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ANGUS CHEMICAL COMPANY

Parent Companies:
EPA Facility ID:
100000050874
Other ID:
LAD 020597597
Facility DUNS:
34601096

Location:

Address:
P. O. BOX 1325
Sterlington, LA 71280
County:
OUACHITA
Lat / Long:
32.691, -92.083 (Get map)
Method:
Interpolation - Satellite
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
ANGUS CHEMICAL COMPANY
Phone:
(318) 665-0100
Address:
P. O. BOX 1325
350 LA Highway 2
Sterlington, LA 71280 -1325
Foreign Address:

Person responsible for RMP implementation:

Name:
Tina W. Murray
Title:
Site Leader

Emergency contact:

Name:
Brian Moore
Title:
EH&S Manager
Phone:
(318) 665-5245
24-hour phone:
(318) 243-6312
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(318) 665-0010
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Ouachita Parish LEPC
Full-Time Equivalent Employees:
170
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2011-V10
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
May 10, 2010
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

56520
RMP ID:
1000078414
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Sulfur dioxide (anhydrous)
7446-09-5
106,000
No
Formaldehyde (solution)
50-00-0
350,000
No
Ammonia (anhydrous)
7664-41-7
4,250
No
Propane
74-98-6
685,000
No
Trimethylamine [Methanamine, N,N-dimethyl-]
75-50-3
67,800
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Matt Simonton
Address:
350 LA Highway 2
P. O. Box 1325
Sterlington, LA 71280
Foreign Address:

Phone:
(318) 665-5115

Latest RMP Submission:

Date:
March 21, 2017
Type:
Resubmission
Reason:
Process no longer covered (source has other processes that remain covered) (40 CFR 68.190(b)(7))
Registered:
Yes
RMP ID:
1000062505

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in 56520)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in 56520)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in 56520)
CBI claimed:
No
Percent weight:
50.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in 56520)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in 56520)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in 56520)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Deluge systems
  • Water curtain
  • Excess flow valve
Public OCA Chemical (in 56520)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

56520, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000065877
Safety Review Date
Aug. 24, 2016, since latest RMP submission
PHA Update Date
Sept. 28, 2016, since latest RMP submission
PHA Techniques
  • Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Dikes
  • Water Curtain
  • Enclosure
Monitoring Systems
  • None
Changes since PHA
  • Increased Inventory
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Dec. 7, 2016, since latest RMP submission
Training Review Date
Aug. 25, 2016, since latest RMP submission
Maintenance Review Date
Nov. 12, 2016, since latest RMP submission
Maintenance Inspection Date
Oct. 11, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 13, 2016
Management of Change Review Date
Aug. 27, 2014
Pre-startup Review Date
Oct. 24, 2016
Compliance Audit Date
Jan. 20, 2016
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Dec. 2, 2014
Hot Work Review Date
March 29, 2016
Contractor Safety Review Date
Jan. 9, 2015, since latest RMP submission
Contractor Safety Eval. Date
June 30, 2016, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
June 23, 2016
Local Response Agency:
Local Response Agency Phone:
(318) 322-2641
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

ANGUS Chemical Company, Sterlington, LA

Risk Management Program

Executive Summary

Revision and Update, March 6, 2017



2694 LDEQ Facility ID Number

1000 0005 0874 USEPA Facility ID Number



Update: Chlorine deleted. The use of chlorine as a cooling tower disinfectant has been discontinued, and all chlorine cylinders were removed from the site on February 1, 2017. An alternative disinfectant product is being used.





ANGUS Chemical Company, Sterlington, LA

Risk Management Program

Executive Summary

Revision and Update, December 15,2016



2694 LDEQ Facility ID Number

1000 0005 0874 USEPA Facility ID Number



1.0 The Stationary Source and Regulated Substances Handled



The ANGUS Chemical Company (ANGUS) owns and operates an organic chemical manufacturing facility (NAICS 325199) at the Town of Sterlington, Louisiana. ANGUS is located in the northeast corner of Ouachita Parish, near the Town of Sterlington, off of Louisiana Highway 2 on the east bank of the Ouachita River. Sterlington is a small community of approximately 1,900 inhabitants within the city limits.



The ANGUS facility operates 24 hours per day, seven days per week, and it employs approximately 170 full-time employees. It consists of six separate operating units: a nitroparaffins unit, a nitric acid unit, a nitroparaffins derivatives unit, a crystallization unit, an isopropyl hydroxylamine (IHPA) unit and a hydrogen generation unit. It also includes a shipping facility that supports the process unit's needs regarding both incoming raw materials and outgoing products. There is also a pilot plant that provides research and development support to the manufacturing units.



