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Firestone Polymers, LLC

Parent Companies:
Bridgestone Procurement Holdings USA
EPA Facility ID:
100000073822
Other ID:
Facility DUNS:
16136237
Parent Company DUNS:
80408959

Location:

Address:
1801 Hwy. 108 South
Sulphur, LA 70665
County:
CALCASIEU
Lat / Long:
30.184, -93.333 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Firestone Polymers, LLC
Phone:
(337) 882-1211
Address:
PO Box 1361
Lake Charles, LA 70602
Foreign Address:

Person responsible for RMP implementation:

Name:
Greg Defrates
Title:
Director of CSR

Emergency contact:

Name:
Billy Phillips
Title:
Manager of Safety and Health
Phone:
(337) 882-5374
24-hour phone:
(409) 466-1941
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 882-1211
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
300
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0520-00007-V5
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
April 22, 2016
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

Synthetic Rubber Manufact
RMP ID:
1000077245
CBI claimed:
No
Program Level:
3
NAICS:
Synthetic Rubber Manufacturing (325212)
Chemical name
CAS#
Quantity (lbs.)
CBI
1,3-Butadiene
106-99-0
2,100,000
No
Boron trifluoride [Borane, trifluoro-]
7637-07-2
30,000
No
2-Butene-cis
590-18-1
71,000
No
2-Butene-trans [2-Butene, (E)]
624-64-6
44,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
ERM
Address:
3838 North Causeway Blvd.
Suite 3000
Metairie, LA 70002
Foreign Address:

Phone:
(504) 831-6700

Latest RMP Submission:

Date:
Jan. 5, 2017
Type:
Resubmission
Reason:
Newly regulated substance above TQ in already covered process (40 CFR 68.190(b)(3))
Registered:
Yes
RMP ID:
1000061677

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 Synthetic Rubber Manufact)
CBI claimed:
No
Percent weight:
Physical state:
Gas
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 Synthetic Rubber Manufact)
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:
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 Synthetic Rubber Manufact)
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 Synthetic Rubber Manufact)
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

Synthetic Rubber Manufact, Synthetic Rubber Manufacturing (325212)
Prevention Program ID:
1000064991
Safety Review Date
Nov. 14, 2016, since latest RMP submission
PHA Update Date
Oct. 31, 2016, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Aug. 3, 2016, since latest RMP submission
Training Review Date
Nov. 25, 2014, since latest RMP submission
Maintenance Review Date
Nov. 1, 2016, since latest RMP submission
Maintenance Inspection Date
Oct. 4, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 17, 2016
Management of Change Review Date
Aug. 31, 2016
Pre-startup Review Date
Nov. 16, 2016
Compliance Audit Date
Sept. 1, 2016
Compliance Audit Change Completion Date
Dec. 31, 2017
Incident Investigation Date
Dec. 28, 2015
Incident Invest. Change Completion Date
June 20, 2016
Participation Plan Review Date
Nov. 10, 2016
Hot Work Review Date
July 27, 2016
Contractor Safety Review Date
Nov. 21, 2016, since latest RMP submission
Contractor Safety Eval. Date
Nov. 15, 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:
Sept. 15, 2016
Local Response Agency:
Local Response Agency Phone:
(337) 437-3512
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

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES



The Lake Charles Plant is committed to operating the plant in a manner that is safe for its workers, the public and the environment. As part of this commitment, Firestone has established a system to help ensure safe operation of the processes of the Lake Charles Plant. One component of this system is a risk management program (RMP) that helps manage the risks at the plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirement Risk Management Program (the RMP rule) and OSHA's 29 CFR part 1910.119 (the PSM rule). This document is intended to satisfy the RMP Plan requirement of the RMP rule and to provide interested parties with a description of the risk management program at the Plant.



Firestone is an active participant in the community. The Lake Charles Plant is voluntarily involved in the Calcasieu Community Advisory Panel (CAP). The purpose of this group is to share information about plant operations with members of the community and to discuss their concerns. The Lake Charles Plant is also an active member of the Lake Area Industry/McNeese Engineering Partnership (LAI/MEP), the Safety Council of Southwest Louisiana, Mutual Aid of Southwest Louisiana, Calcasieu Area Emergency Response (CAER), and the Calcasieu Parish Emergency Planning Committee.



Over the past five years the Lake Charles Plant has received several corporate pollution prevention awards and Bridgestone/Firestone corporate safety awards for 15%, 30% and 35% improvements in safety performance.



Firestone is committed to the safety of workers, the public and the preservation of the environment through the prevention of accidental releases of hazardous substances. The Lake Charles Plant implements reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel are prepared to re
spond quickly and effectively.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES



The Lake Charles Plant is located at 1801 Highway 108 South near Sulphur, Louisiana. The Plant produces a wide range of synthetic rubber products manufactured by the solution polymerization process.

Three flammable substances and one toxic substance are covered under the Accidental Release Program (ARP). The three flammable substances are 1,3-butadiene, 2-butene-cis, and 2-butene-trans. The toxic substance is boron trifluoride.



