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 only one incident in the last five years that qualifies 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. (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 inclu de 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-up 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 steer ing 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 currently 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 give s 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 did 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-s ite 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 Information 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 Measures - 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 cl oud 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 Scenario - Vapor cloud fire Off-site Impacts - Industrial area Mitigation Measures - Shutoff valve stops leak |