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Pioneer Americas LLC d/b/a/ Olin Chlor Alkali

Parent Companies:
Olin Chlor Alkali
EPA Facility ID:
100000082457
Other ID:
Facility DUNS:
62666540
Parent Company DUNS:
1338086

Location:

Address:
4205 Highway 75
St. Gabriel, LA 70776
County:
IBERVILLE
Lat / Long:
30.241, -91.107 (Get map)
Method:
GPS - Unspecified
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Olin Corporation
Phone:
(314) 480-1400
Address:
190 Carondelet Plaza, Suite 1530
Clayton, MO 63105 -3443
Foreign Address:

Person responsible for RMP implementation:

Name:
Valerie Matherne
Title:
ORC Specialist

Emergency contact:

Name:
Donald Pulliam
Title:
ORC Manager
Phone:
(225) 642-1885
24-hour phone:
(225) 642-1800
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(423) 954-2721
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Iberville Parish LEPC
Full-Time Equivalent Employees:
97
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
April 21, 2015
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

Alkalies and Chlorine Mfg
RMP ID:
1000041926
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
15,000,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Providence Engineering and Environmental Group, LLC
Address:
1201 Main Street
Baton Rouge, LA 70809
Foreign Address:

Phone:
(225) 766-7400

Latest RMP Submission:

Date:
May 8, 2013
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000034317

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 Mfg)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Area Chlorine Monitors
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 Mfg)
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:
  • Area chlorine monitors
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

None

5. Flammables: Alternative release

None

6. Five-year accident history

July 8, 2017 at 09:01
ID:
1000051737
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
3 hours and 7 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
4.5 miles/h NW
Temperature:
89.00 ℉
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:
$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:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised maintenance
  • Revised training
Dec. 29, 2014 at 06:32
ID:
1000038443
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
2 hours and 8 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
4.5 miles/h N
Temperature:
49.00 ℉
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:
Human Error
Contributing factors:
  • Overpressurization
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures
March 11, 2009 at 11:15
ID:
1000028379
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:
7.0 miles/h S
Temperature:
75.00 ℉
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:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures
  • Retrain operations, maintenance, & contractor personnel on hot bolting procedures
Aug. 17, 2008 at 08:30
ID:
1000028378
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
32 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
2.0 miles/h SE
Temperature:
81.00 ℉
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:
2
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:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised training
  • Revised emergency response plan

7. Prevention: Program level 3

Alkalies and Chlorine Mfg, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000036518
Safety Review Date
Aug. 24, 2012, since latest RMP submission
PHA Update Date
Aug. 24, 2012, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Enclosure
  • Neutralization
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Aug. 24, 2012, since latest RMP submission
Training Review Date
Sept. 1, 2012, since latest RMP submission
Maintenance Review Date
Oct. 11, 2012, since latest RMP submission
Maintenance Inspection Date
March 9, 2012, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 30, 2012
Management of Change Review Date
Oct. 23, 2012
Pre-startup Review Date
Nov. 16, 2012
Compliance Audit Date
April 18, 2013
Compliance Audit Change Completion Date
Oct. 26, 2015
Incident Investigation Date
March 11, 2009
Incident Invest. Change Completion Date
June 1, 2009
Participation Plan Review Date
June 13, 2011
Hot Work Review Date
June 1, 2009
Contractor Safety Review Date
Aug. 7, 2012, since latest RMP submission
Contractor Safety Eval. Date
April 30, 2012, 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:
May 31, 2012
Local Response Agency:
Local Response Agency Phone:
(225) 687-5140
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

2644 LDEQ Facility ID Number



INTRODUCTION

Pioneer Americas, LLC d/b/a Olin Chlor Alkali (Olin) St. Gabriel facility occupies approximately 60 acres of a 300-acre tract located along Highway 75 (River Road), in St. Gabriel, Iberville Parish, Louisiana. The primary products produced at St. Gabriel are chlorine and sodium hydroxide (caustic). Chlorine is used in the purification and sanitation of drinking water, hospital sanitation, swimming pool treatment, and laundry bleach. Chlorine is a basic building block chemical used in the production of industrial chemicals and in the construction industry. In addition, more than 85% of pharmaceuticals are derived from chlorine derivatives. Sodium hydroxide is used in the production of products as diverse as soap, latex paint, rayon, and nylon clothing.



