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Ineos Nitriles USA LLC.

Parent Companies:
Ineos Nitriles USA LLC.
EPA Facility ID:
100000062095
Other ID:
77979BPCHMTEXAS
Facility DUNS:
175894752
Parent Company DUNS:
0

Location:

Address:
13050 Texas Hwy 185
Port Lavaca, TX 77979
County:
CALHOUN
Lat / Long:
28.566, -96.839 (Get map)
Method:
Interpolation - Photo
Description:
Well
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Paul Wachtendorf
Phone:
(361) 552-8225
Address:
PO Box 659
Port Lavaca, TX 77979
Foreign Address:

Person responsible for RMP implementation:

Name:
Steven A. Stokely
Title:
PSM/Quality Coordinator

Emergency contact:

Name:
Steven A. Stokely
Title:
PSM/Quality Coordinator
Phone:
(361) 552-8443
24-hour phone:
(832) 564-7987
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(361) 552-8216
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calhoun County LEPC
Full-Time Equivalent Employees:
127
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
01284
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Jan. 16, 2018
Inspecting Agency:
USCG
Using Predictive Filing:
No

Processes:

Acrylonitrile Mfg
RMP ID:
1000085780
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Acrylonitrile [2-Propenenitrile]
107-13-1
61,000,000
No
Ammonia (anhydrous)
7664-41-7
23,000,000
No
Butane
106-97-8
133,000
No
Chlorine
7782-50-5
26,000
No
Hydrocyanic acid
74-90-8
1,700,000
No
Sulfur dioxide (anhydrous)
7446-09-5
75,000
No
Flammable Mixture
00-11-11
25,000,000
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
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
aeSolutions
Address:
2500 Commonwealth Drive
Suite 200
Greenville, SC 29615
Foreign Address:

Phone:
(864) 676-0600

Latest RMP Submission:

Date:
April 10, 2018
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000068358

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 Acrylonitrile Mfg)
CBI claimed:
No
Percent weight:
8.1
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
135.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • Dikes
  • splash wall added to top of concrete dike to prevent spillover
not considered:
  • 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 Acrylonitrile Mfg)
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:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • 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 Acrylonitrile Mfg)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
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 Acrylonitrile Mfg)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
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 Acrylonitrile Mfg)
CBI claimed:
No
Percent weight:
8.1
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • 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 Acrylonitrile Mfg)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
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 Acrylonitrile Mfg)
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 Acrylonitrile Mfg)
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

June 10, 2015 at 04:15
ID:
1000053258
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
1 hours
Chemicals involved:
  • Hydrocyanic acid
Release events:
Gas release
Weather conditions at time of event
Wind speed:
1.0 miles/h NW
Temperature:
70.00 ℉
Atmospheric stability:
D
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
1
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Maintenance activity/inactivity
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised training
  • Revised operating procedures
  • Revised emergency response plan
  • Changed process

7. Prevention: Program level 3

Acrylonitrile Mfg, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000072417
Safety Review Date
Oct. 6, 2017
PHA Update Date
Oct. 6, 2017
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Earthquake
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
July 31, 2017
Training Review Date
Oct. 19, 2017
Maintenance Review Date
Oct. 19, 2017
Maintenance Inspection Date
Feb. 2, 2018
Equipment Tested
Yes
Management of Change Most Recent Date
March 2, 2018
Management of Change Review Date
Jan. 11, 2017
Pre-startup Review Date
March 2, 2018
Compliance Audit Date
Oct. 19, 2017
Compliance Audit Change Completion Date
Oct. 19, 2018
Incident Investigation Date
Jan. 18, 2018
Incident Invest. Change Completion Date
Feb. 15, 2018
Participation Plan Review Date
March 16, 2017
Hot Work Review Date
Oct. 19, 2017
Contractor Safety Review Date
Feb. 10, 2017
Contractor Safety Eval. Date
Jan. 15, 2018

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:
Feb. 18, 2018
Local Response Agency:
Local Response Agency Phone:
(361) 553-4400
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

Ineos Green Lake RMP Executive Summary



1. Accidental Release Prevention and Emergency Response Policies

We at Ineos are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release.





2. The Stationary Source and the Regulated Substances Handled



The process used to produce Ineos Green Lake products contain quantities of flammable or listed hazardous chemicals which require application of Process Safety Management (PSM) as required in OSHA 29 CFR Part 1910 and the EPA Risk Management Program (RMP). INEOS management strongly supports Process Safety Management and the Risk Management Program and recognises it as a good business practice as well as a good approach to protecting workers and the public from industrial operation hazards. Ineos Green Lake applies the basic principles of Process Safety Management and the Risk Management Program.



Ineos has 8 EPA RMP regulated substances present at our facility above the threshold quantity. These substances include;

Acrylonitrile

Ammonia

Butane

Propylene

Propane

Chlorine

Sulfur Dioxide

Hydrogen Cyanide



Acrylonitrile is the end product of our process. Ammonia (anhydrous) and Propylene are utilized as raw materials in the production of Acrylonitrile. Propane is an impurity in the Propylene. Butane is utilized in catalyst activation. Chlorine is utilized in water purification. Sulfur Dioxide is utilized as an inhibitor. A by-product of the Acrylonitrile process is Hydrogen
Cyanide. Hydrogen Cyanide is processed into Acetone Cyanohydrine for shipment. Acetone Cyanohydrine is not a listed chemical by the EPA RMP.



3. Accidental Release Prevention Program

Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.



The following sections briefly describe the elements of our release prevention program that are in place at our stationary source.



Process Safety Information

Ineos maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.



Process Hazard Analysis

Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The HAZOP, What-If, and Checklist methodologies are used to carry out these analyses. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at 5 year intervals. Any findings related to the hazard analysis are addressed in a timely manner.



Operating Procedures

For the purposes of safely conducting activities within our covered processes, Ineos maintains written operating procedures. 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 with the processes.



Training

Ineos has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Re
fresher training is provided at least every 3 years and more frequently as needed.



Mechanical Integrity

Ineos carries out documented maintenance checks on process equipment to ensure proper functions. Process equipment examined by these checks include among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.



Management of Change

Written procedures are in place at Ineos to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.



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 Ineos . These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe start-up prior to placing equipment into operation.



Compliance Audits

Ineos conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.



Incident Investigation

Ineos promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the r
elease from reoccurring. All reports are retained for a minimum of 5 years.



Employee Participation

Ineos truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation to the RMP rule, in particular, information resulting from process hazard analyses.



Contractors

Ineos hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Ineos has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.





4. Five-year Accident History

On June 10, 2015, the site experienced a failure at a joint. This allowed hydrocyanic acid gas to be released. This resulted in a fatality onsite. The site has implemented changes to the process operations and procedures to prevent a similar incident from occurring at the facility again.





5. Emergency Response Plan

Ineos carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.



To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.



6. Planned
Changes to Improve Safety

The site added a requirement to conduct LOPA studies on all new and revalidated HAZOPs. The site initiated quarterly management audits that include elements of PSM/RMP. Additionally, the management team conducts a monthly housekeeping audit that incorporates PSM/RMP audit items (ie, fire proofing, insulating, painting, etc). The site has implemented a Behavior-Based Safety Program. The site shut down the catalyst plant in 2018 which reduced the amount of hazardous chemicals onsite.