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INEOS Nitriles USA LLC

Parent Companies:
EPA Facility ID:
100000073412
Other ID:
OHD042157644
Facility DUNS:
42157644

Location:

Address:
1900 Fort Amanda Road
Lima, OH 45804
County:
ALLEN
Lat / Long:
40.714, -84.132 (Get map)
Method:
Interpolation - Map
Description:
Center of Facility
Horizonal accuracy:
10 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
10

Owner/Operator:

Name:
INEOS Nitriles USA LLC
Phone:
(419) 226-1200
Address:
1900 Fort Amanda Road
Fort Amanda & Adgate Roads
Lima, OH 45804
Foreign Address:

Person responsible for RMP implementation:

Name:
Joseph F. Bianco
Title:
Safety, Health & Env Manager

Emergency contact:

Name:
Craig J. Hohenbrink
Title:
Sec. & Emerg. Response Coordinator
Phone:
(419) 226-1243
24-hour phone:
(419) 226-1375
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(419) 226-1200
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Allen County LEPC
Full-Time Equivalent Employees:
145
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0302020015
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
March 18, 2015
Inspecting Agency:
OSHA
Using Predictive Filing:
No

Processes:

Nitriles Manufacturing
RMP ID:
1000076946
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Acrylonitrile [2-Propenenitrile]
107-13-1
25,000,000
No
Ammonia (anhydrous)
7664-41-7
170,000
No
Formaldehyde (solution)
50-00-0
24,000
No
Hydrocyanic acid
74-90-8
1,500,000
No
Sulfur dioxide (anhydrous)
7446-09-5
20,000
No
Flammable Mixture
00-11-11
300,000
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

RMP Preparer:

Name:
Daniel J. Donovan
Address:
1900 Fort Amanda Road
Lima, OH 45804
Foreign Address:

Phone:
(419) 226-1206

Latest RMP Submission:

Date:
Dec. 16, 2016
Type:
Resubmission
Reason:
Process no longer covered (source has other processes that remain covered) (40 CFR 68.190(b)(7))
Registered:
Yes
RMP ID:
1000061498

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 Nitriles Manufacturing)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
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 Nitriles Manufacturing)
CBI claimed:
No
Percent weight:
100.0
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 Nitriles Manufacturing)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
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:
  • Water curtain
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Nitriles Manufacturing)
CBI claimed:
No
Percent weight:
37.0
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:
  • Water curtain
not considered:
  • Sprinkler systems
  • Deluge systems
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Nitriles Manufacturing)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by refrigeration
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:
  • Water curtain
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Nitriles Manufacturing)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
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:
  • Water curtain
not considered:
  • Sprinkler systems
  • Deluge systems
  • 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 Nitriles Manufacturing)
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 Nitriles Manufacturing)
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

Nitriles Manufacturing, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000064683
Safety Review Date
March 8, 2016, since latest RMP submission
PHA Update Date
Nov. 6, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
  • Water Curtain
Monitoring Systems
  • Process Area
Changes since PHA
  • Reduced Inventory
  • Process Parameters
  • Process Controls
  • Process Detection
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 15, 2016, since latest RMP submission
Training Review Date
April 30, 2015, since latest RMP submission
Maintenance Review Date
Jan. 15, 2016, since latest RMP submission
Maintenance Inspection Date
Feb. 10, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 16, 2016
Management of Change Review Date
March 10, 2014
Pre-startup Review Date
Oct. 9, 2012
Compliance Audit Date
Dec. 7, 2015
Compliance Audit Change Completion Date
Dec. 29, 2017
Incident Investigation Date
March 1, 2016
Incident Invest. Change Completion Date
April 1, 2016
Participation Plan Review Date
June 1, 2013
Hot Work Review Date
Nov. 15, 2015
Contractor Safety Review Date
Feb. 15, 2015, since latest RMP submission
Contractor Safety Eval. Date
Feb. 10, 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:
Nov. 12, 2015
Local Response Agency:
Local Response Agency Phone:
(419) 227-3535
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

Executive Summary

INEOS Nitriles USA LLC, Lima, Ohio

EPA Risk Management Plan - Executive Summary



ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES

INEOS is strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. Our plant adheres to process safety policies, guidelines, and best practices that have been developed based on company and industry experience over the years. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the incident.



