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Facility #1 : KMCO, LLC


Basic Facility Info facility_Basic_Facility_Info help link help link  
Facility ID100000118623
Deregistered (Yes/No)No
Facility NameKMCO, LLC
Street Address Line 116503 Ramsey Road
CityCrosby
StateTX
Zip Code77532
CountyHarris County
Owner or Operator NameORG Chemical MidCo, LLC
Latitude29.921667
Longitude-95.053056
Number of RMP Submissions9

Most Recent Submission Info facility_Most_Recent_Submission_Info help link help link  
RMP ID1000068260
Submission Typerevised submission for facility
Submission Date02/23/2018
Reason For SubmissionRegulated substance present above TQ in new (or previously not covered) process (40 CFR 68.190(b)(4))
Process Toxic Amount Total (lbs)10,250,000
Process Flammable Amount Total (lbs)493,130
Process Amount Total (lbs)10,743,130
Number of Potential Offsite Consequence Processes2
Potential Offsite Consequence Toxic Amount Total (lbs)10,250,000
Potential Offsite Consequence Flammable Amount Total (lbs)493,130
Potential Offsite Consequence Amount Total (lbs)10,743,130
All Process NAICS325199 32519
Exec Summary Submission Date02/23/2018

Executive Summary facility_Executive_Summary help link help link (Facility #1 : KMCO, LLC, executive summary: all)

Executive Summary
KMCO

Risk Management Plan



1. EXECUTIVE SUMMARY



KMCO is committed to operating in a manner that is safe for KMCO workers, the public, and the environment. As part of this commitment, KMCO has established a system to help ensure safe operation of the processes at this facility. One part of this system is a risk management program (RMP) that helps manage the risks at KMCO and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements; Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at KMCO. This document is intended to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of the risk management program at KMCO.



1.1 Accidental Release Prevention and Emergency Response Policies



KMCO is committed to the safety of KMCO workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. KMCO implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, our trained Emergency Response personnel will respond to control and contain such releases. KMCO evaluates each situation, evacuates workers as necessary, and contacts the local fire department to control and contain the release and to prevent and/or reduce the consequences of the release. KMCO, the local emergency planning committee (LEPC), and the fire department have established a program to warn the community if an accident occurs that could threaten the community.



1.2 KMCO and Regulated Substances



KMCO handles six listed toxic substances by the RMP rule in sufficient quantities to be covered by the RMP rule:



Ethylene oxide is stored for use in the customer tolling processes. KMCO also handles propylene oxide
, formalin, ammonia, ethyl chloride, and sulfur dioxide.









1.3 Offsite Consequence Analysis



KMCO performed an offsite consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. The OCA consists of evaluating both worst-case scenarios (WCSs) and alternative release scenarios (ARSs). KMCO does not expect a worst case release scenario to ever occur. An ARS represents a release that might occur during the lifetime of a facility like KMCO. ARSs help the LEPC improve the community emergency response plan. We have shared that information with the LEPC and other organizations involved in emergency response activities. It is also available to the public. If you are interested in this information, please contact our RMP coordinator at (281) 328-3501.



The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance. At distances less than the endpoint distance, the effects should be greater; at distances greater than the endpoint distance, the effects would be less.



Worst-case Release Scenarios



The worst-case release scenario for toxic substances is failure of a storage tank containing 246,000 lbs of Ethylene Oxide (EO). KMCO does not believe that a worst case scenario could ever occur. Nevertheless, a computer modeling program, RMP Comp, was used to calculate offsite impact. The scenario is based on the following: the product is liquefied by refrigeration, release is to concrete diked contaiment, and the release rate due to evaporation is 310 lbs/minute for a duration of 792 minutes in rural surroundings. Although mitigation measures (e.g., deluge system at the storage tanks) are available, none were assumed for the modeling. Factors such as city water service interruption and/or low water pre
ssure (firewater pump failure) were also assumed. Calculation resulted in a distance to toxic endpoint of 3.5 miles, and the toxic cloud would affect the surrounding populous.



