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Eagle US 2 LLC, Lake Charles Plant

Parent Companies:
Eagle US 2 LLC
EPA Facility ID:
100000082082
Other ID:
70669PPGNDCOL
Facility DUNS:
8086506
Parent Company DUNS:
1344803

Location:

Address:
1300 PPG Drive
Westlake, LA 70669
County:
CALCASIEU
Lat / Long:
30.224, -93.283 (Get map)
Method:
Interpolation - Other
Description:
Facility Centroid
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Eagle US 2 LLC
Phone:
(337) 708-4500
Address:
P.O. Box 1000
Lake Charles, LA 70602 -1000
Foreign Address:

Person responsible for RMP implementation:

Name:
Daniel Pund
Title:
Process Safety Compliance Supt.

Emergency contact:

Name:
Rocky DeRoche
Title:
Shift Superintendent
Phone:
(337) 708-4340
24-hour phone:
(337) 912-2638
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
1,149
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1929-VO,2229-VO
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Feb. 12, 2015
Inspecting Agency:
US Coast Guard
Using Predictive Filing:
No

Processes:

Alkalies and Chlorine
RMP ID:
1000069009
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
37,000,000
No
Vinyl chloride [Ethene, chloro-]
75-01-4
69,000,000
No
Ethyl chloride [Ethane, chloro-]
75-00-3
15,000,000
No
Ammonia (anhydrous)
7664-41-7
80,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Daniel Pund
Address:
1300 PPG Drive
Westlake, LA 70602 -1000
Foreign Address:

Phone:
(337) 708-4095

Latest RMP Submission:

Date:
Jan. 14, 2016
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000055178

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 Alkalies and Chlorine)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
Model used:
PHAST Dispersion Modeling Program
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Administrative Controls
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 Alkalies and Chlorine)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
Model used:
PHAST Dispersion Modeling Program
Wind speed (meters per sec):
3.80
Stability class:
B
Topography:
Urban
Passive mitigation
considered:
  • Administrative Controls
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Alkalies and Chlorine)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
PHAST Dispersion Modeling Program
Wind speed (meters per sec):
3.80
Stability class:
B
Topography:
Urban
Passive mitigation
considered:
  • Administrative Controls
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

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 Alkalies and Chlorine)
CBI claimed:
No
Model used:
PHAST Dispersion Modeling Program
Passive mitigation
considered:
  • Administrative Controls
not considered:
  • Blast walls
Public OCA Chemical (in Alkalies and Chlorine)
CBI claimed:
No
Model used:
PHAST Dispersion Modeling Program
Passive mitigation
considered:
  • Administrative Controls
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 Alkalies and Chlorine)
CBI claimed:
No
Model used:
PHAST Dispersion Modeling Program
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

6. Five-year accident history

Feb. 18, 2015 at 23:45
ID:
1000042470
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
9 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
1.0 miles/h SW
Temperature:
50.00 ℉
Atmospheric stability:
F
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
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:
30
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised training
  • New process controls
Dec. 20, 2013 at 13:41
ID:
1000042469
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
57 minutes
Chemicals involved:
  • Hydrogen chloride (anhydrous) [Hydrochloric acid]
  • Vinyl chloride [Ethene, chloro-]
Release events:
Gas release
Fire
Weather conditions at time of event
Wind speed:
16.7000008 miles/h SSW
Temperature:
78.00 ℉
Atmospheric stability:
D
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
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:
$8000000
Known off-site impacts
Deaths:
0
Hospitalizations:
1
Medicals treatments:
27
Evacuated:
130
Sheltered-in-place:
5000
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Human error
  • Improper procedure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised maintenance
  • Revised training
  • Revised operating procedures
April 22, 2013 at 05:25
ID:
1000042468
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
5 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
8.0 miles/h N
Temperature:
45.00 ℉
Atmospheric stability:
D
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
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:
  • Human error
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Revised maintenance
  • Revised operating procedures
Dec. 24, 2012 at 13:19
ID:
1000042467
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
33 minutes
Chemicals involved:
  • Vinyl chloride [Ethene, chloro-]
Release events:
Gas release
Liquid spills/evaporation
Fire
Weather conditions at time of event
Wind speed:
6.9000001 miles/h W
Temperature:
75.00 ℉
Atmospheric stability:
A
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$3900000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
  • Smoke
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Improper procedure
  • Maintenance activity/inactivity
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised operating procedures
April 21, 2011 at 15:15
ID:
1000042457
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
1 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
8.0 miles/h NNW
Temperature:
95.00 ℉
Atmospheric stability:
C
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
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:
  • Equipment failure
  • Human error
  • Improper procedure
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures

7. Prevention: Program level 3

Alkalies and Chlorine, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000057673
Safety Review Date
Dec. 30, 2015
PHA Update Date
Jan. 8, 2016
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Controls
  • None Recommended
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 11, 2016
Training Review Date
June 25, 2014
Maintenance Review Date
Oct. 26, 2015
Maintenance Inspection Date
Jan. 12, 2016
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 11, 2016
Management of Change Review Date
June 28, 2015
Pre-startup Review Date
Jan. 12, 2016
Compliance Audit Date
Oct. 16, 2015
Compliance Audit Change Completion Date
May 31, 2017
Incident Investigation Date
Feb. 18, 2015
Incident Invest. Change Completion Date
Nov. 9, 2015
Participation Plan Review Date
Nov. 3, 2014
Hot Work Review Date
April 16, 2015
Contractor Safety Review Date
Sept. 29, 2015
Contractor Safety Eval. Date
Feb. 19, 2015

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:
Jan. 13, 2016
Local Response Agency:
Local Response Agency Phone:
(337) 721-3800
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



CHLORINE & CHLORINATED HYDROCARBON PROCESSES



EPA Facility ID #: 1000 0008 2082

LDEQ Facility ID: 1255

Eagle US 2 LLC, Lake Charles, LA



Accidental Release Prevention and Emergency Response Policies.