Olin's environmental, safety, and health policies emphasize the importance of safeguarding our employees, contractors, the environment and the community from potential exposures to chemical materials, by-products and end products, and to limit adverse effects on the physical environment, in which its activities are carried out. Olin has implemented programs to ensure compliance with regulations and continued improvement of environmental, health and safety performance over the years. One part of these programs is a risk management plan (RMP) that helps manage the risks at the facility and that complies with the requirements of the Environmental Protection Agency's (EPA) Rule 40 CFR Part 68.



Chlorine is the only chemical that the RMP regulation pertains to at the facility. There are no other toxic or flammable substances on-site that exceed RMP thresholds. Olin is subject to OSHA's Process Safety Management (PSM) standard, as well as Program 3 of EPA's RMP Rule. Olin complies with the regulation and, in addition, has implemented several elements of the RMP in non-RMP process areas. Olin was the first OSHA Voluntary Protection Program (VPP) Star site in Louisiana, and
has maintained that rating since 1985. This entails a complete audit by OSHA of our entire Safety and Health programs every 3-4 years. In addition, Olin has received the EPA's Environmental Excellence Award from the State of Louisiana multiple times. Facility personnel participate in monthly communication meetings with the local Community Advisor Panel (CAP) to discuss and explain any facility safety and environmental issues that could potentially affect the community.



OFF-SITE CONSEQUENCE ANALYSIS

The EPA has defined the worst case scenario as the hypothetical rupture and full release of all contents of the facility's largest storage tank taking into account the administrative controls, assuming all safeguards have failed, during extremely stable weather conditions. While the probability of this scenario is extremely low, it does provide a template for emergency response planning. The release duration for this scenario is ten minutes with an estimated quantity released of 750,000 lbs. The EPA's RMP*Comp was used in the analysis. The computer-generated model for the largest chlorine tank at the facility results in a planning zone of 25 miles. Based on this analysis, public and environmental receptors would be affected by the worst case scenario.



Facilities must also prepare an alternative scenario that could have an off-site impact, based on facility operations. The alternative scenario may take into account emergency response control measures and actual storage and weather conditions. The alternative release scenario, although unlikely, is a more realistic scenario than the worst case scenario. The alternate scenario for this facility is the rupture of a loading line while actively loading a chlorine rail car. For planning purposes only, it is assumed that the safety check valve on the rail car does not engage. Scenario 1 analyzed a release of 243 lbs over 0.2 minutes. The EPA's RMP*Comp software was used in this analysis. The computer-generated model for th
is release results in a possible impact of up to 1.3 miles. There are public and environmental receptors that would be affected by this alternative release scenario.



PREVENTION PROGRAM

Olin has a long-standing commitment to the safety of the general public, to Olin employees, and to the preservation of the environment. One primary portion of this commitment is the prevention of accidental releases of hazardous substances in and around the facility. Olin utilizes engineering controls, inspection programs, and detailed procedures as a means to prevent accidental releases. In the event of a release, the facility has well trained emergency response teams to contain, mitigate, monitor, and stop the release. In addition to handling the release, the facility has also established a wide variety of communication systems to alert the community in the event of a significant release. In conjunction with the local emergency planning committee (LEPC), the facility has the ability to notify the local community through cable override systems, radio broadcasts, and/or through an automated telephone notification system.

The facility has developed a comprehensive accidental release prevention program based on the elements of OSHA's PSM. The elements are recognized as being fully implemented and integrated into the standard operating practices of the facility.

Summarized below are brief descriptions of each part of the prevention program along with details of the emergency response program and trade secrets:



Process Safety Information

Olin maintains a variety of technical documents to ensure that process hazards are understood and that the facility is operated and maintained in a safe manner. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.



Chemical-specific information, including exposure hazards and emergency response/exposure tr
eatment considerations, is provided in Safety Data Sheets (SDS). This information is supplemented by documents that specifically address any known hazards associated with the inadvertent mixing of chemicals. Critical information on chlorine properties, chlorine production techniques, and chlorine handling is also made readily available to facility personnel through SDS, along with current drawings, and comprehensive operating procedures.



Olin also maintains numerous technical documents that provide information about the design and construction of process equipment. Equipment specifications and vendor manufacturing information is used for equipment and system designs. Additionally, the Chlorine Institute provides information and guidelines in the form of regularly updated technical pamphlets. This information is used while conducting Process Hazard Analyses (PHA) and Pre-Startup Safety Reviews (PSSR) and is the basis for developing our operating procedures and chemical process systems. This information includes materials of construction, piping and instrumentation diagrams, design pressure and temperature ratings, electrical rating of equipment, etc. 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.