WORST AND ALTERNATIVE CASE SCENARIO FLAMMABLE



Both the flammable worst-case and alternative release scenarios at the site involve 1,3-butadiene. A worst-case release of 1,154,673 pounds of 1,3-butadiene from tank F-133 results in a distance to endpoint of 0.8 miles. The alternative release scenario involves a release of 1,3-butadiene through piping failure in the tank farm area. A 3/4 inch piping failure is assumed to have occurred and it is assumed that the flow would continue for ten (10) minutes in duration. A total of 3,840 pounds of 1,3-butadiene is determined to be released for the 10 minute duration before the release is isolated. The alternative release scenario results in a distance to endpoint of 0.08 miles. The USEPA's RMP*Comp modeling software was used to determine the distance to endpoints for both flammable release scenarios.



WORST AND ALTERNATIVE CASE SCENARIO TOXIC



Both the toxic worst-case and alternative release scenarios at the site involve boron trifluoride. A worst-case release of 30,000 pounds of boron trifluoride is determined to occur from 16 cylinders that are manifolded together on two truck trailers. The release results in an endpoint of 7.4 miles. The alternative release scenario involves a release from a single cylinder, which contains 1,875 pounds of boron trifluoride. The entire contents of the cylinder are assumed to be released over a ten minute span (release rate of 187.5 lbs./min.). The al
ternative release scenario results in a distance to endpoint of 0.7 miles. The USEPA's RMP*Comp modeling software was used to determine the distance to endpoints for both toxic release scenarios.





MANAGEMENT SYSTEM FOR PROCESS SAFETY/RISK MANAGEMENT



The following is a summary of the accident prevention program in place at the Lake Charles Plant. The processes at the plant that are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard. Therefore, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. The Prevention Program questions found in section 7 of the Risk Management Plan Data Elements submittal have been answered assuming that they apply to OSHA 29 CFR Part 1910.119.



Employee Participation



Open communications are encouraged between supervisors and employees regarding all safety and health issues. There are various levels of responsibility taken by different employees, including the facility manager, safety coordinator, department managers, first-line supervisors, and all employees.



The Plant actively seeks employee involvement in the development and conduct of all accident prevention activities through the appropriate existing safety programs. Accident prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments, or suggestions.



Process Safety Information (PSI)



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



Chemical-specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDSs). Other chemical-specific information includes maximum intended inventories of chemicals, information on inadvertent chemical mixtures that could occur and their associated hazards. The Plant also maintains numerous technical documents that provide information about the design and construction of process equipment, which include information on materials of construction, piping/instrumentation diagrams, relief systems design, as well as others. This information is provided to maintain safe operations at the facility.



This information, 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. PSI is updated through the Management of Change Program, as are the operating specifications. The entire system is audited every three years.



Process Hazard Analysis (PHA)



The 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.



The Plant uses some or all of the hazard evaluation techniques outlined in the American Institute of Chemical Engineers publication Guidelines for Hazard Evaluation Procedures to perform these evaluations. The analyses are conducted using a team with operating and maintenance experience as well as engineering expertise. PHA team members include employees with expertise in the following areas: technical, staff engineering, operations, maintenance, safety, and PHA methodology. This team ident
ifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes recommendations for additional prevention and/or mitigation measures when the team believes such measures are necessary.



The PHA team findings are forwarded to plant management for resolution. The final resolution of each finding is documented and retained. All PHA team recommendations are tracked until they are completed.



To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the PHA team updates and revalidates each PHA every five years. These periodic reviews are conducted at this frequency until the process is no longer operating.



Operating Procedures



The Plant maintains written procedures that address various modes of process operations, such as (1) initial startup, (2) normal startup, (3) normal operation, (4) normal shutdown, (5) emergency operations, (6) emergency shutdown, (7) temporary operation, (8) preparation for maintenance procedure, (9) quality assurance, and, (10) inadvertent mixing.



The specific instructions include the applicable safety precautions and appropriate information on safety implications.



These procedures provide guidance for experienced operators and a basis for consistent training of new operators.



Operating procedures are reviewed and updated annually by the Manufacturing Department to verify current status. The review is to assure that the procedures reflect current operating practice, include changes from process technology changes, chemical changes, equipment changes, and changes to facilities. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process.



Training



In addition to training on operating procedures, the Plant has a comprehensive training program for all employees involved in operating the proc
ess.



New employees receive immediate training in the following areas of the process: overview of process; process fundamentals; and process description. Training includes emphasis on specific safety and health hazards, emergency operations, and safe work practices applicable to the job. This training must be passed through oral or written testing and the employee must demonstrate and verify that they understand the required operating procedures before they are allowed to operate the unit alone.



In addition, all operators receive refresher training at least every three years. This refresher training on the operating procedures is to ensure that their skills and knowledge are maintained at an acceptable level. Additionally, more frequent training will occur upon the request of the employee. The appropriate frequency of training is decided by management in consultation with the employees involved in operating the particular process. All of this training is documented for each operator including the means used to verify that the operator understood the training.