The Eagle US 2 LLC Lake Charles facility complies with OSHA's Process Safety Management Rule (29 CFR 1910.119), EPA's Risk Management Program Rule (40 CFR Part 68), other applicable state and federal EPA regulations, and applicable Coast Guard and Department of Transportation requirements. Eagle US 2 LLC also follows the Responsible Care; Codes of Management Practice, including the Responsible Care; Community Awareness Code of Management Practice, and Eagle US 2 LLC's own Community Awareness and Emergency Response (CAER) Policy to assure emergency preparedness and foster community right-to-know. Eagle US 2 LLC's CAER Policy requires each manufacturing plant to have a pro-active community awareness and emergency response program to handle emergencies that might happen in that facility. All of these activities form an integral part of Eagle US 2 LLC's overall Environment, Health and Safety Policy, whose goal is "to manufacture, sell, and distribute products worldwide in a manner that is safe and protective of our employees, neighbors, customers, other stakeholders, and the environment."



Regulated substances handled:

Eagle US 2 LLC's Lake Charles facility is part of the ChlorAlkali & Derivatives Strategic Business Unit of Eagle US 2 LLC Corporation. The facility is a fully integrated process that produces chlorine, caustic soda and various chlorinated hydrocarbons. These chemicals are utilized in many areas such as water treatment, food processing, medicines, plastics and Freon substitutes. Chlorine, ethyl chloride, vinyl chloride and ammonia are manufactured or stored in quantities that meet EPA Risk Management Program threshold values.



General accidental release prevention program and chemical specific prevention steps:

Personn
el, environmental, health and safety measures are included in all phases of the Eagle US 2 LLC Lake Charles operation. Detailed engineering and design standards are used. These standards may include national codes and standards, quality assurance inspections, over pressure protection systems, flammable and toxic gas detectors, emergency shutdown systems, a fire water system, computer controls for the processes and a procedure to systematically analyze potential hazards in each new process.



Employees at the facility receive job-appropriate training. The training program includes periodic retraining, as appropriate.



Safety, environmental, operating and training procedures are subject to periodic reviews and updates. Additional systems are in place to review proposed changes and assure that any new training requirements are met. Another system assures a detailed review for hazards in each operating unit on a prescribed frequency. All of the training and updating procedures are monitored.



Eagle US 2 LLC's Lake Charles facility has an array of maintenance and inspection programs that minimize the possibility of equipment or piping failures. Periodic equipment inspections are performed to assure the equipment integrity. The inspections utilize recognized codes and procedures that are followed by specially trained individuals. Preventive and predictive maintenance programs are utilized and can include vibration monitoring, infrared imaging, inspections by independent experts, inspections by insurance specialists and root-cause analysis investigations. Piping systems are inspected and tested with X-rays and hydrostatic tests prior to operation. The piping is monitored by a variety of methods to assure its condition. Maintenance personnel are included in many of the training and testing programs that the operators utilize. Additional training and procedures have been developed for activities that are specific to maintenance.



Five-year accident hist
ory:



An accidental release of chlorine occurred on 4/21/2011. One employee was treated for chlorine inhalation before returning to work.

A fire happened on 12/24/2012. One employee was treated for smoke inhalation before returning to work.

An accidental release of chlorine occurred on 4/22/2013. One employee was treated for chlorine inhalation before returning to work.

The 12-20-13 incident offsite numbers are estimates and to the best current knowledge and are subject to change. The 5 Year Incident Report input fields (drop down menu) have limited options and no opportunity to provide further explanation. Eagle US 2 LLC's Lake Charles has concluded that the incident was caused by a pipe rupture attributed to conditions that exceeded the safe operating limits during furnace re-start, without timely intervention to stem the extreme temperature event.

The offsite impact numbers are particularly difficult to accuretly account for and are estimates based on the following:

- Hospitalization: 1 (based on information received from S&H Manager

- Other Medical Treatment: 27 (based on newspaper release information;

American Press article 02-17-2014)

- Evacuated: 130 (estimate based on personnel working at PPG SIlicas)

- Sheltered in place: 5000 - This number is not the number of indiviuals that have sheletered in place , but the

number of households called and messages delivered by the Calcasieu Office of Emergency Prepardness to Zones

S-9, W-5, W-6, W-10 and W-11 .

An accidental release of chlorine occurred on 2/18/2015. There were no on site consequences. There were no offsite consequences except that a neighbor facility opted to shelter in place when they heard the alarms as a precaution (no mandatory shelter in place was issued).





Notification requirements are defined and assigned to specific individuals in the plant. Some individuals work a rotating shift allowing notifications 24 hours a
day. Other people are available at any time. Eagle US 2 LLC has a corporate emergency system that can be accessed at any time. This corporate system has additional resources for use in an emergency.



Planned changes to improve safety:

Eagle US 2 LLC is committed to the process of continuous improvement. This commitment extends beyond production into the environmental and safety aspects of our operations.