supportive activities for the above, which include effluent treatment systems, maintenance, utilities, chemical development, and analytical and quality control. 
Safety in Novartis Crop Protection's St. Gabriel Plant site is incorporated into all aspects of plant operation and is foremost in the design, maintenance and operation of every process.  The facility is guided by an operational philosophy that "safety shall not be compromised for economy".   
Novartis is proud to be certified as an OSHA STAR facility.  As one of over 450  such  sites in the US, we have verifiab 
ly achieved a level of safety performance far surpassing our industry counterparts.  Additionally, our major resident contractor has also achieved this level of safety performance and Federal recognition making us one of  only a few sites in the US to have the host employer and nested contractor with such accolade.   
The following information fulfills the requirements of 40 CFR 68.155; 
(a) The accidental release prevention and emergency response policies at the stationary source; 
Novartis is committed to the Responsible Care Program of the Chemical Industry.  In fact this commitment is included in the corporate Health, Safety and Environment Policy issued by the Novartis Chairman and President.  This corporate policy also states "Health, Safety and Environmental Protection (HSE) are part of our commitment to conduct our activities in harmony with society and nature and without compromising the health and safety of our stakeholders.  We expect all our employees to implement the Novar 
tis HSE Policy." 
This commitment to safety is supported from the corporate senior management down to the plant workers.  Employees at Novartis participate in several groups committed to safety at the plant.  These include a Safety Incentive Committee (SIC'M), Unit Health and Safety Committees, and an Employee Health and Safety Committee. 
Novartis also has a strong commitment to the environment.  Several programs are run on-site by employees to assist in this commitment.  These include a spill prevention committee which has been successful in reducing the number of on-site spills from 1992 by more than half and an Employee Environmental Committee which runs a comprehensive recycling program and has developed and maintains a nature trail. 
Some of our awards and recognition's which reflect our strong safety and environmental commitments include: Award for Pollution Prevention Activities (LaDEQ), Certified Corporate Habitat Program (Wildlife Habitat Council), Forest Stewardship Certific 
ation (Department of Agriculture), Environmental Leadership Program Pilot Program (DEQ/EPA), Gold Medal for Corporate Environmental Achievement (World Environmental Center), Total Quality Management Award (Malcolm Baldridge) and the National Award for Environmental Sustainability (Renew America). 
In addition to the strong corporate HSE policies, the Novartis St. Gabriel Plant site instills a strong site level commitment to health safety and the environment.  These are evident in several plant policy and procedures, including Plant Procedure A-1, which is the Statement of Policy.  This procedure states that "safety is a primary concern at Novartis" and that "it is the policy of the St. Gabriel Plant management that safety is a definite job requirement at every level of the organization".    
More relevant to the Risk Management Program is Plant Procedure C-8 which is entitled Process Safety Management Standard Compliance Procedure.  The purpose of this procedure is "To establish mea 
sures (per Process safety Management standard 29 CFR 1910.11 and Risk Management Program 40 CFR 68) to ensure that accidental releases of toxic, reactive, flammable, or explosive chemicals are minimized and procedures are in place to lessen the consequence should  large release occur. 
(b) The stationary source and regulated substances handled; 
In order to best comply with the requirements of this initial RMP submission, Novartis has separated the facility into  several processes.  Of these, the  processes subject to RMP and the regulated substances handled by these processes are as follows:   
MPF Unit - anhydrous hydrogen chloride; hydrogen; anhydrous ammonia 
Development Pilot Plant - bromine; vinyl acetate; phosgene; chlorine 
HCN/Sequestrene/HPF and associated Tank Farms - anhydrous ammonia; sulfur dioxide; formaldehyde solution; ethylenediamine; hydrocyanic acid; chlorine; isopropylamine; ethylamine 
Note that in completing Section 7.0 of the RMP, the description of the pre 
vention programs for these units, Novartis separated the HCN/Sequestrene/HPF and associated Tank Farms into three sub-processes.  This was done because the Process Hazard Analysis for each of these is done independently of the others.  Also note that the information provided for each of these represents  the entire unit and  associated chemicals as opposed to  describing only the regulated compounds. 
(c) The worst-case release scenario(s) and alternative release scenario(s), including administrative controls and mitigation measures to limit distances for each reported scenario; 
As required by the RMP regulations, Novartis has conducted and is providing the required off-site consequence analysis of potential releases.  This information is provided in a table format at the end of this summary. 
(d) The general accidental release prevention program and chemical-specific prevention steps; 
Novartis is regulated by the Process Safety Management regulations and as such conducts vari 
ous process hazard analyses to prevent accidental releases from the facility.  These analyses are conducted on unit equipment as well as processes and procedures. 
  Novartis also has comprehensive procedures for inspection and maintenance of equipment.  The Novartis Maintenance Department maintains a Preventive/Predictive Maintenance (PM/PDM) Manual.  This comprehensive manual documents the system used to ensure that maintenance and inspections are conducted effectively and efficiently and hat closure is attained on recommendations resulting from these activities.  The PM/PDM incorporates inspection plans designed to "enhance safety, environmental integrity, operational reliability, and protection for plant personnel and the surrounding community". 
Novartis also conducts extensive employee training.  Some of this training is done via a Computer Aided Training System (CATS) allowing on demand training around the clock.  The Training Records Information Management System (TRIM) ele 
ctronically records this training. 
(e) The five-year accident history; 
Novartis has had two incidents in the last five years that qualify as an accident reportable under the RMP Five-year Accident History.  On April 10, 1995, a sight glass on a reactor shattered releasing a mixture containing approximately 326 pounds of hydrogen chloride.  Although no off-site impact as defined by RMP occurred, two on-site injuries did occur.  As a result of this incident, all sight glasses considered unnecessary were removed.  The remaining sight glasses were replaced with a more sturdy design. 