Alternative Release Scenarios



The ARS for EO is rupture of a 2-inch diameter liquid unloading line (located outside of containment) from the railcar to one of the secondary EO storage tanks. This scenario assumes the EO is liquefied under pressure, release duration is 10 minutes, with no mitigation. (There is containment around the EO storage tank -- specifically, a 26' x 20' x 6' deep concrete ""bunker"" , with a wall thickness of 12"". But, for this scenario, it will not be considered applicable.) Estimated distance to toxic endpoint is 0.3 miles.

Other alternate scenarios are available for each of the other substances handled.



1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps



The following is a summary of the general accident prevention program in place at the KMCO plant. Because processes at the KMCO plant are regulated by the EPA RMP regulation are also subject to the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.



Employee Participation



KMCO encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to information created as part of the KMCO plant accident prevention program. In addition, KMCO has a number of initiatives under way that address process safety and employee safety issues. These initiatives include a Safety Committee to promote both process and personal safety. The team has members from
various areas of the plant, including operations, maintenance, engineering, administration, and plant management.



Process Safety Information



KMCO keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs) and available on the KMCO intranet. This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, KMCO has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in PHA documentation. KMCO ensures that the process is maintained within these limits by using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g. pressure/temperature indicators and automated shutdown systems).



KMCO also maintains documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel,, provides a basis for establishing inspection and maintenance activities, as well as for evaluating prop9osed process and facility changes to ensure that safety features in the process are not compromised.



Process Hazard Analysis



KMCO has established programs to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify
hazards and ensure that adequate controls are in place to manage these hazards.



HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise.



The PHA team findings and/or action items are forwarded to appropriate personnel. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained.



These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to appropriate personnel for consideration, and the final resolution of the findings is documented and retained.





Operating Procedures



KMCO maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent graining of new operators. Procedures are periodically reviewed and annually certified as current and accurate. Procedures are maintained current by revising them as necessary to reflect changes made through the management of change process.



Training



To complement the written procedures for process operations, KMCO has implemented a company-training program for employees involved in operating a process. New employees receive basic training in KMCO plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties an
d tasks. After operators demonstrate (e.g. through test, skill demonstration) they possess adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years.

All of this training is documented for each operator, including the means used to verify that the operator understood the training.



Contractors



KMCO uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, KMCO has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform KMCO plant personnel of any hazards that they find during their work.





Pre-startup Safety Reviews (PSSRs)



KMCO conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all-supporting systems are operationally ready.



Mechanical Integrity



KMCO has practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include:

(1) conducting training, (2) developing writt
en procedures, (3) performing inspections and trust, (4) correcting identified deficiencies, and (5) applying quality assurance measures.



Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or an MOC will be distributed to appropriate personnel to review the use of equipment and determine what actions are necessary to ensure the safe operation of the equipment.



Safe Work Practices



KMCO has safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e. hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.



Management of Change



KMCO has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to i
ncorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change.



Incident Investigation



KMCO investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to the HSE Department for filing recommendations are tracked until they are complete.



Compliance Audits



Compliance audits are conducted at least every 3 years. Both hourly and management personnel may participate as audit team members and typically a third-party consultant is hired to assist in the audit. The audit team develops findings that are forwarded to KMCO plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the most recent audit report is retained.



Chemical-specific Prevention Steps



The processes at KMCO have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all Program 2 and 3 EPA RMP -covered processes at KMCO. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors.



In addition to the accident prevention program activities, KMCO has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes:



Release Detection



* Ethylene Oxide detectors

* Proces
s alarms



Release Containment/Control

* Process relief valves that discharge to a flare to capture and incinerate episodic releases

* Scrubber to neutralize chemical releases

* Valves to permit isolation of the process (manual or automated)

* Automated shutdown systems for specific process parameters (e.g. high level, high temperature)

* Curbing or diking to contain liquid releases

* Redundant equipment and instrumentation (e.g. uninterruptible power supply for process control system, backup firewater pump)

* Atmospheric relief devices



Release Mitigation



* Fire suppression and extinguishing systems

* Deluge system for specific equipment

* Trained emergency response personnel

* Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)



1.5 Five-Year Accident History



No releases of Ethylene Oxide, Propylene Oxide, Sulfur dioxide, Formaldehyde solution, Ethyl Chloride, or Ammonia have occurred from KMCO in the last five years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site.