Contractors



The Plant uses contractors for selected maintenance, construction, and engineering service support activities. The Lake Charles Plant evaluates contractor safety programs and performance during the selection of a contractor. Because some contractors work on or near process equipment, the Lake Charles Plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have appropriate knowledge and skills, (3) are aware of the hazards of their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site specific 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 their beginning work.



Contract personnel complete prequalification forms annually to fulfill their safety obligations.



Pre-startup Safety Review (PSSR)



The Plant conducts a PSSR on any new plant modification that requires a change in 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 procedure also provides a final check that construction is in accordance with the design specifications and that all supporting systems are operationally ready.



The 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 purpose of the Mechanical Integrity Program is to assure the continued integrity of process equipment in order to prevent or minimize employee exposure to the uncontrolled release of toxic, flammable or explosive chemicals, and the attendant consequences of such a release. The Plant has well established practices and procedures for maintaining process equipment.



The basic aspects of this program include (1) training, (2) developing written procedures, (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.



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 jobs in a safe manner.



Another integral part of the mechanical integrity program is quality assurance. The Plant incorporates quality assurance measures into equipment purchases, instal
lations, repairs and replacement. 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.



Safe Work Practices



The Plant 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/tag out procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous and toxic substances before process piping and 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



The Plant has a comprehensive system of written procedures to manage changes to all covered processes. The purpose of this system is to ensure that process changes maintain or enhance the safety, environmental, and technical integrity originally designed into the Plant. This system requires that changes to items such as chemicals, process equipment, technology (including process-operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented.



Prior to changes being made, they 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, including contractor employees, are notified and provided any necessary training
on the change.



Incident Investigation



The 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 personal injury. The goal of each investigation is to gather the facts, determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident.



The investigation team documents its findings in a report. The report includes dates of the incident and investigation, description of incident, factors contributing to the incident. The team develops recommendations to prevent a recurrence, and forwards this report to the plant management team for resolution. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHA's and PHA revalidations.



Compliance Audit



To help ensure that the accident prevention program is functioning properly, the 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 three years. The audit includes an evaluation of the design and effectiveness of the PSM system.



The audit team develops findings in a report that is forwarded to plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked and documented until they are complete. The final resolution of each finding is documented, and the two most recent compliance audit reports are retained.



CHEMICAL SPECIFIC PREVENTION STEPS



The processes at the Plant have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to the RMP-covered process at the Lake Charles Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caus
ed by equipment failures and human errors. In addition to the accident prevention program activities the Plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a

release, and, (3) reduce (mitigate) the consequences of a release. The following types of safety features are used in various processes:



Release Detection



1. Sensors with audible alarms are located to detect and warn of leaks.

2. Video cameras are located in the facility, which assist with leak detection.

3. Operators perform visual walk arounds of operating areas.



Release Containment/Control



1. Pressure relief valves on applicable tanks.

2. Key manual valves are chained and padlocked in their critical (open/closed) position.

3. Excess flow check valves in selected operations to limit releases.

4. Dikes are utilized around applicable vessels.

5. Water deluge systems are utilized at points within the facility to assure the ability to suppress releases.

6. Atmospheric scrubbers are utilized to reduce emissions/releases.



Release Mitigation



1. Standard operating procedures that control, isolate, and terminate leaks.

2. Personnel trained in emergency procedures.

3. Personal protective equipment (e.g., escape respirator, self-contained breathing apparatus, and supplied air breathing apparatus).



FIVE YEAR ACCIDENT HISTORY



The Plant has an excellent record of accident prevention over the past five years. There has been no RMP defined incident involving a regulated substance.



EMERGENCY RESPONSE PROGRAM



The 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 overall emergency response program for the Lake Charles Plant addresses personnel, plann
ing, resources, communications and alliances. Firestone has an emergency response team consisting of employees representing various units in the plant. This team has been trained in hazardous materials, confined-space rescue and medical training.



Planning has been developed in coordination with the Local Emergency Planning Commission (LEPC) and Mutual Aid as well as neighboring companies and communities. The Plant has the resources to respond to emergencies immediately; these include equipment, materials and additional labor. Fire water pumps, dry chemicals, foam, emergency vehicles, rescue equipment, spill control/cleanup material and water are available on-site for immediate use. Firestone has an alliance with the LEPC and Mutual Aid if additional equipment or personnel is needed.



An internal public-address system is in place to allow communication with employees to address a variety of conditions that may need their response. Communication with the public is done through the Community Awareness Emergency Response (CAER) sirens and the local broadcast media. There is also a 24-hour community information line, access to the Emergency Call System (ECAL) of the Calcasieu Office of Emergency Preparedness and use of a dedicated emergency radio signal.



PLANNED CHANGES TO IMPROVE SAFETY



Firestone is committed to continuous improvement in safety for its workers, the public and the environment. The Lake Charles Plant has a number of active programs (as outlined in the section above entitled "MANAGEMENT SYSTEM FOR PROCESS SAFETY/RISK MANAGEMENT) to identify opportunities for improvement.