For specific process areas, the facility has documented safety-related upper and lower process limits for specific process parameters (e.g., temperature, level, composition) in the operating procedures for each process unit. The facility ensures that the process is maintained within these limits by using process controls and monitoring instruments, operating procedures, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).



Process Hazard Analysis

The facility has a comprehensive PHA program
to help ensure that hazards associated with the chlorine processes are identified and controlled. PHAs are performed on an established schedule for RMP/PSM processes. A trained team with a certified PHA Leader performs PHA's on the RMP process and other process nodes not regulated by the standard. The analysis is conducted in accordance with regulatory requirements, generally accepted industry standards, and guidance from safety organizations such as the Center for Chemical Process Safety.



The PHA team recommendations are forwarded to management for resolution. The recommendations are then prioritized and implemented accordingly. Implementation of safety improvements in response to PHA findings is completed in a timely manner. All approved safety improvements being implemented in response to PHA team recommendations are tracked until they are complete. The final resolution of each recommendation is documented and retained.



To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, Olin periodically updates and revalidates its PHAs of affected units. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The team findings are forwarded to management for consideration, and are documented and retained. The final resolution of the recommendations is also documented and retained.



Operating Procedures

The facility maintains written procedures that address various modes of process operations, 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 can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and annually certified by the area supervisor as current and accurate. P
rocedures are maintained current by revising them as necessary to reflect changes made to the process. In addition, the Olin operating procedures discuss consequences of deviating from the safe limits and provide guidance on how to respond to events that result in exceeding safe operating limits for specific process or equipment parameters. The written operating procedures are readily available to operators and for other personnel to use as necessary to safely perform their job tasks. Changes to operating procedures are tracked through the management of change (MOC) process.



Training

To complement the written procedures for process operations, Olin has implemented a training program for all employees involved in operating a process. New employees receive basic training in Olin operations if they are not already familiar with such operations. After operators demonstrate (e.g., through tests, skills demonstration) 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 ongoing training and refresher courses on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level and to continually enhance the capabilities of the employees. This refresher training is conducted every three years. Training in operating procedures is confirmed with a written test and walk-through of the process. All of this training is documented for each operator, including the means used to verify that the operator understood the training.



Mechanical Integrity

Olin has well-established practices and procedures to ensure that facility equipment is in a safe operating condition. The mechanical integrity program is designed to ensure that plant equipment is maintained in/at the minimum designed specification. The basic aspects of this program include (1) the development of a maintenance schedule for equipment involved in chlorine service
and critical safety equipment, (2) developing written maintenance procedures, (3) conducting training, (4) performing and documenting inspections and tests, (5) correcting identified deficiencies, and (6) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment.



Olin has a documented inspection program that enhances the integrity of critical equipment and systems at the facility. 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 to 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 (e.g., adequate wall thickness for pressure vessels).

Recommendations from equipment inspections are then prioritized and implemented accordingly. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or an MOC 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. Olin incorporates quality assurance measures into 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.



Management of Change

Olin has a comprehensive system to manage changes to processes. Written procedures are in place to ensure that all process changes at the facility undergo several levels of review at the planning stage. The system requires that c
hanges 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. Systems are also in place to assure that communications of the changes will be made to all affected personnel before changes are implemented. Affected chemical hazard information, process technology information, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change.



Pre Start Up Reviews

Olin conducts a pre-startup safety review for any systems that require a change in the process safety information (not required for replacement in kind). The purpose of the review is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides an additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The review team uses checklists to verify all aspects of readiness. A review involves field verification of the construction and serves a quality assurance function.



Compliance Audits

To help ensure that the accident prevention program is functioning properly, Olin periodically conducts audits to confirm the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. These audits are led by qualified personnel within the Olin Corporation as required. The findings are forwarded to Olin management for resolution. Corrective actions taken in response to the audit team's fi
ndings are tracked until they are complete. The final resolution of each finding is documented.



Incident Investigation

Olin 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 determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team, which may include contractors, documents its findings, develops recommendations to prevent a recurrence, and forwards these results to Olin 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 facility personnel who could be affected by the findings. The facility embraces the Total Incident Reporting System to assure that all potential incidents are captured and addressed in a timely manner. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.