ANGUS is subject to OSHA Process Safety Management (PSM) regulations at 29 CFR 1910.119. Thus, the required Process Hazard Analysis (PHA) of covered processes has been performed and revalidated in compliance with the applicable regulations.



ANGUS is also subject to the US EPA's chemical accident prevent
ion regulations at 40 CFR Part 68, by virtue of storing, processing and/or handling on site chemical substances, above their threshold quantities, as listed at 40 CFR 68.130. These regulated substances include four toxics (sulfur dioxide, formaldehyde, chlorine and ammonia) and two flammables (propane and trimethylamine). ANGUS also manufactures a detonable material, nitromethane. Although not listed as a regulated substance, ANGUS has chosen to report Nitromethane under the General Duty Clause. This material, and the unit where it is produced, is also managed under the PSM program.



2.0 Accidental Chemical Release Prevention and emergency Response Policies



The ANGUS Chemical Company is strongly committed to maintaining high standards of employee, public, and environmental safety and protection. The prevention of accidental chemical releases is an integral and important part of the ANGUS policies, and it has established a comprehensive accidental release prevention program that covers such areas as process design, system installations, operating procedures, maintenance practices, and employee training, as they apply to each one of its operating units and support facilities at the Sterlington location.



ANGUS ensures the safety of plant operations through the use of process safety management (PSM) techniques, including but not limited to:



* Periodic process hazard analyses (PHA's) of production, utilities, and shipping operations;

* Strict adherence to Management of Change procedures;

* Strict enforcement of the written standard operating procedures (SOP's);

* Comprehensive and periodic (refresher) training of plant personnel.

* Mechanical integrity programs utilizing predictive and preventive maintenance principles.

* A comprehensive mandatory contractor safety program for contractors.

* An active employee participation program.

* Incidents, including near-misses, are investigated to determine root cause and contributing factors.



3
.0 Emergency Response Strategy



ANGUS takes a proactive approach toward the prevention of incidents, including accidental chemical releases. As an important element of this approach, ANGUS has developed and implemented a detailed emergency response plan (ERP) that makes it possible to generate a rational, practical, and timely response if an incident does occur. ANGUS believes that a quick and appropriate response is an important element in the mitigation and minimization of any potential adverse effects on the facility, its personnel, and the local community.



Other elements in ANGUS' strategy for managing and mitigating emergencies include:



* The incorporation of emergency response actions into the facility's standard operating procedures.

* The procurement of necessary personal protective equipment (PPE) and emergency response equipment and supplies.

* The development and implementation of an Incident Command System to assure a quick and rational response to emergencies.

* Ensuring that operating personnel have been thoroughly educated and trained in the appropriate mitigating, corrective, and response actions that must be taken in the event of an accidental release.



The facility's contingency capabilities and incident preparedness are tested at least four times per year to verify the operational readiness of personnel to respond to plant emergencies.



4.0 Offsite Consequence Analysis (OCA)



In compliance with the requirements of 40 CFR 68.165, PSRG Inc. (Consultancy firm, Houston based) performed a complete Offsite Consequence Analysis (OCA) for each of the regulated substances present on site to assess the potential consequences of hypothetical major chemical releases. Worst Release Cases and Alternative Release Cases (WRC and ARC, respectively), as defined in the regulations, were developed for each of the covered toxic and flammable substances, plus the detonable substance. The WRC's showing the largest potential offsite effects wer
e selected (one toxic, one flammable, and one detonable) for entry into the RMP submittal document. Likewise, the ARC for each of the covered toxics, and an ARS to represent covered flammables, was included. In addition an ARC for nitromethane was included, even though it is not listed in 40 CFR 68.130. These are briefly mentioned below but, per the 2004 Amendments to the RMP regulations, no further OCA details or discussions are provided.



4.1 Worst Case Scenarios (WCS's)



Worst-case scenarios were developed, modeled, and evaluated to identify the one with the greatest distance to the end point for the hypothetical release of one toxic (sulfur dioxide), one flammable (propane) and one detonable (nitromethane) substance. The results of the toxic and flammable scenarios are outlined within the body of the RPM submittal. The WCS for nitromethane is maintained in the ANGUS files.



4.2 Alternative Release Scenarios (ARS's)



Similarly, alternative release scenarios were developed, modeled, and evaluated for each of the toxics (sulfur dioxide, ammonia, chlorine, and formaldehyde) and one flammable (propane), as called for in the regulation. One ARS was also prepared for the detonable substance. The results are summarized in the appropriate section of this RMP submittal. The ARS for the detonable substance is maintained in the ANGUS files.



5.0 General Accidental Release Prevention Program and Chemical-Specific Prevention Steps.



ANGUS has taken the necessary steps to comply with the accidental release prevention requirements at 40 CFR Part 68 of the USEPA. This facility conforms to industry-recognized good engineering practices in design, construction, and maintenance.