1.6 Emergency Response Program



KMCO coordinates emergency response procedures with the local fire department. KMCO emergency response personnel will respond to minor events that do not have the potential for significant effect (e.g., small fires or small leaks). In the event of a larger fire or release, workers and contractors may evacuate the area if necessary and contact the local fire department. KMCO's emergency response team (ERT) is trained to respond to larger fires and releases. Training includes a two-day and four-day annual fire school at Texas A&M (TEEX).



KMCO has established a written emergency response plan that has been communicated to local emergency response officials through the local fire department. Regular dialogue is maintained between KMCO and the Fire Chief and Dep
artment. KMCO is a member of the Local Mutual Aid Organization (MAMB).



1.7 Planned Changes to Improve Safety



KMCO strives to improve the safety of KMCO processes through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers. KMCO resolves all findings from PHAs,, some of which result in modifications to the process. The following types of changes are planned during the next 5 years:



* Ongoing revisions to personnel training programs



* Revised written operating procedures
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees164
Owner or Operator NameORG Chemical MidCo, LLC
Owner or Operator Address Line 116503 Ramsey Road
Owner or Operator CityCrosby
Owner or Operator StateTX
Owner or Operator Zip77532
Parent Dun and Bradstreet Number0
Second Parent Dun and Bradstreet Number0
Number of Full Time Employees164
Number of FTE CBI FlagNo
Other Facility IDTXD 074198961
Covered by OSHA PSM StandardYes
Covered by EPCRA Section 302Yes
Covered by CAA Title VYes
CAA Title V Air Operating Permit IDO-01441
Last Safety Inspection Date20150128
Last Safety Inspection ByEPA
OSHA Star or Merit RankingNo
LEPC NameHarris County-

Submission - Contact Info facility_Submission_-_Contact_Info help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223)
Owner or Operator Phone2813283501
Facility URLhttp://kmcollc.com
Facility Phone2813283501
Facility Dun and Bradstreet Number74198961
RMP ContactKelly Nidini
RMP Contact TitleHSSE Manager
RMP Contact Emailkellyn@kmcoinc.com
RMP Preparer NameRita Hunter
RMP Preparer Address Line 116503 Ramsey Road
RMP Preparer CityCrosby
RMP Preparer StateTX
RMP Preparer Zip77532
RMP Preparer Phone2813280263

Submission - Additional Info facility_Submission_-_Additional_Info help link help link  
RMP Complete FlagYes
Predictive FilingYes
No RMP Accidents Last 5 YearsYes
Complete Check Date20180223
Error Report Datenull
Postmark Date20180223
Anniversary Date20230223
Confidential Business InformationNo

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223)
Latitude29.921667
Longitude-95.053056
Valid Lat/LongYes
Lat/Long MethodInterpolation - Satellite
Lat/Long Location TypeProcess Unit Area Centroid
FRS Latitude29.9217
FRS Longitude-95.0533
FRS Lat/Long DescriptionFACILITY CENTROID
FRS Lat/Long MethodINTERPOLATION-MAP

Submission - Counts and Totals facility_Submission_-_Counts_and_Totals help link help link  
Number of RMP Accidents0
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Number of RMP Accidents0
Number of Processes2
Number of Process Chemicals0
Number of Toxic Worst-case Scenarios1
Number of Toxic Alternate Case Scenarios5
Number of Flammable Worst-case Scenarios2
Number of Flammable Alternate Case Scenarios1
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Total RMP Accident Deaths0
Total RMP Accident Injuries0
Total RMP Accident Evacuated/Sheltering In Place0
Total RMP Accident Property Damage$0