Employee Participation

Employee participation is the cornerstone of the VPP. Operators, maintenance technicians, and engineers, as well as supervisors and managers participate fully in Hazard and Operability (HAZOP) Studies, procedure development, trainings, and incident investigations. A broad range of facility personnel also make up the safety committee and participate in a wide range of safety related activities.



Hot Work & Work Permits

The facility's hot work procedure requires that detailed permitting activities take place before, during, and after any job that has the potential to provide a source of ignition. The permit is followed through to completion of the work and those permits are maintained in the EHS department.
The plant has implemented other work permits to assure safe work conditions are communicated to maintenance and contract personnel.



Contractor Safety

Olin uses contractors to supplement its work force during periods of increased maintenance or construction activities. Some contractors work on or near process equipment; therefore, Olin 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 Olin personnel of any hazards that they find during their work. The contractor safety program places stringent qualification requirements on contracting firms before entering into the facility to perform work. Contractors provide training documentation of their employees that meet or exceed the requirement of the job scope. Contactors participate in an industry supported 24-hour safety certification and then site specific orientation before being permitted to work in the facility. Contractors are provided with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, (4) safe work practices, and (5) a work permit process (i.e., for hot work, confined space, etc.) prior to their beginning work.

Contractor safety performance and compliance with facility safety requirements are monitored during all contract projects. Contractor performance evaluations can be found in purchasing files.



EMERGENCY RESPONSE PROGRAM

Olin maintains a comprehensive written Emergency Action Plan to protect the safety of workers and the public, as well as, the environment. The plan provides for 24 hour/day, 365 day/year response capabilities. The manual includes procedures for responding to a release of a regulated substance. The procedures address all aspects of emergency response, includ
ing proper first aid and medical treatment, 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. Facility responders are trained and qualified on the proper response techniques for the chemicals associated with the facility and are equipped with the necessary equipment to perform critical response procedures.

As part of the ongoing training program for responders, routine drills are conducted. These include both tabletop planning sessions, as well as, full field responses to simulated incidents at the facility. Additionally, Olin conducts joint drills with the Iberville Parish Office of Emergency Preparedness and works closely with that office to coordinate emergency response actions. Olin is also an active member of the Geismar Area Mutual Aid group, which provides equipment resources for emergency response from other area facilities.

The facility is equipped with a facility-wide alarm system. When the alarm system is activated, response teams assemble immediately; including those assigned the task of making critical notifications. Current emergency phone numbers are maintained in the control room of the facility and in the Emergency Action Plan, which is immediately available in several critical areas of the plant so that timely notifications can be made.

The facility-wide chlorine monitoring network has monitors stationed at key locations throughout the facility. These monitors can detect chlorine at low concentrations. Operations personnel monitor the real-time readings from the chlorine sensors and will respond immediately to any detection. Additionally, the facility utilizes a computer modeling system that can help to plan potential scenarios and develop appropriate responses.



Trade Secrets

Olin operates under North American Industrial Classification System (NAICS) code 32518 (Other Basic Inorgan
ic Chemical Manufacturing). The facility produces chlorine and sodium hydroxide (caustic). There are currently no chemicals or components at the facility that carry the Trade Secret label.



FIVE-YEAR HISTORY

Olin is committed to minimizing potential risks to the public, employees and environment. A fundamental part of this commitment is the prevention of accidental releases of hazardous substances in and around the facility. Within the past five years, there has been one releases of a regulated substance from a regulated process that has occurred and resulted in injuries. In December 2014, a gas release occurred for a period of 2 hours that resulted in 12,000 lbs being released and one injury. As a result of the incident, changes were introduced to decrease the probability of the incident reoccurring. If another incident would occur, as per the procedure, a thorough investigation would be initiated to determine the causes of the incident. In addition, the incidents would be reported to the appropriate agencies.



SAFETY IMPROVEMENTS

Olin believes that continuous improvement is the key to success in the future. This is especially true in the safety, health, and environmental areas. Olin continuously looks for opportunities to improve our abilities in protecting our people and our community. Olin actively solicits and implements safety and process improvement suggestions through our safety committee, our employee suggestion program, and our Total Quality Improvement program, to solve problems and implement solutions. Currently, our ongoing safety improvement efforts include the replacement of process piping, improved equipment reliability and improved work systems in the maintenance department.