Processes are provided with applicable process controls and monitoring systems, including but not limited to, high and low-range sensors and alarms on critical process parameters (such as liquid level, flow, pressure, and temperature), with interlocking logic and redundancy where a
ppropriate.



The following sections briefly describe the elements of the release prevention program that are in place at the ANGUS facility.



5.1 Process Safety Information



The ANGUS facility maintains a record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with covered processes. The documentation kept on site and readily available to all personnel includes, but is not limited to, Material Safety Data Sheets (MSDS's) for covered substances and chemicals; specification sheets, drawings, and performance information for equipment, tanks, pumps and other covered equipment and operating parameters for covered processes.



5.2 Process Hazard Analysis



Every covered process at ANGUS is subject to a periodic process safety analysis (PSA). The facility conducts comprehensive studies to ensure that hazards associated with the processes are identified and controlled efficiently. The methodologies used to carry out these analyses may include What If/Checklist (combined), hazard and operability study (HAZOP), and Reactive Chemicals/Process Hazards Analysis. These studies are undertaken by qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of no more than five years. Findings and action items arising from the process hazard analysis are addressed in a timely manner.



5.3 Standard Operating Procedures



For the purposes of safely conducting activities within our covered processes, ANGUS maintains written standard operating procedures (SOP's). These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Before an employee starts to work on a covered job or assignment, they are provided
with the necessary training (both class-room and on-the-job, as necessary) to ensure that they are capable of understanding the requirements of the job and are able to execute tasks safely and efficiently. As an integral part of training, the employee must demonstrate understanding these procedures before actually starting to work. Refresher training is also provided periodically.



5.4 Technical Support Staffing:



ANGUS maintains a staff of qualified personnel in its engineering, production, operations, maintenance, and other support areas, to ensure that the plant operates in a safe and productive manner. Staffing is based on the plant?s safety, production, and regulatory needs, and personnel are selected on their technical knowledge, experience and ability to operate and support the manufacturing processes. Chemical engineers make up the core of the facility's technical staff to provide technical assistance to the plant's production, administrative, and technical functions. Mechanical engineers and industrial technologists are responsible for plant maintenance programs, including mechanical integrity. Trained personnel are involved in the oversight and direction of safety programs and issues related to personal safety, property protection, and process safety management.



5.5 Training:



ANGUS provides an extensive training program to educate plant personnel. The training program is an on-going key element of the plant's safety program, and personnel undergo initial training before starting to work, plus periodic refresher training. Training sessions are planned and scheduled, and records of training are kept, by the facility training coordinator.



The Training coordinator compiles and maintains training requirements for each job or role, from which a training curriculum is developed for each position. These requirements are reviewed annually and revised and updated as necessary.



5.6 Fire Prevention Program



ANGUS maintains procedures a
nd controls to prevent fires in the Sterlington facility. These controls are specified and discussed in the plant's procedures and safety rules, and both employees and contractors are expected to comply with and adhere to these requirements. These controls include restrictions on the use of igniters, restrictions on the use of vehicles within certain areas of the plant, established hot work permit procedures, spark and flame detection systems, and electrical classification program requirements.



5.7 Process Safety Management (PSM) System



ANGUS has developed and implemented a comprehensive process safety management system. ANGUS' PSM program includes functioning procedures and activities that address the PSM elements (such as process safety information, PHA's, reactive chemical reviews, operating procedures, training, and mechanical integrity), as described in 29 CFR Part 1910.119 and 40 CFR Part 68.67.



5.8 Mechanical Integrity



ANGUS carries out documented periodic maintenance checks on process equipment to ensure proper operations. ANGUS' Mechanical Integrity (MI) program utilizes predictive and preventive maintenance principles to ensure that operating equipment is maintained properly in good operating condition. Process equipment that undergoes MI checks includes, pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, instrumentation and controls, and process pumps. Maintenance operations are only performed by well-trained and qualified personnel with experience in maintenance practices. Furthermore, these personnel are provided specialized training as needed. Equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.



5.9 Management of Change



Proposed process changes, modifications and improvements undergo an evaluation through the management-of-change process. Written procedures are in place at ANGUS to manage changes in process chemicals, technolo
gy, equipment, and procedures. Process operators, maintenance personnel, or any other employee whose job tasks are affected by a modification in process conditions or system configuration are promptly made aware of the change, and they are provided the necessary training to understand the modification and its effect on their jobs and written operating procedures.



5.10 Pre-startup Reviews



Pre-start up safety reviews related to new processes, and to modifications in established processes, are conducted as a regular practice at ANGUS. These reviews are conducted to confirm that construction, equipment, operating procedures, training, and maintenance procedures are suitable for safe startup prior to placing equipment into operation.