Processes facility_Processes help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c)
Process DescriptionBatch Reaction, organic c
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)10,250,000
Flammable Amount Total (lbs)150,000
Process Amount Total (lbs)10,400,000
Number of Process Chemicals0
Number of Toxic Worst-Case Scenarios1
Number of Toxic Alternate Scenarios5
Number of Flammable Worst-Case Scenarios1
Number of Flammable Alternate Scenarios0

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDEthyl chloride [Ethane, chloro-]
CAS number000075003
Chemical TypeFlammable
Process Chemical Amount (lbs)150,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process chemical #2)
Process Chemical IDEthylene oxide [Oxirane]
CAS number000075218
Chemical TypeToxic
Process Chemical Amount (lbs)5,000,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDFormaldehyde (solution)
CAS number000050000
Chemical TypeToxic
Process Chemical Amount (lbs)150,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDPropylene oxide [Oxirane, methyl-]
CAS number000075569
Chemical TypeToxic
Process Chemical Amount (lbs)5,000,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process chemical #5)
Process Chemical IDSulfur dioxide (anhydrous)
CAS number007446095
Chemical TypeToxic
Process Chemical Amount (lbs)50,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDAmmonia (anhydrous)
CAS number007664417
Chemical TypeToxic
Process Chemical Amount (lbs)50,000
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Worst-Case Flammable Scenarios facility_Worst-Case_Flammable_Scenarios help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process chemical #7, worst-case flammable scenario #1)
Model UsedEPA's RMP*Comp(TM)
Passive Mitigation - Blast WallsNo
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Worst-Case Toxic Scenarios facility_Worst-Case_Toxic_Scenarios help link help link  
Percent Weight (Within Mixture)100
Physical StateGas liquified by refrigeration
Model UsedEPA's RMP*Comp(TM)
Release Duration (minutes)1
Wind Speed (meters/sec)1.5
Atmospheric Stability ClassF
TopographyRural
Passive Mitigation - DikesYes
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Passive Mitigation - Otherpartially-submerged concrete bunker, with above-ground concrete surrounding walls
Confidential Business InformationNo

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process chemical #8, alternate toxic scenario #1)
Percent Weight (Within Mixture)100
Physical StateGas liquified by refrigeration
Model UsedEPA's RMP*Comp(TM)
Wind Speed1.5
Atmospheric Stability ClassF
TopographyRural
Passive Mitigation - DikesYes
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsNo
Active Mitigation - Water CurtainNo
Active Mitigation - NeutralizationNo
Active Mitigation - Excess Flow ValvesNo
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownNo
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process chemical #9)
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link  
Percent Weight (Within Mixture)37
Physical StateLiquid
Model UsedEPA's RMP*Comp(TM)
Wind Speed3
Atmospheric Stability ClassD
TopographyRural
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsNo
Active Mitigation - Water CurtainNo
Active Mitigation - NeutralizationNo
Active Mitigation - Excess Flow ValvesNo
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownNo
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process chemical #10)
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link  
Percent Weight (Within Mixture)100
Physical StateLiquid
Model UsedEPA's RMP*Comp(TM)
Wind Speed1.5
Atmospheric Stability ClassA
TopographyRural
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsNo
Active Mitigation - Water CurtainNo
Active Mitigation - NeutralizationNo
Active Mitigation - Excess Flow ValvesNo
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownNo
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process chemical #11)
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link  
Percent Weight (Within Mixture)100
Physical StateGas
Model UsedEPA's RMP*Comp(TM)
Wind Speed3
Atmospheric Stability ClassD
TopographyRural
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsNo
Active Mitigation - Water CurtainNo
Active Mitigation - NeutralizationNo
Active Mitigation - Excess Flow ValvesNo
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownNo
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process chemical #12)
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Alternate Case Toxic Scenarios facility_Alternate_Case_Toxic_Scenarios help link help link  
Percent Weight (Within Mixture)100
Physical StateGas liquified by pressure
Model UsedEPA's RMP*Comp(TM)
Wind Speed3
Atmospheric Stability ClassD
TopographyRural
Passive Mitigation - DikesNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - BermsNo
Passive Mitigation - DrainsNo
Passive Mitigation - SumpsNo
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsNo
Active Mitigation - Water CurtainNo
Active Mitigation - NeutralizationNo
Active Mitigation - Excess Flow ValvesNo
Active Mitigation - FlaresNo
Active Mitigation - ScrubbersNo
Active Mitigation - Emergency ShutdownNo
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process NAICS code #1 : 325199)
NAICS Code325199: All Other Basic Organic Chemical Manufacturing