DESCRIPTION AND REGULATED SUBSTANCES

The Ineos Nitriles USA LLC Plant is located at 1900 Ft. Amanda Road, Lima OH 45804 and is owned by Ineos LLC. Our facility is a major producer of industrial chemical products. The plant's primary product, acrylonitrile, is manufactured by combining ammonia, propylene and air. Acrylonitrile is a key ingredient in synthetic fibers, plastics and nitrile rubber. We have 6 regulated substances present at our facility. These substances include Acrylonitrile [2-Propenenitrile], Hydrocyanic Acid, Propylene [1-Propene], Ammonia (anhydrous), Formaldehyde (solution) and Sulfur Dioxide (anhydrous). Hydrocyanic Acid [HCN] is a co-product produced in the acrylonitrile process and is used as a raw material for making a variety of chemicals. Propylene [1-Propene] is used for as a raw material for the production of acrylonitrile. Ammonia (anhydrous) is used as a raw material to combine with propylene for the production of acrylonitrile. Formaldehyde (solution) is used in a purification step for acrylonitrile co-product production. Sulfur Dioxide (anhydrous) is used as an inhibitor for the purification and storage
of hydrocyanic acid.



HAZARD ASSESSMENTS

The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario have been performed for all listed flammable and toxic chemicals at the facility. To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. A technical team consisting of seven local area chemical manufacturers and the City of Lima selected the basis for the scenarios. The team findings were communicated in public meetings. Specific information on these releases is presented in detail in the plan.



PREVENTION PROGRAM

The following is a summary of the accident prevention program in place at the INEOS Nitriles USA LLC, Lima plant. 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 the release prevention program that is in place at our stationary source. Because processes at the plant that are regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary also addresses the OSHA PSM elements and describes the management system in place to implement the prevention program.



EMPLOYEE PARTICIPATION

The INEOS Nitriles USA LLC plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical information to participating as a member of a process hazard analysis (PHA) team and monthly LPSC (Lima Process Safety Committee) meetings. Employees have access to all information created, as part of the plant prevention program. Specific ways that employees can be involved in the prevention program are documented in the employee participation plan that addresses each preve
ntion program element. In addition the plant has a number of initiatives under way that address process safety and personal safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operation, maintenance, engineering, and plant management.



PROCESS SAFETY INFORMATION

The INEOS Nitriles USA LLC plant 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. Each process has documentation available showing the location of this information to help employees and visitors locate any necessary process safety Information.

Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in Safety Data Sheets (SDS's). This information is supplemented by documents that specifically address known exposure concerns and any known hazards associated with the inadvertent mixing of chemicals. For process areas, the plant has documented safety-related limits for specific process parameters (i.e. temperature, level, composition). The plant assures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (i.e. automated shutdown systems). In addition, information is available summarizing the consequences of deviation from these limits and the corrective actions to take.

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



PROCESS HAZARD ANALYSIS

The INEOS Nitriles USA LLC plant has a comprehensive program 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.

This plant primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. 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. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. Any findings related to the hazard analysis are addressed in a timely manner. The LOPA (Layer Of Protection Analysis) method is employed during the PHA to evaluate the adequacy of credited protection layers.

To help ensure that the process controls and or process hazards do not eventually deviate significantly from the original design safety features, this plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years as long as the process exists. The recommendations from these updates are also forwarded to management. Final resolution of the recommendations is tracked, documented, and retained.



OPERATING PROCEDURES

The INEOS Nitriles USA LLC plant maintains written procedures that address various modes of process o
perations, 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 are developed/revised by experienced operators as needed and provide a basis for consistent training of new operators. The procedures are periodically reviewed and annually certified as current and accurate. The procedures are revised as necessary to reflect changes made through the management of change process.

Safe operating limits are also maintained to provide guidance on how to respond to upper or lower exceedences for specific process or equipment parameters. This information, along with the written operating procedures, is readily available to the process operators and other personnel to use as necessary to safely perform their job tasks.

