Monsanto Company Luling Plant - Executive Summary
1096 LDEQ Facility ID Number |
Monsanto operates several manufacturing units, owned by four different companies: Monsanto Company, Solutia Inc., Rhodia Inc., and Occidental Chemical, at its Luling Plant. Monsanto, the site operator, submitted the initial Risk Management Plan to EPA on June 18, 1999. As a result of Solutia's decision to exit the ammonia business and de-commission the ammonia storage facility, the inventory of anhydrous ammonia has been reduced from 6,000,000 pounds to less than 10,000 pounds between June 1999 and March 2000. This submittal is to reflect the significant reduction in inventory and several minor changes associated with our registration information and Prevention Program.
Monsanto is a life science company committed to finding solutions to the growing global needs for food and health by sharing common forms of science and technology among agriculture, nutrition and health. The company?s 30,000 employees worldwide make and market high-value agricultura
l products, pharmaceuticals and food ingredients. We are committed to pursuing these goals in sustainable ways that meet people's needs without compromising future generation's ability to meet their needs.
One of the locations contributing to this vision is Monsanto's Luling manufacturing plant, located at 12501 River Road in Luling, Louisiana. This facility manufactures Roundup brand herbicide, acetaminophen, ACL brand active chlorine, and stores aqueous ammonia. As part of operations, the facility handles sufficient quantities of chlorine, aqueous ammonia, formaldehyde, phosphorus trichloride, and isopropylamine to require compliance with the EPA's Risk Management Program rule.
The major elements of the RMP prevention program are very similar to OSHA?s PSM regulation. OSHA has conducted an audit of our facility under their Voluntary Protection Program (VPP) and has twice awarded their highest rating - "Star". Receipt of this award demonstrates our commitment to the safety and
health of employees and the surrounding community as well as protection of the environment.
Our location has a documented Emergency Response plan which includes defined responsibilities and actions to be implemented for a number of events, including inclement weather, fire and toxic chemical releases. There are personnel responsible for implementation of this procedure on site at all times. In general, the plan describes actions which result in a safe response for company employees as well as prompt notification of community organizations. The plan has been integrated with the St. Charles Parish Department of Emergency Preparedness (DEP) and other appropriate organizations.
Should an event occur:
DEP is notified immediately.
Plant personnel respond immediately.
DEP determines possible community impact and takes appropriate action which could include no action, shelter-in-place, evacuation, or continual communications.
Methods of communicating to the public include siren system, ca
ble TV, radio, telephone alert system, and door-to-door.
During the past 5 years, there has been one RMP defined accidental release event. It occurred on February 6, 1996 when approximately 6 pounds of formaldehyde was released from a storage tank vent during unloading. As a result, one employee was exposed sufficiently to result in an OSHA recordable injury. Although the DEP was notified as a precautionary measure, there was no discernable community impact. This incident was subsequently investigated according to established Monsanto procedure, and all corrective recommendations made by the investigating committee have been completed.
Based on the type and number of RMP regulated substances present at this facility, seven accidental release scenarios have been provided, one toxic worst case, one flammable worst case, four toxic alternatives, and one flammable alternative. Scenario selection was made by knowledgeable plant personnel, and off-site impacts determined using EPA metho
dologies. The worst case scenario for each chemical assumes the entire contents of a vessel is discharged in a 10 minute period, which is highly unlikely and sometimes physically impossible. Alternate scenarios should be "more likely events."
The toxic worst case scenario is a release of phosphorus trichloride from a rail car. There are four toxic alternate scenarios, aqueous ammonia, formaldehyde, chlorine, and phosphorus trichloride. Mitigation measure generally include emergency shut-down procedures, personnel detection, area sensors, and mass/volume differential computers. The flammable worst case is a release of isopropylamine from a storage vessel. Administrative controls include a limit on inventory. There is one flammable alternate scenario for isopropylamine including an administrative control limit on inventory and area sensors.
In addition to and complimentary with the comprehensive prevention and emergency response program required under the EPA RMP and OSHA PSM
rules, e.g., process hazard analysis, mechanical integrity, operating procedures, management of change procedure, and contractor /guest program, this facility employs numerous other boards, programs, and procedures to promote safety and communication, including:
Safety Board with general oversight and regular meetings
Safety committee and several subcommittees each with its own charter
Human elements awareness initiative
Community advisory panel
Adopt a school program
Hazardous material training
Plant-wide training group
Certified wildlife habitat site
Maintaining and improving the safety of our operations is a core value at our location. This brief summary provides some insight into the extensive system Monsanto utilizes to maintain safe operations. If you would like additional information about Monsanto, please visit our Internet home page at www.monsanto.com. If you have questions about this RMP, please contact us at (504)785-8211.