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date20150220
PHA Update Date20140926
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20150630
Hazard Identified - Toxic ReleaseYes
Hazard Identified - FireNo
Hazard Identified - ExplosionNo
Hazard Identified - Runaway ReactionNo
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureNo
Hazard Identified - CorrosionNo
Hazard Identified - OverfillingNo
Hazard Identified - ContaminationNo
Hazard Identified - Equipment FailureNo
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeNo
Hazard Identified - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
Process Controls - VentsYes
Process Controls - Relief ValvesYes
Process Controls - Check ValvesYes
Process Controls - ScrubbersYes
Process Controls - FlaresNo
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsNo
Process Controls - InterlocksNo
Process Controls - AlarmsYes
Process Controls - Keyed BypassNo
Process Controls - Emergency AirYes
Process Controls - Emergency PowerNo
Process Controls - Backup PumpNo
Process Controls - GroundingYes
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksYes
Process Controls - Excess Flow DevicesNo
Process Controls - Quench SystemYes
Process Controls - Purge SystemYes
Process Controls - NoneNo
Mitigation Systems - SprinklersNo
Mitigation Systems - DikesYes
Mitigation Systems - Fire WallsNo
Mitigation Systems - Blast WallsYes
Mitigation Systems - Deluge SystemsYes
Mitigation Systems - Water CurtainsNo
Mitigation Systems - EnclosureYes
Mitigation Systems - NeutralizationNo
Mitigation Systems - NoneNo
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Monitoring Systems - OtherEO storage temp and pressure instrumentation (TI, PI)
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryYes
Changes Since PHA - Process ParametersNo
Changes Since PHA - Process ControlsNo
Changes Since PHA - Process DetectionNo
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Procedure Review Date20170911
Training Review Date20161012
Type of Training - ClassroomNo
Type of Training - On the JobYes
Type of Training - OtherComputer Based Training
Competency Testing - Written TestsYes
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationYes
Competency Testing - ObservationNo
Competency Testing - OtherOn the Job Training
Maintenance Review Date20150128
Maintenance Inspection Date20150213
Equipment TestedPRVs
Management of Change Most Recent Date20150205
Management of Change Review Date20150205
Pre-startup Review Date20150428
Compliance Audit Date20160429
Compliance Audit Change Completion Date20170131
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20150128
Hot Work Review Date20160621
Contractor Safety Review Date20150128
Contractor Safety Eval. Date20160718
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process NAICS code #1 : 325199, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
1000106892
1000106891
1000106893
1000106894
1000106895
1000106896

