St. Gabriel Plant - Executive Summary |
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3263 LDEQ Facility ID Number Air Products and Chemicals, Inc. St. Gabriel, Louisiana Chemical Manufacturing Facility 1. Accidental Release Prevention and Emergency Response Policies: The St. Gabriel Plant of Air Products and Chemicals, Inc. incorporates an extensive prevention policy to provide an active defense against injuries or accidental releases. Compliance is maintained for all applicable Federal and state rules and regulations. This facility is ISO 9002 certified for the quality of the process and is re-audited every six months. Employees help incorporate safe work practices through extensive health and safety training. This facilitys emergency response program is compliant with OSHAs HAZWOPER regulation. This facility communicates regularly and works closely with the Louisiana Emergency Planning Committee (LEPC), the Office of Emergency Preparedness (OEP), and other community responders. Detailed emergency response plans incorporating the OEP, the local police an d fire departments, are in place at this facility. 2. Hazardous Chemicals Used and Produced in Quantities Greater than the EPA Threshold Limit: The Air Products and Chemicals, Inc. St. Gabriel Plant is a highly automated manufacturing facility of alkyl-based amines, located on approximately 160 acres 12 miles south of Baton Rouge, LA. Anhydrous ammonia and alcohol are reacted to produce amine products, such as ethylamines and isopropylamines. These amines are then used by other companies to produce a variety of products, such as pharmaceuticals, detergents, automobile coatings, carpet fiber, particle board, plastics, clothing dyes, latex rubber gloves, herbicides, and pesticides. Ammonia, hydrogen, ethylamine, and isopropylamine are stored in quantities greater than the EPA threshold limit for hazardous chemicals. Ammonia is stored in two tanks, each with a maximum capacity of 250,000 lbs and Hydrogen is stored in one tank, with a maximum capacity of 12,000 lbs. Ethylamine i s stored in one tank, with a maximum capacity of 7,400,000 lbs and Isopropylamine is stored in two tanks, one with a maximum capacity of 2,600,000 lbs and the other with 8,800,000 lbs. 3. The Worst-Case Release Scenarios and the Alternative-Case Release Scenarios for Toxic and Flammable Regulated Substances: The worst-case toxic scenario is a catastrophic failure in an ammonia storage tank, resulting in the maximum capacity (250,000 lbs) of the tank to be released and vaporized. This would have off-site impact. Even though safety controls such as alarms, a concrete dike to contain releases, and water monitors to absorb any NH3 vapors are in place, no credit was taken for these active mitigation measures to evaluate this worst-case scenario. The alternative-case toxic scenario is the release of ammonia through a pressure relief valve located on the ammonia column. A reflux failure or cooling loss causes the column to over-pressure and the relief valve to lift. This results in a release of 8350 lbs of ammonia, which would have an off-site impact. The worst-case flammable scenario is a catastrophic failure in the isopropylamine storage tank. The full capacity (8,800,000 lbs) of the tank is assumed to be released and vaporized, causing a vapor cloud explosion. This would have off-site impact. However, no credit was taken for the active mitigation measures in place, such as safety controls and a containment dike, to evaluate this worst-case scenario. The alternative-case flammable scenario is the release of ethylamine through a pressure relief valve located on the storage sphere, resulting in a vapor cloud explosion. This tank over-pressure would be caused by an external fire. This results in a release of 33,680 lbs of ethylamine, which would not have off-site impact. However, ignition sources are limited near the storage tank and the containment dike would help control the release. Fire would be controlled with water and foam. All toxic release sce narios were calculated using the RMP*Comp Ver. 1.06 software. All flammable release scenarios were calculated with the APCI RMP Model established by Air Products and Chemicals, Inc. All worst-case release scenarios assumed an atmospheric stability class of F and a wind speed of 1.5 m/s. All alternative-case release scenarios assumed an atmospheric stability class of D and a wind speed of 3 m/s. Endpoints were calculated for an urban topography. 4. The General Accidental Release Prevention Program and Specific Prevention Steps: The St. Gabriel facility of Air Products takes a pro-active role regarding accidental release prevention. * This facility is ISO 9002 certified and is re-audited every 6 months. * This facility is compliant with the Process Safety Management Program and the OSHA 1910 Process Safety Management Guidelines. * Hazard reviews are conducted for all new processes and procedures. * All government standards for permits are met and maintained. * Safety controls , such as warning alarms and interlocks, provide an active defense. * Automatic shut-off valves and pressure relief devices protect against unexpected changes in temperature or pressure. * Equipment is routinely inspected through a Mechanical Integrity Program. * Standard operating procedures and engineering practices are kept updated and online. * Employees and contractors receive extensive health and safety training. 5. Five Year Accident History: This facility has had one accidental release in the past five years. It occurred on May 26, 1996 during a plant clean-up following an isopropylamine campaign. A total of 479 lbs of chemicals were released through a thermal relief valve on the liquid ammonia loading line. A total of 185 lbs of ammonia, isopropylamine, isopropyl alcohol, and di-isopropylamine were released to the air and 294 lbs were released to the ground. The air discharge caused several area residents to go to a local hospital complaining of respiratory discomfort and nausea. All were evaluated and released that evening. The incident was investigated and the appropriate actions were taken. The set point of the relief valve was raised to a higher pressure compliant with ASME codes, standard operating procedures were modified, and employees were retrained on these procedures. 6. The Emergency Response Program: This facilitys emergency response program is based on OSHAs HAZWOPER standard. In addition, it has on-site medical first responders, a confined-entry rescue team, and an alarm system for fires and spills. In the event of an emergency, it is a member of the Geismar Mutual Aid Organization and it cooperates with a neighboring plant (Novartis) to share personnel trained for fire-fighting. This facility communicates regularly and works closely with the Local Emergency Planning Committee (LEPC), the Office of Emergency Preparedness (OEP), and other community responders. Detailed emergency response plans incorporating the OEP, the local police and fire departments, are in place at this facility. Emergency response drills are performed with these responders and Air Products employees. Under OSHAs HAZWOPER standard, employees have been trained from First Responder Awareness Level to the Instant Command Level. The OEP maintains a manned 24-hour 911 center, the parish emergency siren system, a cable override system, the telephone ring-down system, and a computer-aided dispatch system. Emergency alert information is broadcasted on the 530 AM station. 7. Planned Changes to Improve Safety: The St. Gabriel facility conducted an Operations Plant Hazard Review (OPHR) in May of 1993. The hazard review was revalidated in December 1997, in accordance with the five year revalidation requirement by OSHA1910 - Process Safety Management regulations. These hazard reviews encompass the safety concerns of the process and provide a check to ensure that each concern has been addressed in a timely manner. Changes to impro ve safety based on these hazard reviews include changes in process parameters, process controls, standard operating procedures, and any corresponding documentation. In addition, the quantity of chemicals stored on-site has been reduced due to major plant modifications which allow for continual process runs, instead of batch runs. Safety is a continual focus at this facility. |