The INEOS Nitriles USA LLC plant has long-standing 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 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, and (4) 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.



TRAINING

To complement the written procedures for process operations, the INEOS Nitriles USA LLC plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in chemical plant operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After the new operator demonstrates (i.e. throug
h tests, skills demonstration, etc.) having 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 three years. All of this training is documented, including the means used to verify that the operator understood the training.



CONTRACTORS

The INEOS Nitriles USA LLC plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the plant 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 plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to work starting. In addition, the INEOS plant evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.



PRE-STARTUP SAFETY REVIEW (PSSR)

The INEOS Nitriles USA LLC plant 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, equipment, procedures, and personnel are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check t
o make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.



MECHANICAL INTEGRITY

The INEOS Nitriles USA LLC plant has well-established 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 written procedures and plans, (3) performing Inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination these activities form a system that maintains the mechanical integrity of the process equipment.

Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. 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 (i.e. adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The plant incorporates quality assurance measures i
nto equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.



HOT WORK PERMIT

The INEOS Nitriles USA LLC plant has a hot work permit program which details those areas which require a permit and those areas for which a permit is not required. A permit is required in process areas for all cutting, welding, spark producing equipment, etc. except in designated areas. The procedure includes accountability and responsibility for authorizing and issuing the hot work permit, display of the permit at the site of the hot work until the work is completed, site inspection, designation of appropriate precautions to be taken with the hot work, and assignment of a fire watch where appropriate.



MANAGEMENT OF CHANGE

The INEOS Nitriles USA LLC plant has a comprehensive system to manage changes to processes as well as organizations within the facility. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before 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 incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. The system ensures that all documentation is updated and training completed prior to the commissioning of the change.



INCIDENT INVESTIGATION

The INEOS Nitriles USA LLC plant promptly investigates all incidents that resulted in, or reasonably could have resulted in a fire/explosion, toxic gas release, major property damage, environmental loss, or persona
l 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 management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years, so that the reports can be reviewed during future PHAs and PHA revalidations.



COMPLIANCE AUDITS

To help ensure that the accident prevention program is functioning properly, the INEOS Nitriles USA LLC plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years, with internal audits conducted on an annual bases: Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete.



FIVE-YEAR ACCIDENT HISTORY

The INEOS Nitriles USA LLC facility in Lima, Ohio (also known as Lima Chemicals) has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period that has affected the community.

Over the past five years there have been other incidents where chemical releases have occurred but did not affect the local community. These are documented in our incident reporting system along with notification given to the
proper governmental agencies. Information on these incidents is available at the facility from the SHE Manager (419-226-1200).



CHEMICAL SPECIFIC PREVENTION STEPS

The processes at the INEOS Nitriles USA LLC plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to all Program 3 EPA RMP covered processes at this facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.

In addition to the accident prevention program activities, the INEOS Nitriles USA LLC plant 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

1. Hydrocarbon detectors with alarm.



Release Containment/Control

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

2. Scrubber to neutralize chemical releases.

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

4. Automated shutdown systems for specific process parameters (i.e. high level, high temperature)

5. Vessel to permit partial removal of the process inventory in the event of a process problem (i.e. dump tank) or a means of safely removing inventory (i.e. thermo oxidizer)

6. Curbing or diking to contain liquid releases

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

8. Atmospheric relief devices



Release Mitigation

1. Fire suppression and extinguishing systems

2. Deluge systems for specific equipment

3. Trained emergency response personnel

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

5. Mobile firefighting equipment



EMERGENCY RESPONSE PROGRAM INFORMATION


The INEOS Nitriles USA LLC plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as Instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to plant processes or other plant facilities. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes.

The overall emergency response program for the plant is coordinated with the Allen County Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., Shawnee Fire Department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the plant conducts periodic emergency drills that involve the LEPC and emerg
ency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the plant.



PLANNED CHANGES TO IMPROVE SAFETY

The plant resolves all findings from PHAs, some of which result in modifications to the process.