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  

Prevention Program Description

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date20150220
PHA Update Date20140926
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20150630
Hazard Identified - Toxic ReleaseYes
Hazard Identified - FireNo
Hazard Identified - ExplosionNo
Hazard Identified - Runaway ReactionNo
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureNo
Hazard Identified - CorrosionNo
Hazard Identified - OverfillingNo
Hazard Identified - ContaminationNo
Hazard Identified - Equipment FailureNo
Hazard Identified - Cooling LossYes
Hazard Identified - EarthquakeNo
Hazard Identified - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
Process Controls - VentsYes
Process Controls - Relief ValvesYes
Process Controls - Check ValvesYes
Process Controls - ScrubbersYes
Process Controls - FlaresNo
Process Controls - Manual ShutoffsYes
Process Controls - Auto ShutoffsNo
Process Controls - InterlocksNo
Process Controls - AlarmsYes
Process Controls - Keyed BypassNo
Process Controls - Emergency AirYes
Process Controls - Emergency PowerNo
Process Controls - Backup PumpNo
Process Controls - GroundingYes
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksYes
Process Controls - Excess Flow DevicesNo
Process Controls - Quench SystemYes
Process Controls - Purge SystemYes
Process Controls - NoneNo
Mitigation Systems - SprinklersNo
Mitigation Systems - DikesYes
Mitigation Systems - Fire WallsNo
Mitigation Systems - Blast WallsYes
Mitigation Systems - Deluge SystemsYes
Mitigation Systems - Water CurtainsNo
Mitigation Systems - EnclosureYes
Mitigation Systems - NeutralizationNo
Mitigation Systems - NoneNo
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Monitoring Systems - OtherEO storage temp and presure instrumentation (TI, PI)
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryYes
Changes Since PHA - Process ParametersNo
Changes Since PHA - Process ControlsNo
Changes Since PHA - Process DetectionNo
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedNo
Changes Since PHA - NoneNo
Procedure Review Date20170911
Training Review Date20150128
Type of Training - ClassroomNo
Type of Training - On the JobYes
Competency Testing - Written TestsYes
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationYes
Competency Testing - ObservationNo
Competency Testing - OtherOn Job Training
Maintenance Review Date20150128
Maintenance Inspection Date20150213
Equipment TestedPRVs
Management of Change Most Recent Date20150205
Management of Change Review Date20150128
Pre-startup Review Date20150428
Compliance Audit Date20160525
Compliance Audit Change Completion Date20161028
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20150128
Hot Work Review Date20160621
Contractor Safety Review Date20150128
Contractor Safety Eval. Date20160718
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #1 : Batch Reaction, organic c, process NAICS code #1 : 325199, prev. program 3 #2, prev. program 3 chemical: all)
Process Chemical Record ID
1000106894
1000106891
1000106893
1000106895
1000106896
1000106892

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description


Processes facility_Processes help link help link  
Process DescriptionIsobutylene
Program Level3
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)343,130
Process Amount Total (lbs)343,130
Number of Process Chemicals0
Number of Toxic Worst-Case Scenarios0
Number of Toxic Alternate Scenarios0
Number of Flammable Worst-Case Scenarios1
Number of Flammable Alternate Scenarios1

Process Chemicals facility_Process_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #2 : Isobutylene, process chemical #1)
Process Chemical ID2-Methylpropene [1-Propene, 2-methyl-]
CAS number000115117
Chemical TypeFlammable
Process Chemical Amount (lbs)343,130
Confidential Business InformationNo

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Worst-Case Flammable Scenarios facility_Worst-Case_Flammable_Scenarios help link help link  
Model UsedEPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
Passive Mitigation - Blast WallsNo
Passive Mitigation - OtherLEL Detectors
Confidential Business InformationNo

Alternate Case Flammable Scenarios facility_Alternate_Case_Flammable_Scenarios help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #2 : Isobutylene, process chemical #2, alternate flammable scenario #1)
Model UsedEPA's RMP Guidance for Chemical Distributors Reference Tables or Equations
Passive Mitigation - DikesNo
Passive Mitigation - Fire WallsNo
Passive Mitigation - Blast WallsNo
Passive Mitigation - EnclosuresNo
Passive Mitigation - OtherLEL Detectors
Active Mitigation - SprinklersNo
Active Mitigation - Deluge SystemsYes
Active Mitigation - Water CurtainNo
Active Mitigation - Excess Flow ValvesNo
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link  
NAICS Code32519: Other Basic Organic Chemical Manufacturing