                                                                                                                                                                    Also, on July 18, 1999, a release of approximately 125 pounds of ammonia occurred due to a gasket leak.  Although no off-site or on-site injuries or environmental damage occurred, approximately 1,200 residents were requested to shelter-in-plac 
e as a precautionary measure.  As a result of this incident, Novartis has revised the method of gasket replacement as well as the appropriate operating procedures.                                                                                                                                                                                 
(f) The emergency response program; 
Novartis is a very proactive participant of the local Community Awareness and Emergency Response (CAER) committee as well as having close involvement and interaction with the Iberville Parish Emergency Preparedness agency (the local LEPC).  The facility is part of the community emergency response plan and has a facility emergency response plan.  Both plans include specific actions to be taken in response to accidental releases of regulated substances. 
In the event of an emergency Novartis, in conjunction with the LEPC, has several mechanisms in place to notify the surrounding community including an automated dial-u 
p phone system, activation of a televised public announcement and a strategically placed community siren system.  Novartis also has on-site first aid and emergency medical responders, a hazmat team as well as emergency response equipment including a fire truck and ambulance. 
(g) Planned changes to improve safety. 
As a result of the HCN Super PR/OP, a high integrity  safety system was installed in the HCN and Sequestrene Units.  The system provides dedicated safety functions in both units as well as "watch-dog" functions for the process control system.  In addition some of the older plan process control computers are being replaced with new, state of the art control systems. 
The existing Employee Health and Safety Committee steering committee is being expanded to include other safety committee representatives, medical, industrial hygiene and other groups.  This is being done to coordinate long term safety objectives and help further improve our excellent safety record. 
The site curr 
ently tracks all spills, even small spills contained completely within secondary containment.  The current electronic incident tracking system is being expanded to include electronic spill reporting to replace the current paper reporting system. 
The following supplemental information is provided as supporting information to the preparation of this RMP submission. 
As recommended by EPA, Novartis obtained the information on  the potentially affected population from LandView III.  This software is based on the 1990 census and provides two methods of determining the population within a given area.  Novartis chose to use the  Block Group Uniform Density  as opposed to the Block Group Centroid Method as it is felt that this method gives better estimations.  However, due to the calculation technique used in this method, it was found populations were given in areas which clearly have no residents.  For instance when the impact area was only over industrial areas.  In these cases, Novartis di 
d not rely on the LandView III information. 
Although Novartis provided the most current date for the completed Process Hazard Analysis in the HCN Unit and MPF Unit, these processes are currently finalizing another PHA as required by the PSM regulations.  These tasks are anticipated to be complete by July 1999. 
The alternative release scenario determined for phosgene is a pipe leak at 0.02 pounds/hour for 5 minutes.  The RMPSubmit software however would not allow for values this low.  As such, the values in the software are overstated, however the offsite impact is based on the actual values determined. 
Worst Case Release Scenario Information 
Toxic Chemical - Ammonia 
Scenario - Gas release of entire storage tank contents 
Off-site Impacts - Schools; residences; hospitals;  prisons; recreation areas; industrial areas 
Flammable Chemical -Isopropylamine 
Scenario -Vapor cloud explosion of entire tank contents 
Off-site Impacts - Industrial areas 
Alternative Release Scenario Informat 
Chemical - Anhydrous Ammonia 
Scenario - Storage tank gasket blow out 
Off-site Impacts - Industrial areas 
Mitigation Measures - Isolation valve stops flow; water cannon suppresses vapors 
Chemical - Bromine 
Scenario - Vessel Leak 
Off-site Impacts - None 
Mitigation Measures - Transfer stopped; neutralization stops vapors 
Chemical - Chlorine 
Scenario - Pipe leak 
Off-site Impacts - Residence, recreation area, industrial area 
Mitigation Measures - Emergency shutdown system; supplier pulls back liquid in pipe to stop leak 
Chemical - Ethylenediamine 
Scenario - Gasket failure 
Off-site Impacts - Industrial area 
Mitigation Measures - Stop pump and close valve; water spray suppresses vapors 
Chemical - Formaldehyde Solution 
Scenario - Gasket failure 
Off-site Impacts - Industrial areas 
Mitigation Measures - Stop pump and close valve; dike contains spill; deluge system suppresses vapors 
Chemical - Hydrocyanic Acid 
Scenario - Gasket failure 
Off-site Impacts - Industrial areas 
Mitigation Meas 
ures - Shutdown system stops leak; deluge system suppresses vapors 
Chemical - Hydrogen Chloride 
Scenario - Actual incident - Sight glass breaks 
Off-site Impacts - Industrial areas 
Mitigation Measures - Blocked in flow; drained to sump and neutralize to stop vapors 
Chemical - Phosgene 
Scenario - Pipe leak 
Off-site Impacts - None 
Mitigation Measures - Enclosure contains fumes; scrubber reduces by 99% 
Chemical - Sulfur dioxide 
Scenario - Cylinder plug melts 
Off-site Impacts - Industrial areas 
Mitigation Measures - Plug stops leak; water cannon suppresses vapors 
Chemical - Vinyl acetate 
Scenario - Drum leak 
Off-site Impacts - None 
Mitigation Measures - Plug stops leak; adsorbent stops vapors 
Chemical - Hydrogen 
Scenario - Vapor cloud fire 
Off-site Impacts - None 
Mitigation Measures - Remote shutoff valve stops leak 
Chemical - Isopropylamine 
Scenario - Vapor cloud fire 
Off-site Impacts - Industrial area 
Mitigation Measures - Remote shutoff of pump stops leak 
Chemical - Ethylamine 
nario - Vapor cloud fire 
Off-site Impacts - Industrial area 
Mitigation Measures - Shutoff valve stops leak
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