5.11 Compliance Audits



The ANGUS facility conducts audits on a regular basis to determine whether the provisions set out under the RMP rules are being implemented and complied with. These audits are carried out at least every three years, and corrective actions required as a result of the audits are addressed promptly.



5.12 Incident Investigation



ANGUS promptly investigates incidents, including near-misses that occur within the facility. Investigations are undertaken to identify the root cause and contributing factors and to identify corrective actions that will help prevent the incident from reoccurring. Incidents and the investigation findings are discussed with personnel during safety meetings. The incident investigation reports are made available to employees, and they are retained on file for a minimum of five years.



5.13 Employee Participation



ANGUS believes that process safety management and accident prevention require a team effort. Company employees are strongly encouraged to express their views concerning accident prevention and to recommend improvements. In addition, our employees have access to information created as part of the facility's implementation of the RMP and PSM rules, including informat
ion resulting from process hazard analyses.



5.14 Contractors



ANGUS hires contractors to conduct specialized maintenance, to carry out construction work, and to perform various other activities. Prior to selecting a contractor, a thorough evaluation of safety performance of potential contractors is conducted. ANGUS has a strict policy of informing the contractors of known potential hazards that may exist in the contractor's work area and in neighboring units and processes. Contractors are also informed about the plant alarms and the procedures for emergency response. Contractors are required to inform ANGUS of any hazards or hazardous substances that they may bring into the site as part of their work.





6.0 Five Year Accident History



Time Period Covered: January 2012 through date of submission



40 CFR 68.42 defines a "reportable" incident as an accidental release from covered processes that results in deaths, injuries, or significant property damage or environmental damage, either on or off-site, or that requires evacuations or sheltering in place in the nearby communities.



There were no "reportable" incidents as defined above at the ANGUS Sterlington facility during this reporting period.



7.0 Emergency Response Plan (ERP)



ANGUS has developed and maintains an emergency response plan (ERP) that provides for a quick response to plant emergencies. The ERP is not limited to chemical releases, but it also includes provisions to respond to emergencies that may occur within the plant boundaries. The ERP provides information about the appropriate response to specific hazardous materials present on the plant site. It also delineates the procedures to be followed for notification of personnel for emergencies such as fires, explosions, and chemical releases. It also contains contingencies for sheltering-in-place, evacuation, points of assembly, and personnel accounting.



In addition to the plant-wide, overall ERP, each operating unit has dev
eloped specific steps and actions to take in the event of an emergency within each unit. Such actions include, but are not limited to, the safe shut down of process equipment and mitigating measures to take in the event of an incident.



Plant personnel are trained on the ERP and what actions they are to take in the event of an emergency. Plant operators are trained on specific operating response actions within their respective areas, which are addressed in the plant's standard operating procedures (SOP's) as well. In addition, plant personnel are trained to recognize hazardous materials incidents. Maintenance and operations personnel are trained to respond to chemical releases and incipient stage fires.



The ERP is tested at least four times per year, and community response agencies are invited to participate in at least one emergency drill per calendar year. During such drills, incident command center and internal/external communications are emphasized. To improve communications between the plant's emergency response personnel and the Ouachita Parish Fire Department, the latter has been provided with an ANGUS plant 2-way radio. This allows for immediate and direct communications between the plant's incident commander and the responding fire department, so that the responding unit can be informed about the nature, magnitude, and location of the emergency prior to entry into the plant site.



ANGUS' ERP is coordinated with several local outside agencies, including the Ouachita Parish Fire Department, the Ouachita Parish Office of Homeland Security & Emergency Preparedness, the Ouachita Parish Sheriff's Department, the Louisiana State Police, and the Sterlington Police Department. Medical protocols have been developed and approved by the plant's medical consultant, for the emergency treatment of individuals affected during an emergency. Area hospitals have been briefed on the plant's emergency plan and medical protocols, and local hospitals have agreed t
o receive individuals from the ANGUS facility in the event of an emergency.



The ANGUS facility is provided with a plant emergency alert system for emergency conditions within the plant boundaries. It also has a feature that allows external notification to the Sterlington Town Hall, the Sterlington Hospital, and Sterlington Middle School. The emergency alert system is tested periodically, along with the weekly plant alarm system test. In addition, when an actual emergency occurs, telephone contact is made with the businesses and other locations in close proximity to the ANGUS facility.



8.0 Planned Changes To Improve Safety



ANGUS is committed to maintaining and operating its facilities in a safe manner, and every effort is made to provide the necessary resources to ensure that processes are well designed, engineered, constructed, maintained, and operated.



Safety and operating procedures undergo periodic reviews, and the technical department is always in search of improved and safer ways to operate the facility's processes.