Prevention Program 3 facility_Prevention_Program_3 help link help link  
Safety Info Review Date20150220
PHA Update Date20140926
PHA Technique - What IfNo
PHA Technique - ChecklistNo
PHA Technique - What If/ChecklistNo
PHA Technique - HAZOPYes
PHA Technique - FMEANo
PHA Technique - FTANo
PHA Change Completion Date20150630
Hazard Identified - Toxic ReleaseNo
Hazard Identified - FireYes
Hazard Identified - ExplosionNo
Hazard Identified - Runaway ReactionNo
Hazard Identified - PolymerizationNo
Hazard Identified - OverpressureNo
Hazard Identified - CorrosionNo
Hazard Identified - OverfillingNo
Hazard Identified - ContaminationNo
Hazard Identified - Equipment FailureNo
Hazard Identified - Cooling LossNo
Hazard Identified - EarthquakeNo
Hazard Identified - FloodNo
Hazard Identified - TornadoNo
Hazard Identified - HurricaneNo
Process Controls - VentsNo
Process Controls - Relief ValvesYes
Process Controls - Check ValvesNo
Process Controls - ScrubbersNo
Process Controls - FlaresNo
Process Controls - Manual ShutoffsNo
Process Controls - Auto ShutoffsNo
Process Controls - InterlocksNo
Process Controls - AlarmsNo
Process Controls - Keyed BypassNo
Process Controls - Emergency AirNo
Process Controls - Emergency PowerNo
Process Controls - Backup PumpNo
Process Controls - GroundingYes
Process Controls - Inhibitor AdditionNo
Process Controls - Rupture DisksNo
Process Controls - Excess Flow DevicesNo
Process Controls - Quench SystemNo
Process Controls - Purge SystemNo
Process Controls - NoneNo
Mitigation Systems - SprinklersNo
Mitigation Systems - DikesNo
Mitigation Systems - Fire WallsNo
Mitigation Systems - Blast WallsNo
Mitigation Systems - Deluge SystemsYes
Mitigation Systems - Water CurtainsNo
Mitigation Systems - EnclosureNo
Mitigation Systems - NeutralizationNo
Mitigation Systems - NoneNo
Monitoring Systems - Process AreaYes
Monitoring Systems - PerimeterNo
Monitoring Systems - NoneNo
Monitoring Systems - OtherLEL Monitors
Changes Since PHA - Reduced InventoryNo
Changes Since PHA - Increased InventoryNo
Changes Since PHA - Process ParametersNo
Changes Since PHA - Process ControlsNo
Changes Since PHA - Process DetectionNo
Changes Since PHA - Perimeter MonitoringNo
Changes Since PHA - Mitigation SystemsNo
Changes Since PHA - None RecommendedYes
Changes Since PHA - NoneNo
Procedure Review Date20170911
Training Review Date20161012
Type of Training - ClassroomNo
Type of Training - On the JobNo
Type of Training - OtherComputer Based Training
Competency Testing - Written TestsYes
Competency Testing - Oral TestsNo
Competency Testing - DemonstrationNo
Competency Testing - ObservationNo
Competency Testing - OtherOn the Job Training
Maintenance Review Date20150128
Maintenance Inspection Date20160630
Equipment TestedSRVs
Management of Change Most Recent Date20150205
Management of Change Review Date20180102
Pre-startup Review Date20150428
Compliance Audit Date20160525
Compliance Audit Change Completion Date20161028
Incident Investigation Datenull
Incident Invest. Change Completion Datenull
Participation Plan Review Date20150128
Hot Work Review Date20170630
Contractor Safety Review Date20170630
Contractor Safety Eval. Date20170630
Confidential Business InformationNo

Prevention Program 3 Chemicals facility_Prevention_Program_3_Chemicals help link help link (Facility #1 : KMCO, LLC, RMP submission #1 : 20180223, process #2 : Isobutylene, process NAICS code #1 : 32519, prev. program 3 #1, prev. program 3 chemical: all)
Process Chemical Record ID
1000106897

Prevention Program 3 Text facility_Prevention_Program_3_Text help link help link  
Prevention Program Description


Emergency Response Plan Info facility_Emergency_Response_Plan_Info help link help link  
Facility In Community PlanYes
Facility Own Response PlanYes
Specific Facility Response PlanYes
Inform. Procedures in Response PlanYes
Emergency Care in Response PlanYes
Plan Review Date20161019
Response Training Date20160518
Local Response AgencyGarner Environmental Services
Local Response Agency Phone2819301200
Subject To - OSHA EAPYes
Subject To - OSHA HAZWOPERYes
Subject To - CWAYes
Subject To - RCRAYes
Subject To - OPAYes
Subject To - State EPCRAYes


Search Criteria Used
RMP Facility ID100000118623

*END OF REPORT*